ITAT Mumbai Judgments — June 2026

The Tribunal condoned the delay in filing the application, finding that a reasonable cause was demonstrated. It also held that the CIT (Exemptions) had not properly examined the nature of the trust's activities and the issue of investments, which should be considered during assessment proceedings.

The Tribunal held that the CIT(Exemption)'s finding was factually incorrect as the prior registration certificate was uploaded with the application. Therefore, the rejection order was based on a false premise.

The Tribunal held that initiating reassessment proceedings against a deceased person, when the department was aware of the death and the legal heir's registration, is a jurisdictional defect rendering the proceedings void ab initio. Consequently, all subsequent actions, including the assessment order, are invalid.

The Tribunal accepted the assessee's request to withdraw the appeals, acknowledging that the subsequent grant of 80G approval had resolved the primary grievance. Therefore, the appeals were dismissed as withdrawn.

The Tribunal accepted the assessee's request to withdraw the appeals, acknowledging that the subsequent grant of 80G approval had resolved the primary grievance. Therefore, the appeals were dismissed as withdrawn.

The Tribunal quashed the reassessment proceedings and the consequent addition. It held that the AO had not applied his mind independently and relied on borrowed satisfaction, making the reopening unsustainable. Furthermore, the AO's failure to dispose of the assessee's objections was also a critical factor.

The Tribunal held that the impugned orders rejecting the applications had lost their operative effect due to the subsequent grant of renewal and approval. Therefore, the appeals had become infructuous.

The Tribunal held that the impugned orders rejecting the applications had lost their operative effect due to the subsequent grant of renewal and approval. Therefore, the appeals had become infructuous.

The Tribunal set aside the ex parte orders of the CIT(A) and restored the matters for fresh adjudication. The assessee was directed to cooperate, and the CIT(A) was instructed to decide the appeals on merits after affording an effective opportunity of hearing.

The Tribunal held that the controversy arising from the rejection order no longer survives as the subsequent grant of registration and approval renders the appeals infructuous. Any grievance regarding conditions in the fresh order can be challenged independently.

The Tribunal held that the CIT(Exemption) could not attach conditional riders to the grant of registration and approval, especially when granted in compliance with a High Court judgment. Such caveats create uncertainty and are not sustainable.

The tribunal allowed the assessee's claim for interest paid to the Reserve Bank of India for default in maintaining Statutory Liquidity Ratio, holding it to be compensatory. However, an additional ground of appeal regarding expatriate salary expenses was dismissed as it involved mixed questions of fact and law not properly raised before the lower authorities.

The Tribunal held that while the issue of interest expenditure was inquired into by the Assessing Officer (AO), the arithmetical correctness of the computation of interest income on loans advanced was not specifically verified. Therefore, the AO was directed to conduct limited verification on this aspect.

The Tribunal held that the CIT(Exemption) could not attach conditional riders to the grant of registration and approval, especially when granted in compliance with a High Court judgment. Such caveats create uncertainty and are not sustainable.

The Tribunal held that the CIT(A) erred in confirming the addition without considering that the booking and payment for the flat were made in FY 2016-17. Therefore, the market valuation as of FY 2016-17 should be applicable.

The Tribunal accepted the assessee's prayer and remitted the matter back to the CIT(A). The CIT(A) was directed to consider the petition for condonation of delay on its merits and also to adjudicate the penalty appeal after the outcome of the pending quantum proceedings.

The Tribunal accepted the assessee's request to withdraw the appeal as the original grievance no longer survived. The appeal was accordingly dismissed as withdrawn.

The Tribunal held that the impugned order rejecting the renewal application has lost its operative effect due to the subsequent grant of renewal. Therefore, the appeal has become infructuous.

The Tribunal set aside the disallowance of prior period expenses for verification by the AO, dismissed the disallowance of carry forward of losses and depreciation due to non-compliance with statutory conditions, and upheld the deletion of deferred income addition based on a previous ITAT ruling.

The Tribunal found that the CIT(A) had misdirected itself by adjudicating on issues not arising from the assessment order under appeal. The impugned appellate order suffered from factual and legal infirmities.

The Tribunal held that the assessee was deprived of a proper hearing and that the ends of justice would be met by setting aside the ex parte order. The matter was restored to the CIT(E) for fresh adjudication.

The tribunal allowed the assessee's claim for interest paid to the Reserve Bank of India for default in maintaining Statutory Liquidity Ratio, holding it to be compensatory. However, an additional ground of appeal regarding expatriate salary expenses was dismissed as it involved mixed questions of fact and law not properly raised before the lower authorities.

The Tribunal held that the controversy arising from the rejection order no longer survives as the subsequent grant of registration and approval renders the appeals infructuous. Any grievance regarding conditions in the fresh order can be challenged independently.

The Tribunal found that the CIT(A) had misdirected itself by adjudicating on issues not arising from the assessment order under appeal. The impugned appellate order suffered from factual and legal infirmities.

The Tribunal accepted the assessee's request to withdraw the appeal. This was due to a subsequent development where the CIT (Exemptions) granted the Section 80G approval after the Bombay High Court ruling on irrevocability clauses.

The Tribunal held that the assessee's activities did not constitute a 'Business Connection' or 'PE' in India, and the attribution of income was erroneous. It also ruled that interest on income-tax refund is not effectively connected with the PE and should be taxed as per the India-Singapore Tax Treaty.

The Tribunal restored the matter to the file of the CIT(Exemption) in the interest of justice. The assessee was directed to furnish all required documents and participate in the proceedings for a fresh adjudication.

The Tribunal upheld the CIT(A)'s decision to reduce the addition to 2% of the disputed purchases, following its own prior ruling on identical facts for the assessee. The Tribunal found no infirmity in the appellate authority's conclusion.

The Tribunal held that the addition under Section 56(2)(x) cannot be sustained as the DVO's report, obtained by the Revenue, determined the fair market value to be equal to the consideration paid. The CIT(A) erred by not considering this crucial report.

The Tribunal held that observations made by the CIT(Exemption) making the registration and approval conditional on a future Supreme Court challenge were unsustainable. A judgment of the jurisdictional High Court is binding, and a contemplated appeal does not dilute its force. The caveats were directed to be deleted.

The Tribunal condoned the delay, finding sufficient cause for the delay in filing the appeal before the CIT(A). The Tribunal held that the CIT(A) erred in dismissing the appeal without adjudicating on merits, violating principles of natural justice.

The Tribunal accepted the assessee's request to withdraw the appeals. The appeals were dismissed as withdrawn by the Tribunal.

The Tribunal found that the additional evidence submitted by the assessee was essential for a just decision. Therefore, the case was remanded to the Commissioner to examine these evidences on merit.

The Tribunal accepted the assessee's request to withdraw the appeals. The appeals were dismissed as withdrawn.

The Tribunal condoned the delay in filing the appeal, finding sufficient cause. It set aside the CIT(A)'s order and restored the matter to the CIT(A) for fresh adjudication on merits, as the substantive grounds were not considered.

The Tribunal held that the addition on account of stamp duty valuation was made without affording the assessee an effective opportunity to explain its case. The proceedings were completed in undue haste.

The Tribunal accepted the assessee's request to withdraw the appeals. The appeals were dismissed as withdrawn.

The Tribunal condoned the delay in filing the first appeal, emphasizing a liberal interpretation of 'sufficient cause' and the importance of substantial justice over technical lapses, especially in the context of the new faceless regime. The matter was then remitted back to the Assessing Officer for a fresh decision.

The Tribunal accepted the assessee's request to withdraw the appeals. The appeals were dismissed as withdrawn based on the assessee's submission that they had received the necessary registration.

The Tribunal held that observations made by the CIT(Exemption) making the registration and approval conditional on a future Supreme Court challenge were unsustainable. A judgment of the jurisdictional High Court is binding, and a contemplated appeal does not dilute its force. The caveats were directed to be deleted.

The Tribunal held that the rejection of segmental profitability by the TPO was not justified as the assessee had provided detailed explanations and the TPO failed to point out specific defects. The Tribunal noted the consistency in accepting similar segmental profitability in prior and subsequent years.

The Tribunal held that the original application was filed within the validity period of provisional registration and the subsequent filing was a corrective measure for a procedural defect. The CIT(E) also failed to consider the power to condone delay.

The Tribunal held that the reassessment notices were issued without jurisdiction and were barred by limitation, as the alleged escaped income did not meet the threshold for the extended period under Section 149(1)(b). Consequently, the penalty orders, being consequential to the invalid assessment, were also quashed.

The Tribunal accepted the assessee's request to withdraw the appeals. The appeals were dismissed as withdrawn by the Tribunal.

The Tribunal held that the right of appeal is a valuable statutory right and provisions for condonation of delay are meant to advance substantial justice. The Tribunal found that the assessee's appeal was dismissed at the threshold without adjudicating the substantive issues.

The Tribunal upheld the CIT(A)'s decision to reduce the addition to 2% of the disputed purchases, following its own prior ruling on identical facts for the assessee. The Tribunal found no infirmity in the appellate authority's conclusion.

The Tribunal held that observations made by the CIT(Exemption) making the registration and approval conditional on a future Supreme Court challenge were unsustainable. A judgment of the jurisdictional High Court is binding, and a contemplated appeal does not dilute its force. The caveats were directed to be deleted.

The Tribunal held that observations made by the CIT(Exemption) making the registration and approval conditional on a future Supreme Court challenge were unsustainable. A judgment of the jurisdictional High Court is binding, and a contemplated appeal does not dilute its force. The caveats were directed to be deleted.