ITAT Hyderabad Judgments — September 2026

The Tribunal held that the addition on account of agricultural income was subsumed within the larger addition for unexplained cash deposits. It also found that the AO had travelled beyond the scope of limited scrutiny in making additions related to agricultural income.

The Tribunal condoned the delay in filing the appeal. It held that the disallowance of PF contributions under Rule 87 was not sustainable but remanded the issue for verification of actual payment as per Section 43B. The ad-hoc disallowance of expenses was upheld due to lack of supporting evidence.

The tribunal upheld the disallowance, agreeing that the assessee failed to substantiate the cost incurred for the movie and the subsequent abandonment with cogent evidence. The transaction was deemed an arrangement to gain tax benefits rather than a genuine business expense.

The Tribunal upheld the CIT(A)'s decision, finding that the deduction by BCCL was a contractual demurrage for failure to transport the agreed quantity, not a penalty for infringing any law. It also found no violation of Section 40A(3) as cash payments did not exceed the daily threshold.

The Tribunal held that Infosys Limited, Wipro Limited, and LTI Mindtree Limited cannot be considered good comparables to the assessee. For Infosys Limited, the Tribunal noted its status as a leading provider of diverse services, significant product portfolio, numerous patents, large client base, and substantial revenue and R&D expenditure, making it different from a captive service provider. Similarly, Wipro Limited was found to be engaged in diversified activities, incurring significant R&D expenditure, owning numerous patents and trademarks, and assuming significant strategic, marketing, and financial risks, unlike the assessee. LTI Mindtree Limited was also found to be engaged in diversified activities across various sectors, possessing significant intangible assets and brand value exceeding one billion dollars, which distinguishes it from the assessee's captive service model. The Tribunal followed the decision of the ITAT, Hyderabad Bench in the case of HighRadius Technologies Vs. DCIT, which dealt with similar comparables. Therefore, the Tribunal directed the AO/TPO to exclude these three companies from the list of comparables and recompute the transfer pricing adjustment. The ground relating to the limitation in passing the final assessment order was kept open for future decision.

The Tribunal held that adding the entire purchase consideration to the assessee's income was arbitrary and unjustified, as she was only a 50% co-purchaser with her son, who had declared the transaction in his return. The matter requires proper verification of facts.

The Tribunal condoned the delay in filing the appeal, acknowledging the assessee's explanation as bona fide. It was held that the disallowance under Section 40(a)(ia) required examination on merits, and the CIT(A) had not adjudicated the grounds on merits.

The Tribunal condoned the delay in filing the appeal. Considering the additional evidence filed by the assessee, the matter was remanded to the Assessing Officer for verification and fresh adjudication.

The Tribunal condoned the delay in filing the appeal, finding sufficient cause due to the medical reasons of the assessee's tax consultant. The CIT(A)'s order was set aside, and the matter was remanded for fresh adjudication on merits.

The Tribunal condoned the delay in filing the appeal. The Tribunal set aside the CIT(A)'s order and remanded the matter back to the Assessing Officer for proper verification and examination of the evidence, including allowing the assessee to seek cross-examination.

The Tribunal held that the CIT(E) rejected the applications without providing sufficient opportunity to the assessee. Therefore, the orders of the CIT(E) were set aside.

The Tribunal held that the addition on account of unexplained cash was explained by the cash in hand as per the assessee's books. It also held that the jewellery found was within the limits prescribed by CBDT Instruction No. 1916, thus no addition was warranted.

The Tribunal condoned the delay in filing the appeal due to the assessee's medical condition. The Tribunal quashed the notice issued under Section 148 as it was barred by limitation, rendering the reassessment order invalid.

The Tribunal upheld the CIT(A)'s decision to delete the disallowance, finding that advertisement and sales promotion expenses are revenue in nature and not capital, especially when the Revenue had accepted similar expenses as revenue in prior and subsequent years.

The Tribunal condoned the delay in filing the appeals before it. For the penalty under Section 271(1)(c), the matter was remanded to the CIT(A) to be decided after the outcome of the pending quantum appeal. The appeal for penalty under Section 271F was dismissed as not pressed.

The Tribunal held that compensation received by BSNL employees under VRS 2019 is exempt under Section 10(10B) of the Income-tax Act. The Assessing Officer was directed to verify the claim and allow the exemption.

The Tribunal condoned the delay in filing the appeals before it. For the penalty under Section 271(1)(c), the matter was remanded to the CIT(A) to be decided after the outcome of the pending quantum appeal. The appeal for penalty under Section 271F was dismissed as not pressed.

The Tribunal condoned the delay in filing the appeal, following precedents in similar BSNL VRS cases. It held that the ex-gratia compensation received under the BSNL VRS-2019 scheme is eligible for exemption under Section 10(10B) of the Act.

The Tribunal condoned the delay in filing the appeal, following precedents in similar BSNL VRS cases. It held that the ex-gratia compensation received under the BSNL VRS-2019 scheme is eligible for exemption under Section 10(10B) of the Act.

The Tribunal held that the CIT(A) ought to have adopted a liberal and justice-oriented approach and condoned the delay, considering the assessee's bona fide belief and the failure of the tax consultant. The appeals were set aside to the CIT(A) for adjudication on merits.

The Tribunal held that the CIT(A) ought to have adopted a liberal and justice-oriented approach and condoned the delay, considering the assessee's bona fide belief and the failure of the tax consultant. The appeals were set aside to the CIT(A) for adjudication on merits.

The Tribunal condoned the delay in filing the appeal before the CIT(A) by following previous decisions in similar BSNL VRS cases. The Tribunal held that the ex-gratia compensation received under the BSNL VRS-2019 scheme is eligible for exemption under Section 10(10B) of the Act.

The Tribunal condoned the delay in filing the appeal before the CIT(A) by following previous decisions in similar BSNL VRS cases. The Tribunal held that the ex-gratia compensation received under the BSNL VRS-2019 scheme is eligible for exemption under Section 10(10B) of the Act.

The Tribunal condoned the delays in filing the appeals, finding the reasons to be bona fide. The Tribunal set aside the CIT(Exemption)'s orders and remanded the matters for reconsideration.

The Tribunal condoned the delays in filing the appeals, finding the reasons to be bona fide. The Tribunal set aside the CIT(Exemption)'s orders and remanded the matters for reconsideration.

The Tribunal held that the addition made by the Assessing Officer was based on a non-existing transaction, mistaking a sale for an investment. The Tribunal set aside the order and remanded the matter to the Assessing Officer for fresh adjudication.

The Tribunal held that since the delay in filing the return of income was condoned by the competent authority, the deduction under Section 80P should be allowed, subject to verification of other conditions. The matter was remanded to the Assessing Officer for this purpose.

The Tribunal condoned the delay in filing the appeal due to the assessee's bona fide reasons and lack of knowledge. It set aside the CIT(A)'s order and restored the matter to the AO for de novo adjudication, granting the assessee an opportunity to present evidence.

The Tribunal accepted the explanation for Rs. 16,95,000 of cash deposits as sale proceeds of ancestral property, and Rs. 1,00,000 from accumulated savings. The issue of Rs. 1,90,000 from a chit fund was remanded to the AO for verification.

The Tribunal condoned the delay in filing the appeal before the CIT(A) considering the medical emergency and the non-receipt of the assessment order. The impugned order of the CIT(A) was set aside and the matter was remanded for adjudication on merits.

The Tribunal held that the assessee had provided sufficient evidence, including bank statements and cash books, to demonstrate that cash transactions did not exceed the 5% limit. Therefore, the penalty levied for non-compliance with Section 44AB was not sustainable.

The Tribunal held that the assessee is eligible for exemption under Sections 11 and 12 for the assessment years in question, directing the AO to recompute the income accordingly. It also deleted ad hoc disallowances of expenses and other additions made by the AO.

The Tribunal held that the assessee is eligible for exemption under Sections 11 and 12 for the assessment years in question, directing the AO to recompute the income accordingly. It also deleted ad hoc disallowances of expenses and other additions made by the AO.

The Tribunal condoned the delay in filing the appeal. It deleted the addition made on account of sundry creditors, citing that Section 68 of the Income Tax Act is not applicable to trade creditors. The matter of disallowance of agricultural income was remanded back to the AO for verification of evidence.

The Tribunal held that the property sale occurred in AY 2015-16, making the reopening for AY 2017-18 invalid. The Assessing Officer had no reason to believe income escaped assessment for AY 2017-18.

The Tribunal upheld the CIT(A)'s decision to dismiss the appeal in limine due to an inordinate delay of 820 days. The assessee failed to provide any sufficient cause for the delay, either before the CIT(A) or the Tribunal.

The Tribunal held that the CIT(E) rejected the applications without providing sufficient opportunity to the assessee. Therefore, the orders of the CIT(E) were set aside.

The Tribunal upheld the CIT(A)'s dismissal of the appeal in limine, stating that the assessee failed to establish sufficient cause for the delay. Consequently, the addition under Section 69A and the penalty under Section 271(1)(c) were also upheld.

The Tribunal held that the notice issued under Section 148 of the Act was barred by limitation. Consequently, the reassessment order passed by the Assessing Officer was quashed.

The Tribunal condoned the delay, citing the assessee's illiteracy and the ex-parte assessment order which assessed the entire sale consideration as STCG without allowing cost of acquisition. The Tribunal set aside the CIT(A)'s order and remanded the matter to the AO for fresh adjudication.

The Tribunal upheld the CIT(A)'s decision, finding no corroborative evidence to link the company's payment to the assessee's property purchase or to treat it as a deemed dividend. The CIT(A)'s deletion of additions was confirmed.

The Tribunal held that the notice issued under Section 148 of the Act on April 13, 2022, was barred by limitation as it was issued beyond six years from the end of the assessment year. Consequently, the reassessment order was quashed.

The Tribunal held that the CIT(A) erred in dismissing the appeal as infructuous based on a misinterpretation of the previous ITAT order. The Tribunal condoned the delay in filing the present appeal and restored the matter to the CIT(A) for adjudication on merits.

The Tribunal held that compensation received by BSNL employees under VRS 2019 is exempt under Section 10(10B) of the Income-tax Act. The Assessing Officer was directed to verify the claim and allow the exemption.

The Tribunal held that the notice issued under Section 148 of the Act was barred by limitation as it was issued beyond six years from the end of the assessment year. Consequently, the reassessment order was quashed.

The Tribunal held that the assessee is eligible for exemption under Sections 11 and 12 for the assessment years in question, directing the AO to recompute the income accordingly. It also deleted ad hoc disallowances of expenses and other additions made by the AO.

The Tribunal held that the assessee is eligible for exemption under Sections 11 and 12 for the assessment years in question, directing the AO to recompute the income accordingly. It also deleted ad hoc disallowances of expenses and other additions made by the AO.

The Tribunal held that the assessee is eligible for exemption under Sections 11 and 12 for the assessment years in question, directing the AO to recompute the income accordingly. It also deleted ad hoc disallowances of expenses and other additions made by the AO.

The Tribunal held that the assessee is eligible for exemption under Sections 11 and 12 for the assessment years in question, directing the AO to recompute the income accordingly. It also deleted ad hoc disallowances of expenses and other additions made by the AO.

The Tribunal upheld the CIT(A)'s dismissal of the appeal in limine, stating that the assessee failed to establish sufficient cause for the delay. Consequently, the addition under Section 69A and the penalty under Section 271(1)(c) were also upheld.