ITAT Delhi Judgments — July 2026

The Tribunal acknowledged that while the purchases were treated as bogus, the assessee's business activities and corresponding receipts/sales were not questioned. Therefore, a lumpsum disallowance of 5% of the alleged bogus purchases was deemed just and proper.

The Tribunal held that the notice under Section 148 was invalid because it was not approved by the higher authority (PCCIT) as mandated by Section 151(ii) for reassessments initiated after three years. Consequently, the entire reassessment proceeding and the resultant assessment order were quashed.

The Tribunal allowed the assessee's appeal regarding unexplained investment in gold coins and Ginnis, finding they belonged to the assessee's sister and brother. The Tribunal also allowed the assessee's appeal concerning unexplained investment in jewellery, directing credit for jewellery owned by the assessee's sister.

The Tribunal allowed the assessee's request to withdraw the appeal. The appeal was dismissed as withdrawn.

The Tribunal allowed the assessee's appeal regarding unexplained investment in gold coins and Ginnis, finding they belonged to the assessee's sister and brother. The Tribunal also allowed the assessee's appeal concerning unexplained investment in jewellery, directing credit for jewellery owned by the assessee's sister.

The Tribunal held that its Delhi benches do not have territorial jurisdiction to decide the appeal. This is based on the situs of the Assessing Officer framing the assessment.

The Tribunal held that reopening proceedings initiated against a dissolved partnership firm are not sustainable in law. Therefore, the reassessment proceedings were quashed.

The ITAT found no merit in the Revenue's appeal, noting that the CIT(A) had already directed the AO to initiate fresh proceedings under section 147 of the Act. The tribunal upheld the CIT(A)'s decision to annul the assessment order.

The Tribunal held that the date of recording the satisfaction note or receipt of records by the AO of the non-searched person is the relevant date for determining the 'deemed date of search'. In this case, the deemed date of search was 19.09.2022, rendering the assessment under Section 153C invalid.

The Tribunal allowed the assessee's appeal regarding unexplained investment in gold coins and Ginnis, finding they belonged to the assessee's sister and brother. The Tribunal also allowed the assessee's appeal concerning unexplained investment in jewellery, directing credit for jewellery owned by the assessee's sister.

The Tribunal held that the date of recording the satisfaction note or receipt of records is the relevant date for determining the 'deemed search date' in the case of a non-searched person. As the satisfaction note was dated 19.09.2022, Section 153C was not applicable.

The Tribunal held that the date of recording the satisfaction note or receipt of records by the AO of the non-searched person is the relevant date for determining the 'deemed date of search'. In this case, the deemed date of search was 19.09.2022, rendering the assessment under Section 153C invalid.

The Tribunal found that the AO made an ex-parte order and the CIT(A) did not call for a remand report on additional documents submitted by the assessee. Therefore, the matter was remitted back to the AO for fresh consideration.

The Tribunal allowed the assessee's appeal regarding unexplained investment in gold coins and Ginnis, finding they belonged to the assessee's sister and brother. The Tribunal also allowed the assessee's appeal concerning unexplained investment in jewellery, directing credit for jewellery owned by the assessee's sister.

The Tribunal held that the date of recording the satisfaction note or receipt of records by the AO of the non-searched person is the relevant date for determining the 'deemed date of search'. In this case, the deemed date of search was 19.09.2022, rendering the assessment under Section 153C invalid.

The Tribunal held that the approval obtained under Section 153D was mechanical and lacked application of mind, rendering it invalid. Consequently, the assessment order was quashed.

The Tribunal held that the delay in filing Form 67 is a procedural defect and should not extinguish the substantive right to claim FTC. Following precedent, the Tribunal directed the AO to consider the delayed Form 67 and allow the FTC after verification.

The tribunal allowed the appeal regarding the disallowance of salary and miscellaneous expenses, stating it could not have been made. However, it rejected the grounds related to payment disallowance and unsecured loans due to the assessee's failure to provide supporting documents.

The Tribunal found that the assessee failed to satisfactorily explain the remaining sum of Rs. 3,64,712/-. However, considering the facts, a lump sum addition of Rs. 2,00,000/- was deemed just and proper.

The Tribunal held that the date of recording the satisfaction note or receipt of records by the AO of the non-searched person is the relevant date for determining the 'deemed date of search'. In this case, the deemed date of search was 19.09.2022, rendering the assessment under Section 153C invalid.

The Tribunal held that the date on the purchase deed was for the certified copy, and the actual registration of the new residential property was on 07.08.2018, which was within the time limit prescribed under Section 54. Therefore, the assessee was eligible for the exemption.

The Tribunal set aside the addition related to accommodation entries due to lack of basis and directed its deletion. For the cash deposits, the Tribunal found that the lower authorities failed to appreciate the evidence submitted by the assessee regarding disclosed sales and directed deletion of these additions as well.

The assessee requested to withdraw these appeals as they were duplicate filings and intended to pursue only one appeal (ITA No. 1638/Del/2026) which had identical facts and grounds. The Tribunal allowed the withdrawal.

The assessee requested to withdraw these appeals as they were duplicate filings and intended to pursue only one appeal (ITA No. 1638/Del/2026) which had identical facts and grounds. The Tribunal allowed the withdrawal.

The Tribunal has not yet decided the appeal as the provided text only contains the introductory part of the judgment. The facts of the case and the specific grounds for appeal are still being presented.

The Tribunal set aside the addition related to accommodation entries due to lack of basis and directed its deletion. For the cash deposits, the Tribunal found that the lower authorities failed to appreciate the evidence submitted by the assessee regarding disclosed sales and directed deletion of these additions as well.

The Tribunal held that no penalty can survive once the quantum addition is deleted. Consequently, the penalty imposed by the Assessing Officer was deleted.

The Income Tax Appellate Tribunal (ITAT) dismissed the appeals as withdrawn based on the assessee's representative's instruction. The assessees did not wish to proceed with their respective appeals.

The Tribunal upheld the CIT(A)'s decision, finding that the assessee had not claimed any bogus LTCG or STCG from penny stock trading. The transactions were conducted in the normal course of business and accounted for in the Profit and Loss account.

The tribunal held that a penalty cannot survive if the underlying quantum addition is absent. Since the quantum issue was remitted for re-adjudication, the penalty order was also set aside.

The Tribunal restored the appeal back to the Assessing Officer for reconsideration and factual verification of the cash deposits. This was done in the interest of justice, allowing the assessee three opportunities for hearing.

The Income Tax Appellate Tribunal (ITAT) dismissed the appeals as withdrawn based on the assessee's representative's instruction. The assessees did not wish to proceed with their respective appeals.

The Tribunal held that the addition on account of cash was rightly deleted by the CIT(A) as the assessee rebutted the presumption of ownership by providing sufficient evidence. However, the addition on account of foreign currency was upheld as the assessee failed to provide evidence to support his claim.

The Tribunal held that TDS amounts deducted and deposited by employers, reflecting in Form 26AS, should not have been refused. It also noted that income attributed to different company names appearing in bank statements and Form 26AS pertained to the same legal entity.

The Income Tax Appellate Tribunal (ITAT) dismissed the appeals as withdrawn based on the assessee's representative's instruction. The assessees did not wish to proceed with their respective appeals.

The Tribunal held that in the interest of natural justice, the matter should be remitted back to the CIT(E) for fresh adjudication. The CIT(E) was directed to provide three effective opportunities to the assessee to present evidence.

The Income Tax Appellate Tribunal (ITAT) dismissed the appeals as withdrawn based on the assessee's representative's instruction. The assessees did not wish to proceed with their respective appeals.

The tribunal decided to remit the issue of interest on outstanding receivables back to the Assessing Officer (AO)/Transfer Pricing Officer (TPO) for re-analysis. If the assessee is found to be debt-free, no adjustment can be made on this issue. The tribunal also noted that this issue should be addressed when working capital adjustments are granted.

The Tribunal held that the reassessment proceedings were void ab initio as the notice under Section 148 was issued after April 1, 2021, for AY 2015-16, following the Supreme Court's decision in Rajeev Bansal. Therefore, the PCIT had no revisionary authority under Section 263.

The Tribunal held that the sale deed executed on 23.03.2011, transferring title and liabilities, should be considered for AY 2011-12, irrespective of the later registration date. The denial of cost of acquisition and indexation was incorrect.

The Tribunal held that the notice under section 148 and the consequent assessment order were invalid. This was in compliance with the Supreme Court's decision in the case of Rajeev Bansal, which stated that notices issued after 01.04.2021 for AY 2015-16 should be dropped.

The Tribunal quashed the notice issued under section 148 and the consequent assessment order. This decision was based on the concession made by the Revenue before the Supreme Court in the case of Rajeev Bansal, stating that notices issued after April 1, 2021, for AY 2015-16 would be dropped.