ITAT Jaipur Judgments — December 2025

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 deposit as being from cash sales, supported by books of accounts and VAT returns. Therefore, the addition made by the AO was not sustainable.

The Tribunal restored the issue of long-term capital gains to the AO for verification of exemption under Section 10(37), as the claim was raised for the first time. The issue of cash deposits was also restored to the AO for fresh consideration due to non-adjudication by the lower authorities. The denial of Section 80C deduction was restored to the AO for making necessary inquiries from the employer.

The Tribunal held that the AO's assumption of jurisdiction to reopen the case for AY 2013-14 was invalid as the information available did not pertain to the impugned 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 delay in filing Form 10BB is a procedural requirement and not a mandatory condition for claiming exemption under Section 11. As long as the form is filed and available during assessment proceedings, the delay should not disentitle the assessee from claiming exemption.

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 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 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 CIT(A) was justified in setting aside the assessment order as the assessee had provided sufficient documentation to explain the source of funds, which were inter-firm transfers. The movement of funds through the assessee's account did not render them unexplained.

The Tribunal held that the withdrawal of the deduction claim, without demonstrating its bona fides, constituted underreporting of income. The Tribunal also found that the AO had clearly specified the charge of misrepresentation or suppression of facts under Section 270A(9)(a) in the assessment order and penalty 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 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.

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.