ITAT Delhi Judgments — July 2026

The Tribunal held that the Goetze (India) Ltd. ruling applies to assessing authorities, not appellate forums like the ITAT. It noted that the assessee consistently received exemption for similar income in preceding and succeeding years, indicating the income is indeed exempt.

The Tribunal condoned the delay in filing the appeal, finding reasonable cause and no deliberate intention to delay. The issue of share capital was set aside to the CIT(A) for fresh adjudication with directions to obtain a remand report from the AO.

The Tribunal held that the learned CIT(E) erred in rejecting the assessee's application for registration. Regarding the donation of ₹50,000, the Tribunal found from the paper book that it was made on 30th October, 2025, which contradicted the CIT(E)'s premise that it was made after the issuance of notice. The Tribunal accepted the assessee's categorical admission that no sports activities were carried out for the last three years, but noted that taxes were paid on the accumulated income for the relevant assessment years. The Tribunal observed that the assessee had complied with all conditions under Section 12A, and the CIT(E) had not cast any doubt on the charitable nature of the assessee's objects and activities. Therefore, the Tribunal concluded that the assessee is a genuine trust and the rejection of registration by the CIT(E) was without basis. The Tribunal directed the learned CIT(E) to grant registration to the assessee trust. The order of the learned CIT(E) was reversed, and the appeal of the assessee was allowed.

The Tribunal held that the Revenue had not challenged the CIT(A)'s finding regarding the invalidity of the reassessment proceedings. Therefore, the CIT(A)'s order quashing the reassessment order became final.

The Tribunal heard both parties and, with no objection from the Department, allowed the assessee's request to withdraw the appeals. The appeals were accordingly dismissed as withdrawn.

The Tribunal heard both parties and, with no objection from the Department, allowed the assessee's request to withdraw the appeals. Consequently, the appeals were dismissed as withdrawn.

The Tribunal agreed with the assessee's justification for non-compliance and, in the interest of justice, remitted the matter back to the CIT(A) for fresh adjudication. The assessee was directed to comply with future notices.

The Tribunal found that the lower authorities did not consider the assessee's accumulated past savings and agricultural income. Therefore, a lumpsum addition of Rs. 3 lakhs was considered to meet the ends of justice.

The Tribunal held that the provisions of section 153C are not applicable for searches initiated on or after April 1, 2021. Since the date of handing over the seized material to the assessee's Assessing Officer was after April 1, 2021, the jurisdiction under section 153C was vitiated.

The Tribunal noted that the quantum appeal related to the additions had been remanded back to the AO. Therefore, the penalty proceedings were also remitted to the AO to decide afresh after giving the assessee an opportunity of being heard.

The Tribunal heard both parties and, with no objection from the Department, allowed the assessee's request to withdraw the appeals. Consequently, the appeals were dismissed as withdrawn.

The Tribunal considered the applications for withdrawal and, with no objection from the Department, allowed the withdrawal. Consequently, all six appeals were dismissed as withdrawn.

The Tribunal condoned the delay in filing the appeal before the CIT(A) by holding that the assessee had sufficient cause. The matter was restored to the AO to pass a fresh order after providing an opportunity of being heard.

The Tribunal held that the notice for reassessment was issued beyond three years from the end of the relevant assessment year and the approval obtained was from an incompetent authority as per the amended Section 151 of the Act. Therefore, the reassessment order was quashed.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that an order giving effect to a higher authority's order is appealable under Section 246A. It also ruled that partial refunds should be adjusted first against interest due and then against the principal amount, following the jurisdictional High Court's precedent.

The Tribunal heard both parties and, with no objection from the Department, allowed the assessee's request to withdraw the appeals. Consequently, the appeals were dismissed as withdrawn.

The Tribunal set aside the orders of the CIT(A) and remanded the matters back for fresh consideration. The assessee is to be granted an opportunity of being heard and to present evidence.

The Tribunal set aside the orders of the CIT(A) and remanded the matters back for fresh consideration. The assessee is to be granted an opportunity of being heard and to present evidence.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the sale of milk by the assessee trust is not commercial in nature and is an inseparable and natural consequence of maintaining cows, which is the primary charitable object. The Tribunal noted that the production of milk is incidental to the charitable activity of running a gaushala, and the sale proceeds are utilized for maintaining the gaushala and carrying out its charitable objects. The Tribunal respectfully followed the judgment in Sabarmati Ashram Gaushala Trust, wherein it was held that the sale of milk was merely incidental to carrying out charitable objects and there was no element of profit motive to attract the proviso to Section 2(15). The Tribunal found that the CIT(E) had misunderstood and misapplied the ratio of the Supreme Court judgment in ACIT(Exemptions) Vs. Ahmedabad Urban Development Authority. Consequently, the Tribunal directed the Learned CIT(E) to grant registration to the assessee trust under Section 12A. As a consequential relief, the appeal concerning approval under Section 80G was also allowed.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the sale of milk by the assessee trust is not commercial in nature and is an inseparable and natural consequence of maintaining cows, which is the primary charitable object. The Tribunal noted that the production of milk is incidental to the charitable activity of running a gaushala, and the sale proceeds are utilized for maintaining the gaushala and carrying out its charitable objects. The Tribunal respectfully followed the judgment in Sabarmati Ashram Gaushala Trust, wherein it was held that the sale of milk was merely incidental to carrying out charitable objects and there was no element of profit motive to attract the proviso to Section 2(15). The Tribunal found that the CIT(E) had misunderstood and misapplied the ratio of the Supreme Court judgment in ACIT(Exemptions) Vs. Ahmedabad Urban Development Authority. Consequently, the Tribunal directed the Learned CIT(E) to grant registration to the assessee trust under Section 12A. As a consequential relief, the appeal concerning approval under Section 80G was also allowed.

The Tribunal held that the appeal filed by the Revenue was not maintainable due to low tax effect. This was in light of the CBDT Circular No. 9/2024, which revised the monetary limit for filing appeals to the Tribunal up to Rs. 60 Lacs and applied to pending appeals.

The Tribunal held that the AO relied solely on an investigation report without conducting independent inquiries or establishing a direct link between the assessee and any manipulative activities. The Tribunal noted that similar appeals involving the same scrip and investigation report were allowed for other family members.

The Tribunal set aside the orders of the CIT(A) and remanded the matters back for fresh consideration. The assessee is to be granted an opportunity of being heard and to present evidence.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal set aside the orders of the CIT(A) and remanded the matters back for fresh consideration. The assessee is to be granted an opportunity of being heard and to present evidence.

The ITAT held that the explanation provided by the assessee for the delay was sufficient cause for condonation, following the liberal approach laid down by the Supreme Court. Consequently, the appeals were restored to the Assessing Officer for fresh adjudication.

The ITAT held that the explanation provided by the assessee for the delay was sufficient cause for condonation, following the liberal approach laid down by the Supreme Court. Consequently, the appeals were restored to the Assessing Officer for fresh adjudication.

The Tribunal noted that the assessee did not file a condonation petition for the delay and failed to rectify the defects in the appeal. Therefore, the appeal was dismissed as defective.

The Tribunal held that the penalty order was time-barred as the action for imposition of penalty was initiated on February 25, 2023 (date of assessment order), and the penalty order was passed beyond the prescribed limitation period under Section 275(1)(c).

The Tribunal acknowledged the significant delay but, in the interest of natural justice, condoned the delay. The matter was remanded back to the CIT(A) for fresh adjudication on merits.

The Tribunal condoned the delay in filing the appeal before the CIT(A) to ensure natural justice. The matter was remanded back to the CIT(A) for fresh adjudication on merits.

The Tribunal found the CIT(A)'s 9% profit calculation to be too high and the assessee's 2% to be low, considering the mining business typically yields around 3% profit. Therefore, the Tribunal directed that profit be calculated at 3% of total turnover.

The Tribunal, considering the interest of justice and the principle of natural justice, decided to remand the matter back to the CIT(A). This was despite the assessee's non-compliance with the notices issued by the CIT(A).

The Tribunal restored the matter to the CIT(A) for fresh adjudication on merits, directing the CIT(A) to provide the assessee with an opportunity of being heard. The assessee was also instructed to make necessary compliances.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, failing to explicitly state that the seized material had a bearing on the determination of the total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.

The Tribunal held that the Section 153C assessments were not sustainable in law because the Assessing Officer's satisfaction was not properly recorded, lacking explicit mention of the seized material having a bearing on the determination of total income.