ITAT Jaipur Judgments — August 2026

The Tribunal held that since the trust had a single, determined beneficiary, it should be taxed at individual slab rates, not MMR. The lower authorities erred in denying this benefit and rejecting the rectification.

The Tribunal held that Section 43CA could not be invoked as the transaction was substantially completed in FY 2011-12, prior to the introduction of Section 43CA. The registration in a later year did not alter the applicability of the law in force at the time of the agreement and substantial payment.

The Tribunal condoned the delay in filing the appeal, citing the need to advance substantial justice. It further held that the assessee, being a bank employee, was entitled to the full exemption of leave encashment as per the revised limits and judicial precedents.

The Tribunal held that the notice issued under Section 148 of the Income Tax Act was barred by limitation as per the first proviso to Section 149(1). Consequently, the assessment order was quashed.

The Tribunal held that the Assessing Officer (AO) had not applied his mind while assuming jurisdiction under Section 153C and framing the assessment. Significant discrepancies in the recorded facts regarding property ownership and payment amounts led to the quashing of the assessment order.

The Tribunal held that the Assessing Officer (AO) clearly lacked application of mind while assuming jurisdiction under Section 153C and framing the assessment. Significant variations in ownership and payment details were noted between the satisfaction notes and the assessment order.