ITAT Delhi Judgments — July 2026

The Tribunal held that the initiation of proceedings under Section 153C was invalid because the date of handing over the seized material to the assessee's AO was after April 1, 2021, when Section 153C(3) barred its application. Consequently, the assessment orders were quashed.

The Tribunal found that the CIT(E) rejected the applications without due consideration of facts and without applying its mind. It was noted that a reasonable opportunity of being heard is a right of every taxpayer.

The Tribunal found that the CIT(E) rejected the applications without due consideration of facts and without applying its mind. It was noted that a reasonable opportunity of being heard is a right of every taxpayer.

The Tribunal held that the notice issued under Section 148 of the Act on July 31, 2022, for AY 2014-15 was barred by limitation, quashing the reassessment. Similarly, for AY 2015-16, the notice was also found to be time-barred, leading to the quashing of reassessment and consequential penalty.

The Tribunal condoned the delay in filing the appeals. It found that the CIT(E) had rejected the assessee's applications without due consideration and without providing a reasonable opportunity of being heard.

The Tribunal condoned the delay in filing the appeals. It found that the CIT(E) had rejected the assessee's applications without due consideration and without providing a reasonable opportunity of being heard.

The Tribunal upheld the CIT(A)'s decision, finding the assessee's explanation for the seized cash to be without merit due to lack of supporting material. The addition made by the Assessing Officer was confirmed.

The Tribunal held that the initiation of proceedings under Section 153C was invalid because the date of handing over the seized material to the assessee's AO was after April 1, 2021, when Section 153C(3) barred its application. Consequently, the assessment orders were quashed.

The Tribunal condoned the delay in filing the appeals. It found that the assessee's right to natural justice was violated as the impugned order was passed without adequate opportunity of being heard.

The Tribunal held that the initiation of proceedings under Section 153C was invalid because the date of handing over the seized material to the assessee's AO was after April 1, 2021, when Section 153C(3) barred its application. Consequently, the assessment orders were quashed.

The Tribunal condoned the delay in filing the appeals. It found that the assessee's right to natural justice was violated as the impugned order was passed without adequate opportunity of being heard.

The Tribunal found that the CIT(E) had not properly considered the facts and evidence, including the ongoing construction of a Dharamshala, which is a charitable activity. The Tribunal set aside the CIT(E)'s orders and remitted the matter back for reconsideration.

The Tribunal found that the assessee's right to natural justice was violated as the order was passed without adequate opportunity of being heard. Therefore, the matter was remitted back to the CIT(E) for fresh adjudication.

The Tribunal found that the assessee's right to natural justice was violated as the order was passed without adequate opportunity of being heard. Therefore, the matter was remitted back to the CIT(E) for fresh adjudication.

The Tribunal held that the assessment order was indeed time-barred, citing a Supreme Court decision. It also found the penalty for the second PAN to be unjustified due to a bona fide mistake and the subsequent surrender of the PAN.

The Tribunal noted that the CIT(E) rejected the applications without due consideration of facts and alluded to a non-application of mind. The Tribunal set aside the impugned orders and remitted the matter back to the CIT(E) for fresh adjudication.

The Tribunal found that the CIT(E) rejected the applications without due consideration of facts and without proper application of mind. The Tribunal set aside the impugned orders and remitted the matter back to the CIT(E) for fresh adjudication.

The Tribunal held that the addition on account of trade payables was not sustainable as the AO did not challenge the underlying sale-purchase transactions and the assessee had provided substantial evidence. Similarly, the addition for cash deposits was deleted as the assessee's cash flow statement showed sufficient cash to justify the deposits.

The Tribunal found that the CIT(E) had not properly considered the facts and evidence, including the ongoing construction of a Dharamshala. The Tribunal set aside the CIT(E)'s orders and remitted the matter back for consideration.

The Tribunal noted that the assessee's right to natural justice was violated as the order was passed without adequate opportunity of being heard. Therefore, the matter was remitted back to the CIT(E) for fresh adjudication.

The Tribunal noted that the assessee's right to natural justice was violated as the order was passed without adequate opportunity of being heard. Therefore, the matter was remitted back to the CIT(E) for fresh adjudication.

The Tribunal held that the notice issued under Section 148 of the Act on July 31, 2022, for AY 2014-15 was barred by limitation, quashing the reassessment. Similarly, for AY 2015-16, the notice was also found to be time-barred, leading to the quashing of reassessment and consequential penalty.

The Tribunal held that due to communication gaps and non-compliance with Section 250(6) of the Act, the order was inappropriate. The appeal was set aside and restored to the CIT(A) for fresh adjudication.

The Tribunal held that earning rental income does not disqualify a charitable institution from registration under Section 12A if the income is applied towards its charitable objects. The assessee's primary activity is education, which falls under the definition of charitable purpose.

The Tribunal held that the assessment order was indeed time-barred, citing a Supreme Court decision. It also found the penalty for the second PAN to be unjustified due to a bonafide mistake and lack of malafides.

The Tribunal found that the CIT (Exemptions) had erroneously assumed the validity period of the provisional approval. The application was filed within the statutory time limit, making the rejection incorrect.

The Tribunal held that employer's contribution to PF/ESI paid before the due date of filing the return under Section 139(1) is allowable. However, employee's contribution to PF/ESI deposited after the prescribed due dates in the respective Acts is disallowable under Section 36(1)(va).

The Tribunal deleted additions related to purchases from Shri Ajit Singh, Shri Anant Rastogi, and Shri Ramesh Bansal, finding the genuineness of these purchases established. However, the addition for delayed employee PF/ESI contributions was upheld.

The Tribunal held that additions cannot be made solely on the basis of third-party statements without corroborative evidence. The AO failed to provide any supporting evidence to link the alleged cash payment to the assessee.

The Tribunal found that the assessee had provided all relevant evidence regarding the identity of the creditors, who were non-banking financial companies. The fact that these loans were repaid was also considered significant. Relying on a jurisdictional High Court decision, the Tribunal upheld the deletion of additions made by the CIT(A).

The Tribunal found that the assessee had provided all relevant evidence regarding the identity of the creditors, who were non-banking financial companies. The fact that these loans were repaid was also considered significant. Relying on a jurisdictional High Court decision, the Tribunal upheld the deletion of additions made by the CIT(A).

The Tribunal held that the notice under Section 143(2) was issued by an officer without jurisdiction, rendering the notice and the subsequent assessment order invalid. The defect in issuing the notice was considered incurable.

The Tribunal held that the reassessment notices were issued beyond the permissible time limit under Section 149(1)(b) as the cumulative expenditure for each distinct event did not exceed the threshold of Rs. 50 lakhs. Therefore, the reassessment orders were quashed.

The Tribunal held that the reassessment notices were issued beyond the permissible time limit under Section 149(1)(b) as the cumulative unexplained expenditure for each separate event did not exceed the threshold of Rs. 50 lakhs. Therefore, the reassessment orders were quashed.

The Tribunal held that the reassessment notices were issued beyond the permissible time limit under Section 149(1)(b) as the cumulative expenditure for each distinct event did not exceed the threshold of Rs. 50 lakhs. Therefore, the reassessment orders were quashed.

The Tribunal held that the initiation of proceedings under Section 153C was invalid because the date of handing over the seized material to the assessee's AO was after April 1, 2021, when Section 153C(3) barred its application. Consequently, the assessment orders were quashed.

The Tribunal held that the notice under Section 148 was invalid as it was issued after three years from the end of the relevant assessment year without the approval of the competent authority as per the amended Section 151 of the Act. Consequently, the reassessment order was quashed.

The Tribunal noted that the information available to the AO was only about procuring a loan by pledging gold, not about the purchase of gold ornaments in the relevant year. Since the AO could not verify when the gold ornaments were procured and the assessee also failed to provide details, the matter was remanded for verification.

The Tribunal held that the notice under Section 143(2) was issued by an officer who lacked the prescribed jurisdiction according to CBDT instructions. Consequently, the assessment order was quashed as being bad in law.

The Tribunal held that the notices issued under Section 153C were barred by limitation as the satisfaction note was recorded after the permissible period. Consequently, the assessment orders were quashed.

The Tribunal held that the notices issued under Section 153C were barred by limitation as the satisfaction note was recorded after the permissible period. Consequently, the assessment orders were quashed.

The Tribunal found that the assessee was denied a fair opportunity to present their case before the CIT(A). Therefore, the matter was remanded back to the CIT(A) to admit fresh evidence and obtain a remand report from the AO.

The Tribunal set aside the CIT(A)'s order and remanded the matter back for fresh adjudication. The CIT(A) is directed to adjudicate on merits after ensuring the assessee rectifies any defects in Form 35 and providing an opportunity of being heard.

The Tribunal held that the addition under Section 68 was unjustified as the cash sales were recorded in the books and supported by stock availability. However, the direction to verify deductions under Sections 80C and 80G was not prejudiced to the assessee.

The Tribunal held that the AO did not provide the relied-upon materials nor an opportunity for cross-examination. Considering the assessee as a regular investor and the lack of evidence to prove sham transactions, the addition made by the AO was deleted.

The CIT(A) correctly set aside the assessment order and remitted it back to the Assessing Officer for fresh examination, considering the ex-parte nature of the assessment and the interest of natural justice. The Tribunal found no illegality in this decision.

The Tribunal held that the Pr. CIT erred in invoking Section 263 for issues not forming the basis of the original scrutiny. However, the assessment order was considered erroneous regarding the verification of business purchases from parties who did not respond to notices.

The Tribunal held that while the assessee's explanation for the cash deposits was not fully discharged, a lumpsum addition of Rs. 2 lakhs would be just and proper, granting relief of Rs. 27,00,000/-. The assessment under Section 115BBE was directed to be under normal provisions as the section was effective from 01.04.2017.

The Tribunal restored the issue to the file of the CIT(E), granting the assessee one final opportunity to substantiate its claim with relevant documents and evidence.

The Tribunal restored the issue to the file of the CIT(E), granting the assessee one final opportunity to substantiate its claim with relevant documents and evidence.