ITAT Mumbai Judgments — July 2026

The Tribunal found that the CIT(E)'s order lacked specificity regarding the deficiencies and did not properly consider the material submitted by the assessee. Therefore, the matter was restored for fresh adjudication.

The Tribunal held that the notices under Section 148 were issued beyond the surviving period allowed by law, making the reassessment proceedings and consequent orders void-ab-initio for all three assessment years. The AO failed to adhere to the directions of the Apex Court regarding the 'surviving period'.

The Tribunal held that the CIT(E) erred in treating the existing registration as invalid solely for non-production of the old registration certificate. The Tribunal also noted that the CIT(E) did not make any adverse findings regarding the trust's objects or activities.

The Tribunal admitted the additional evidence, finding it relevant for a just decision. Consequently, the Tribunal set aside the AO's order and restored the matter to the AO's file for a fresh assessment, allowing the assessee an opportunity to present submissions and evidence.

The Tribunal held that the Assessing Officer failed to bring any independent material to establish the assessee's actual investment. The assessee's explanation, supported by the broker's confirmation, was considered plausible, and the addition was deleted.

The Tribunal held that the notices under Section 148 were issued beyond the surviving period allowed by law, making the reassessment proceedings and consequent orders void-ab-initio for all three assessment years. The AO failed to adhere to the directions of the Apex Court regarding the 'surviving period'.

The Tribunal admitted the additional evidence, finding it relevant for a just decision. Consequently, the Tribunal set aside the AO's order and restored the matter to the AO's file for a fresh assessment, allowing the assessee an opportunity to present submissions and evidence.

The Tribunal held that the assessee had provided sufficient documentary evidence to substantiate the export turnover and the accounting method followed. The addition on account of alleged difference in export turnover was not justified and was directed to be deleted.

The Tribunal found that while the issue was factual, the assessee had a reasonable case. Therefore, the addition was restricted to Rs. 4,00,000/-, and relief was granted on the remaining amount. The tax on the sustained addition was directed to be at normal rates, not 60% as per Section 115BBE.