ITAT Guwahati Judgments — October 2026

The Tribunal held that the addition of Rs. 5,73,983/- as additional business income is acceptable. The Tribunal noted that the AO considered the total turnover of Rs. 1,00,39,426/- and calculated net profit at 12.5%, which was accepted by the assessee's counsel during arguments as turnover. Since the assessee had already declared 12.5% income on a portion of the turnover, the plea for offering 8% on the difference was not accepted. The Tribunal upheld the AO's computation of 12.5% net income on the accepted turnover. Regarding the addition of Rs. 14,05,000/- for cash deposit, the Tribunal noted that these deposits are out of the assessee's income. The Tribunal directed that telescoping benefit should be given to the assessee after considering the cash flow. The issue was remitted to the Joint Assessing Officer (JAO) to determine the availability of funds to rebut the addition made under Section 69A, considering the total income of Rs. 12,54,928/-. The assessee was directed to provide a correct cash flow statement, and no benefit of opening cash balance would be given as it was not accepted. If the JAO finds any shortfall, the addition would be restricted to that extent.

The Tribunal held that the assessee failed to establish that the impugned contribution represented a genuine donation eligible for deduction under Section 80GGC of the Act. The Tribunal noted that the investigation material, bank trail analysis, and the established modus operandi of the recipient political party constituted a complete chain of circumstances overwhelmingly demonstrating that the donation was merely an accommodation entry. The Tribunal relied on the Supreme Court's decisions in CIT v. Durga Prasad More and Sumati Dayal v. CIT, stating that taxing authorities are not required to put on blinkers and are entitled to look beyond the apparent, examine surrounding circumstances, and apply the test of human probabilities. The Tribunal found that mere payment through banking channels and production of donation receipts could not override the overwhelming evidence that the recipient political party was engaged in providing accommodation entries. The Tribunal also noted that the decisions relied upon by the assessee's counsel were distinguishable on facts. Therefore, the Tribunal found no infirmity in the order of the Ld. CIT(A) affirming the disallowance made by the Assessing Officer. The grounds raised by the assessee were dismissed. The appeal was dismissed.

The Tribunal noted that the assessee had substantial cash deposits but had not filed a return of income. The assessee claimed to provide net banking facilities to weaker sections and book tickets, for which incomplete documents were furnished. Considering the prayer of the assessee, the facts of the case, and in the interest of justice, the Tribunal decided to remit the issue back to the Assessing Officer for fresh consideration. The Assessing Officer is directed to provide a reasonable opportunity of being heard to the assessee. The assessee is directed to substantiate their case with cogent documents and avoid unnecessary adjournments to ensure early disposal. The Tribunal stated that no second leniency would be granted if the assessee fails to comply. The issue of whether the addition under Section 69A was justified was not decided on merits but remanded for fresh adjudication.

The Tribunal noted that while the assessee claimed to be a Government employee who undertook foreign visits for official purposes, proper documentation was not furnished. To claim exemption under Section 10(26) of the Income Tax Act, 1961, the assessee failed to provide reliable documents to prove the source of income arising from the specified area. Considering the totality of facts and circumstances, the Tribunal decided to remit the issue back to the file of the Assessing Officer (AO) for de-novo consideration. The AO is directed to decide the issue afresh after granting a reasonable opportunity to the assessee to substantiate their claim with cogent documents. The assessee is also directed to provide necessary documentation and avoid seeking unnecessary adjournments to ensure an early disposal of the case. The Tribunal cautioned that no further leniency would be granted if the assessee fails to comply. The appeal was partly allowed for statistical purposes.

The Tribunal noted that the assessee was initially granted registration under Section 12A(1)(ac)(1) for AY 2022-23 to 2026-27. However, during the renewal process, the assessee failed to respond to the questionnaire issued by the CIT(E) on 08.01.2026, specifically regarding the old registration granted under Section 12AA prior to 01.04.2021. While the assessee claimed to have obtained registration on 16.12.2014, it could not furnish the certificate during the proceedings before the CIT(E). The Tribunal observed that a pre-condition for registration under Section 12A(1)(ac)(1) is having prior registration before 01.04.2021. Considering the facts, the Tribunal decided to remit the issue back to the Ld. CIT(E) for fresh consideration and decision. The Ld. CIT(E) is directed to provide a reasonable opportunity to the assessee to be heard and to substantiate its claim with requisite documents. The assessee is also directed to present its case with supporting documents without seeking unnecessary adjournments for early disposal. The Tribunal explicitly stated that no further leniency would be granted to the assessee in case of failure. The issue of whether the initial registration was obtained on wrong facts and the subsequent declaration of being void ab initio were not definitively decided, as the matter was remanded.

The Tribunal held that while the assessee could not provide satisfactory explanations for the cash of Rs. 99,00,000/- during assessment, they filed additional documents before the Ld. CIT(A) under Rule 46A. The Ld. CIT(A) issued multiple notices and reminders for a Remand Report, but the Assessing Officer failed to submit it. Consequently, the Ld. CIT(A) relied on the additional documents and deleted the addition. The Tribunal opined that the Ld. CIT(A) should have waited for the Remand Report and a rejoinder from the assessee before adjudicating the issue to serve substantial justice. Therefore, the matter was remanded to the Ld. CIT(A) with a direction to procure the Remand Report from the Assessing Officer and decide the appeal afresh, providing the assessee an opportunity to be heard. No issue was expressly left undecided.

The Tribunal allowed the appeal of the Revenue. The primary issue revolved around the satisfaction note required under Section 153C. The CIT(A) had deleted the addition on the ground that the AO had not recorded a valid satisfaction note in his dual capacity. However, the Tribunal, relying on the Supreme Court judgment in Super Malls (P) Ltd. Vs. Pr.CIT (2020), held that when the AO is the same for both the searched person and the assessee, a separate satisfaction note for the assessee is not mandatory if the AO is satisfied that the seized documents belong to the assessee. The Tribunal reproduced the satisfaction note recorded by the AO, which clearly indicated that seized documents belonged to M/s. Supreme Zarda House (Prop. Smt. Puspa Devi Chaurasia). The Tribunal found that the AO had referred to seized documents like bank deposit loose sheets and retail invoices, which were not recorded in the books of accounts, as evidenced by the statement recorded under Section 132(4). Therefore, the Tribunal overruled the objection regarding the non-fulfillment of the mandatory requirement of a valid satisfaction note. Since both parties did not argue the case on merits, the Tribunal did not adjudicate on the merits. The appeal of the revenue was allowed.

The Tribunal allowed the additional grounds raised by the assessee regarding the procedural irregularities in the issuance of notices. For AY 2015-16, the Tribunal noted that the legal ground raised by the assessee was dismissed, and the case was decided on merits, resulting in a partial allowance. However, for AY 2016-17 and 2017-18, the Tribunal found that the notices issued by the Assessing Officer under Section 148 were not proper in the eyes of the law. Specifically, it was observed that for reopening beyond three years, the approval should have been obtained from the PCCIT, but in this case, approval was obtained from the PCIT. Respectfully following the judgment of the Hon'ble Bombay High Court in Mrs. Chitra Supekar vs. ITO, the Tribunal held that the notice issued by the Assessing Officer under Section 148 was not proper. Consequently, the appeals for AY 2016-17 and 2017-18 were allowed. The ratio decidendi is that non-compliance with the mandatory provisions regarding obtaining approval from the appropriate authority (PCCIT for reopening beyond three years) renders the reassessment proceedings void.

The Tribunal allowed the additional grounds raised by the assessee regarding the procedural irregularities in the issuance of notices. For AY 2015-16, the Tribunal noted that the legal ground raised by the assessee was dismissed, and the case was decided on merits, resulting in a partial allowance. However, for AY 2016-17 and 2017-18, the Tribunal found that the notices issued by the Assessing Officer under Section 148 were not proper in the eyes of the law. Specifically, it was observed that for reopening beyond three years, the approval should have been obtained from the PCCIT, but in this case, approval was obtained from the PCIT. Respectfully following the judgment of the Hon'ble Bombay High Court in Mrs. Chitra Supekar vs. ITO, the Tribunal held that the notice issued by the Assessing Officer under Section 148 was not proper. Consequently, the appeals for AY 2016-17 and 2017-18 were allowed. The ratio decidendi is that non-compliance with the mandatory provisions regarding obtaining approval from the appropriate authority (PCCIT for reopening beyond three years) renders the reassessment proceedings void.

The Tribunal allowed the additional grounds raised by the assessee regarding the procedural irregularities in the issuance of notices. For AY 2015-16, the Tribunal noted that the legal ground raised by the assessee was dismissed, and the case was decided on merits, resulting in a partial allowance. However, for AY 2016-17 and 2017-18, the Tribunal found that the notices issued by the Assessing Officer under Section 148 were not proper in the eyes of the law. Specifically, it was observed that for reopening beyond three years, the approval should have been obtained from the PCCIT, but in this case, approval was obtained from the PCIT. Respectfully following the judgment of the Hon'ble Bombay High Court in Mrs. Chitra Supekar vs. ITO, the Tribunal held that the notice issued by the Assessing Officer under Section 148 was not proper. Consequently, the appeals for AY 2016-17 and 2017-18 were allowed. The ratio decidendi is that non-compliance with the mandatory provisions regarding obtaining approval from the appropriate authority (PCCIT for reopening beyond three years) renders the reassessment proceedings void.

The Tribunal held that the penalty order was not sustainable. Regarding the limitation issue (Ground No. 2 of Assessee), the Tribunal noted the well-settled law that the initiation of penalty proceedings is reckoned from the date of satisfaction in the assessment order. The AO recorded satisfaction on 28.03.2024, and the penalty order was passed on 13.12.2024, which, if considered from the satisfaction date, would be beyond the limitation period. However, the Tribunal did not explicitly decide on the limitation point as it found merit in other grounds. On the substantive issue of contravention of Section 269ST (Grounds 4, 5, and 6 of Assessee), the Tribunal observed that the penalty was imposed based on unsigned, unverified loose documents with mixed entries and partial matching of RTGS transactions. The AO failed to conduct independent inquiries, obtain statements from parties, or bring corroborative material on record. The surrender of income to buy peace does not, by itself, establish actual cash receipts violating Section 269ST, especially when the assessee's books were not rejected, and no cash trail or corroborative evidence was found. The Tribunal relied on the decision in Sanjay Kalsi Vs. DCIT, where a similar surrender for peace was held not to establish a violation of Section 269ST. Therefore, the penalty order was deleted. The revenue's appeal was dismissed as infructuous.

The Tribunal held that the penalty order was not sustainable. Regarding the limitation issue (Ground No. 2 of Assessee), the Tribunal noted the well-settled law that the initiation of penalty proceedings is reckoned from the date of satisfaction in the assessment order. The AO recorded satisfaction on 28.03.2024, and the penalty order was passed on 13.12.2024, which, if considered from the satisfaction date, would be beyond the limitation period. However, the Tribunal did not explicitly decide on the limitation point as it found merit in other grounds. On the substantive issue of contravention of Section 269ST (Grounds 4, 5, and 6 of Assessee), the Tribunal observed that the penalty was imposed based on unsigned, unverified loose documents with mixed entries and partial matching of RTGS transactions. The AO failed to conduct independent inquiries, obtain statements from parties, or bring corroborative material on record. The surrender of income to buy peace does not, by itself, establish actual cash receipts violating Section 269ST, especially when the assessee's books were not rejected, and no cash trail or corroborative evidence was found. The Tribunal relied on the decision in Sanjay Kalsi Vs. DCIT, where a similar surrender for peace was held not to establish a violation of Section 269ST. Therefore, the penalty order was deleted. The revenue's appeal was dismissed as infructuous.

The Tribunal allowed the appeal of the assessee. The Tribunal respectfully followed the orders of the Co-ordinate Bench in the case of Ananga Mohan Das Vs. ITO Ward-42(1), Murshidabad, and similar cases. The reasoning was that the BSNL VRS-2019 scheme was considered a retrenchment scheme by coordinate benches, making the compensation received eligible for exemption under Section 10(10B) of the Act. The Tribunal also directed the Assessing Officer to grant exemption in respect of accumulated leave encashment. The ratio decidendi is that compensation received under the BSNL VRS-2019 scheme, when treated as retrenchment compensation, is eligible for exemption under Section 10(10B), and accumulated leave encashment is also to be granted exemption, following precedents set by other benches of the Tribunal. The operative direction is to allow the appeal and direct the Assessing Officer to grant the specified exemptions.

The Tribunal noted that the assessee filed Form No. 10AB on 09.10.2025 for renewal of its Section 80G approval, which was due on or before 30.09.2025. The Ld. CIT(E) did not have the power to condone the delay. However, the assessee relied on CBDT Circular No. 06/2026 dated 07.07.2026, which was issued to address difficulties faced by taxpayers who filed applications between 01.10.2025 and 09.10.2025. Considering the rival submissions, the material on record, and in the interest of justice, the Tribunal decided to remit the issue back to the file of the Ld. CIT(E). The Ld. CIT(E) is directed to consider the applicability of the CBDT circular and decide the matter as per law, providing the assessee an opportunity to be heard and substantiate its claim with cogent documents. The Tribunal stated that no second leniency would be granted if the assessee failed to comply. The appeal was partly allowed for statistical purposes.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the Tax Deducted at Source (TDS). The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and by respectfully following the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO. The Tribunal allowed the appeals of the assessee, directing that the compensation be considered exempt and the TDS be refunded.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, for the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal allowed the appeals of the assessee, respectfully following the judgment in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025, dated 30.05.2025). The ratio decidendi is that tax authorities should grant lawful reliefs even if not claimed in the return, especially when the assessee becomes aware of their eligibility later, and that compensation under the BSNL VRS-2019 scheme is exempt under Section 10(10B) subject to Rule 2BA compliance. All 41 appeals were allowed.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, for the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal allowed the appeals of the assessee, respectfully following the judgment in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025, dated 30.05.2025). The ratio decidendi is that tax authorities should grant lawful reliefs even if not claimed in the return, especially when the assessee becomes aware of their eligibility later, and that compensation under the BSNL VRS-2019 scheme is exempt under Section 10(10B) subject to Rule 2BA compliance. All 41 appeals were allowed.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, for the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal allowed the appeals of the assessee, respectfully following the judgment in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025, dated 30.05.2025). The ratio decidendi is that tax authorities should grant lawful reliefs even if not claimed in the return, especially when the assessee becomes aware of their eligibility later, and that compensation under the BSNL VRS-2019 scheme is exempt under Section 10(10B) subject to Rule 2BA compliance. All 41 appeals were allowed.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, for the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal allowed the appeals of the assessee, respectfully following the judgment in Harish Kumar vs. ITO Ward 5(5), Chandigarh (ITA No. 42/CHD/2025, dated 30.05.2025). The ratio decidendi is that tax authorities should grant lawful reliefs even if not claimed in the return, especially when the assessee becomes aware of their eligibility later, and that compensation under the BSNL VRS-2019 scheme is exempt under Section 10(10B) subject to Rule 2BA compliance. All 41 appeals were allowed.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee had filed the claim before the Ld. CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the TDS. The Tribunal respectfully followed the judgment of the Hon'ble ITAT Chandigarh Bench in Harish Kumar vs. ITO (ITA No. 42/CHD/2025) which dealt with a similar set of facts concerning the BSNL VRS-2019 scheme. The appeals of the assessee were allowed. The operative direction was to allow the exemption and grant the refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the TDS. The reasoning was based on the principle that tax authorities should grant all lawful reliefs even if not claimed by the assessee, citing CBDT Circular No. 14 of 1955. The Tribunal also respectfully followed the judgment of the ITAT Chandigarh Bench in Harish Kumar vs. ITO, which dealt with a similar set of facts concerning the BSNL VRS-2019 scheme. The appeals of the assessee were allowed, and the assessee is eligible for the refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the CIT(A) and, since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the assessee's case had similar facts to the judgment relied upon by the assessee (Harish Kumar vs. ITO, ITA No. 42/CHD/2025, dated 30.05.2025) and respectfully followed that decision. Therefore, the appeals of the assessee were allowed. The Tribunal directed that the compensation received under the BSNL VRS-2019 scheme is exempt under Section 10(10B), subject to compliance with Rule 2BA, and the assessee is entitled to a refund of the TDS paid on this amount.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the Ld. CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the TDS. The Tribunal respectfully followed the judgment cited in *Harish Kumar vs. ITO* (supra) and allowed the appeals of the assessee. The reasoning was based on the principle that tax authorities are obligated to grant all lawful reliefs, even if not claimed by the assessee, as supported by CBDT Circular No. 14 of 1955, and that the compensation received under the specific VRS scheme was indeed eligible for exemption. The Tribunal allowed the appeals of all 41 assessees in the batch.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal found that the assessee filed the claim before the CIT(A) and that since the income is not taxable, the assessee is eligible for a refund of the TDS. The reasoning was based on the fact that the compensation received under the same scheme was held to be exempt in the case of Harish Kumar vs. ITO (ITA No. 42/CHD/2025) by the ITAT Chandigarh Bench. The Tribunal respectfully followed this precedent. The operative direction was to allow the appeals of the assessee, granting them the exemption and the refund of TDS. No issue was expressly left undecided.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal condoned the delay of 216 days in filing the first appeal before the Ld. CIT(A). The Tribunal noted that while the assessee is expected to file appeals on time, delays with bona fide reasons beyond the assessee's control can be construed as sufficient cause. The Tribunal referred to the Hon'ble Supreme Court's landmark decision in Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC), which emphasizes a liberal approach to condoning delays when supported by justifiable reasons to ensure substantial justice. Consequently, the Tribunal remanded the matter back to the Ld. CIT(A) with a direction to decide the appeal afresh on its merits after providing the assessee an opportunity of being heard. The issue of the assessment order's merits was expressly left undecided by the ITAT.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal held that the assessee is eligible for exemption under Section 10(10B) of the Income-tax Act, 1961, on the compensation received under the BSNL VRS-2019 scheme. The Tribunal noted that the assessee had filed the claim before the Ld. CIT(A) and that since the income was not taxable, the assessee was eligible for a refund of the TDS. The Tribunal found that the judgments relied upon by the assessee's counsel supported the case on similar facts. Respectfully following the cited judgments, the Tribunal allowed the appeals of the assessee. The operative direction was to allow the appeals, implying the grant of exemption and refund of TDS.

The Tribunal noted that the case was reopened after duly recording reasons and obtaining approval. The assessee had made purchases of Rs. 22,33,300 from M/s Devyansh Dealcom (P) Ltd. During the appellate proceedings, the assessee filed documents, and the CIT(A) called for a remand report from the AO. This report was sent to the assessee for comments, but no reply was received. Considering the totality of the facts and the paper book filed by the assessee, the Tribunal decided to remit the issue back to the file of the CIT(A) for fresh examination and decision as per law. The assessee is directed to substantiate its case with cogent documents, and a reasonable opportunity of being heard is to be given. The Tribunal did not decide the merits of the additions or the validity of the assessment proceedings but rather remanded the matter for a proper adjudication.

The Tribunal noted that the case was reopened based on information about substantial cash deposits. During the assessment proceedings, the assessee was unable to explain the sources of these deposits, leading to the addition under Section 69A. The assessee's primary grievance before the CIT(A) was the improper appreciation of the remand report. The assessee also contended that the transactions were recorded in audited books as business turnover. The Tribunal, considering the prayer of the assessee's counsel and in the interest of justice, decided to remit the issue back to the file of the AO for fresh consideration. The AO was directed to give the assessee a reasonable opportunity of being heard and to substantiate the case with cogent documents, with a caution against seeking unnecessary adjournments. The Tribunal explicitly stated that no second leniency would be granted if the assessee failed to comply. The issue of deductions under Chapter VIA was not specifically addressed in the final decision but was implicitly part of the remand.