ITAT Mumbai Judgments — July 2026

The Tribunal held that the assessee had provided sufficient documentary evidence to establish the identity, creditworthiness, and genuineness of the loan transaction. The additions were made solely on the basis of a third-party statement without independent corroboration.

The Tribunal held that the CIT(E) should provide an opportunity to the assessee to explain the delay in filing the application for registration. The CIT(E) was directed to consider the applications afresh after providing adequate opportunity to the assessee.

The Tribunal held that the registration of an agreement in the current year did not constitute a fresh acquisition of property when the property was already purchased and possessed nearly two decades earlier. Consequently, the addition under section 56(2)(x) and the consequential penalty under section 270A were rightly deleted.

The Tribunal held that as per the first proviso to Section 56(2)(x), the stamp duty value on the date of the agreement (MOU) should be considered when the agreement date and registration date differ. The addition and consequent penalty were directed to be deleted.

The Tribunal held that assessees should be given an effective and reasonable opportunity to furnish documents and explanations before rejection of their applications. Since this was not adequately provided, the matters were restored to the CIT(E) for fresh adjudication.

The Tribunal held that the assessee had provided sufficient documentary evidence to establish the identity, creditworthiness, and genuineness of the loan transaction. The additions were made solely on the basis of a third-party statement without independent corroboration.

The Tribunal condoned the significant delay in filing the appeal due to the assessee's bonafide belief in pursuing an alternate remedy. The order of the CIT(A) was set aside, and the appeal was restored to the CIT(A) for disposal on merits.

The Tribunal held that the purchase of property from a relative, even if it results in tax planning, is permissible under the law. The denial of deduction solely on the ground of suspicion or the transaction being between related parties is not sustainable.

The Tribunal condoned the delay in filing the application, admitted the appeal, and remitted the matter back to the CIT(E) for a fresh decision on merits. The rejection of the Section 80G application was also set aside for fresh consideration.

The Tribunal condoned the delay in filing the application, admitted the appeal, and remitted the matter back to the CIT(E) for a fresh decision on merits. The rejection of the Section 80G application was also set aside for fresh consideration.

The Tribunal held that the delay in filing the application was nominal and due to a bona fide misconception regarding new provisions. Considering the statutory amendment empowering condonation of delay and the lack of adverse findings on the trust's activities, the matter was remanded.

The Tribunal found merit in the assessee's request to withdraw the appeal. It was determined that the current appeal was a duplicate filing and therefore dismissed as withdrawn.

The Tribunal held that the Assessing Officer (AO) had duly examined the claim for deduction under Section 80P(2)(d) and allowed it after due application of mind. The PCIT's order was set aside, and the AO's order was sustained.

The Tribunal held that assessees should be given an effective and reasonable opportunity to furnish documents and explanations before rejection of their applications. Since this was not adequately provided, the matters were restored to the CIT(E) for fresh adjudication.

The Tribunal held that the CIT's rejection based on a technicality, without examining the substantive merits of the application, was unsustainable. Procedural errors should not override substantive rights, especially when no prejudice is caused to the revenue.

The Tribunal held that the CIT's rejection based on a technicality, without examining the substantive merits of the application, was unsustainable. Procedural errors should not override substantive rights, especially when no prejudice is caused to the revenue.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to the assessee being an NRI and facing issues with communication. The CIT(A)'s order dismissing the appeal in limine was set aside.

The Tribunal found that the appeal was filed within the extended limitation period specified by the CBDT circular. Therefore, the dismissal by the CIT(Appeals) solely on the ground of delay was incorrect.

The Tribunal held that since the reassessment proceedings were founded entirely on seized documents from a third-party search, the AO should have invoked Section 153C, not Section 147/148. Therefore, the assumption of jurisdiction under Section 147/148 was not sustainable.

The Tribunal held that reclassification of income from capital gains to dividend, where the tax liability did not increase and there was no suppression or concealment of income, does not constitute under-reporting of income for the purpose of levying penalty under section 270A.

The Tribunal held that Section 69A was not applicable as the capital was introduced by identified partners through banking channels and recorded in the books. The Revenue failed to provide adverse material to disprove the documents furnished by the assessee.

The tribunal did not condone the delay in filing the appeals due to the vague and unconvincing affidavit provided by the assessee. Furthermore, on merits, the tribunal upheld the additions made by the AO and confirmed by the CIT(A) as the assessee failed to provide evidence for the cash deposits.

The Tribunal held that the addition was unsustainable as it was based solely on third-party statements without independent corroborative evidence connecting the assessee to the cash payment. The Tribunal noted that the assessee's husband was the primary buyer, paid the entire consideration from his accounts, and declared rental income, with no proceedings initiated against him.

The Tribunal upheld the CIT(A)'s decision, finding that the assessee had discharged its onus by providing identity, creditworthiness, and genuineness of the investors. The AO's addition was based heavily on Investigation Wing reports without independent inquiry, and the connection to the alleged accommodation entry provider was not established for the relevant period.

The Tribunal condoned the delay in filing the appeal before the CIT(A) in the interest of justice, granting the assessee another opportunity to present their case. The impugned order of the CIT(A) was set aside and the matter was restored for fresh adjudication.

The Tribunal held that the sanction for issuing the notice under Section 148 was granted by an incompetent authority, rendering the reassessment proceedings void ab initio. Consequently, the entire reassessment was quashed.

The Tribunal condoned the delay in filing the appeal before the CIT(A) in the interest of justice, granting the assessee another opportunity to present their case. The impugned order of the CIT(A) was set aside and the matter was restored for fresh adjudication.

The Tribunal found that the lower authorities did not properly consider the materials on record and the assessee's submissions. Issues like denial of cross-examination and non-provision of relied-upon documents were not adequately addressed.

The Tribunal allowed the admission of additional grounds and restored the issues related to Section 14A and Section 68 to the CIT(A) for fresh adjudication. The Tribunal clarified that this decision does not reflect any opinion on the merits of the dispute.

The Tribunal rejected the assessee's application for condonation of delay due to the absence of sufficient cause and supporting evidence. Consequently, the appeal was dismissed on account of the delay.

The Tribunal held that revaluation of an existing asset, being a notional entry without any inflow of funds or acquisition of a new asset, cannot be treated as an unexplained investment under Section 69. Such revaluation does not result in real income or transfer.

The Tribunal held that the redevelopment scheme did not extinguish ownership rights but merely substituted the old asset with a new one. The holding period should be considered from the date of acquisition of the original flat or the development agreement, making the gain long-term.

The Tribunal held that while the delay was substantial, the assessee's consistent statutory compliances and lack of mala fide intention warranted condonation. The matter was restored to the CIT(A) for adjudication on merits.

The Tribunal held that the notice under section 10(1) of the Black Money Act was issued beyond the prescribed timeline as per CBDT guidelines. Consequently, the entire proceedings were considered procedurally flawed and legally untenable.

The Tribunal held that the additions made by the AO did not constitute an 'asset' as defined for invoking extended reassessment periods under Section 153A/153C. Therefore, the reopening beyond six years was invalid, and the reassessment order was void-ab-initio.

The Tribunal held that the loss arising on year-end revaluation of outstanding foreign exchange forward contracts is an accrued trading loss and allowable as a deduction. Regarding direct costs, the Tribunal held that since the expenditure was incurred wholly and exclusively for the assessee's business and a substantial portion was accepted by the TPO, the disallowance of the remaining direct expenditure was unjustified.

The Tribunal held that the loss arising on year-end revaluation of outstanding foreign exchange forward contracts is an accrued trading loss and allowable as a deduction. Regarding direct costs, the Tribunal held that since the expenditure was incurred wholly and exclusively for the assessee's business and a substantial portion was accepted by the TPO, the disallowance of the remaining direct expenditure was unjustified.

The Tribunal held that the loss arising on year-end revaluation of outstanding foreign exchange forward contracts is an accrued trading loss and allowable as a deduction. Regarding direct costs, the Tribunal held that since the expenditure was incurred wholly and exclusively for the assessee's business and a substantial portion was accepted by the TPO, the disallowance of the remaining direct expenditure was unjustified.

The Tribunal held that the loss arising on year-end revaluation of outstanding foreign exchange forward contracts is an accrued trading loss and allowable as a deduction. Regarding direct costs, the Tribunal held that since the expenditure was incurred wholly and exclusively for the assessee's business and a substantial portion was accepted by the TPO, the disallowance of the remaining direct expenditure was unjustified.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E).

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The Tribunal held that since the 80G approval is dependent on 12A/12AB registration, and the latter was restored, the 80G applications should also be restored. The impugned orders were set aside, and the matters were restored to the CIT(E) for fresh consideration.

The tribunal did not condone the delay in filing the appeals due to the vague and unconvincing affidavit provided by the assessee. Furthermore, on merits, the tribunal upheld the additions made by the AO and confirmed by the CIT(A) as the assessee failed to provide evidence for the cash deposits.

The tribunal held that the approval obtained was not in accordance with the mandatory requirements of section 151(ii) of the Act. Consequently, the notice issued under section 148 and the subsequent assessment order were quashed.

The Tribunal held that the CIT(A) did not exceed his jurisdiction and that his directions for re-verification of interest expenditure and Section 14A disallowance were appropriate. The Tribunal found no infirmity in the CIT(A)'s order.