ITAT Jaipur Judgments — December 2025

The Tribunal held that the assessee had a legitimate claim for exemption regarding capital gains, but the facts needed verification. The Tribunal also restored the issues of capital gains computation, unexplained cash deposits, and Section 80C deduction back to the Assessing Officer for fresh adjudication.

The Tribunal held that the AO's assumption of jurisdiction to reopen the case under Section 147 of the Income Tax Act was invalid, as the reasons recorded did not pertain to the impugned assessment year. Consequently, the assessment order was quashed.

The Tribunal held that the assessee's case qualified as 'underreporting of income' under Section 270A(2)(a) of the Act, as the assessed income exceeded the income processed. The assessee's contention that the addition was on an estimation basis and thus not liable for penalty was rejected.

The Tribunal held that the assessee had sufficiently explained the source of the cash deposits as being from cash sales. The AO's addition was based on assumptions and presumptions, and no infirmity was found in the assessee's books of accounts or VAT returns. Therefore, the addition was not sustainable.

The Tribunal held that the additions made to the assessee's income qualified as 'underreporting of income' under Section 270A(2)(a) of the Act. The Tribunal further held that the exception under Section 270A(6)(b) was not applicable as the assessee's accounts were not found to be correct and complete.

The Tribunal held that the delay in filing Form 10BB is a procedural lapse and not a substantive condition for claiming exemption under Section 11 of the Act. Relying on various High Court and Tribunal decisions, it was concluded that once the form is filed and available to the department, exemption should not be denied solely on account of delayed filing.

The Tribunal held that while the assessee failed to participate in assessment proceedings and presented the claim of denial of the bank account for the first time before the CIT(A), the CIT(A) should have facilitated the assessee in bringing on record material to support his plea. Therefore, the appeal is restored to the CIT(A) for a fresh decision.

The Tribunal noted that the appeals were filed with a significant delay and the assessee remained absent during the hearing without any justification. Consequently, the appeals were dismissed.

The Tribunal held that the applicant Trust failed to furnish any reasons or application for condonation of delay. Since the appeals were filed beyond the prescribed limitation period without sufficient cause, they were dismissed.

The Tribunal held that the appeals were filed beyond the prescribed period of limitation and no sufficient cause was provided for the delay. Relying on the Supreme Court's decision in Pathapati Subba Reddy, the Tribunal found no justification to condone the delay.

The Income Tax Appellate Tribunal observed that both appeals were filed with a delay of 47 days and the assessee failed to appear during multiple hearings, nor did they submit any adjournment requests or reasons for the delay. Consequently, the Tribunal did not condone the delay and dismissed both appeals as non-maintainable.

The Tribunal held that the assessee had provided sufficient documentation and explanations for the credit transactions, which were primarily inter-firm transfers. The Learned CIT(A) had correctly observed that the AO had not disputed the source of funds nor pointed out any defects in the provided books of accounts. Thus, the movement of funds through the assessee's account did not render them unexplained money.

The Tribunal held that the assessee's withdrawal of the deduction claim after reassessment proceedings were initiated constituted underreporting of income. The contention that the AO failed to specify the charge for penalty was rejected as it was found to be specified in the assessment order and the notice.

The Tribunal held that the interest expenditure incurred on a loan for acquiring a capital asset, which was not used for business purposes during the assessment year, is not allowable under Section 36(1)(iii). However, it is allowable under Section 24(b) as 'Income from House Property'.

The Tribunal held that since a co-ordinate bench had already deleted the addition of Rs. 3,96,05,000/- in a prior appeal (ITA No. 587/JP/2024), the subsequent rectification to apply a higher tax rate was unjustified. Consequently, the CIT(A)'s order setting aside the rectification was upheld.

The Tribunal noted that the Assessing Officer accepted the appellant's submissions in entirety in the subsequent assessment order, making the present appeal infructuous. The Ld. DR had no objection to the withdrawal.