ITAT Mumbai Judgments — August 2026

The Tribunal upheld the CIT(A)'s order, finding that the assessee failed to discharge its onus to prove the genuineness of transactions despite admissions and corroborating evidence. The estimation of commission income was deemed reasonable.

The Tribunal admitted an affidavit from the Chartered Accountant explaining a technical error that caused duplication of figures in the return. The matter was restored to the CIT(A) for fresh adjudication after considering this additional evidence.

The Tribunal held that the addition under Section 68 was not sustainable as the assessee had provided primary evidence and established repayment through banking channels, relying on previous decisions. However, the disallowance of interest was partly allowed, subject to verification of whether the written-off interest was offered as income in a subsequent year.

The Tribunal held that the CIT(A) was correct in deleting the additions. The assessee had discharged the onus by providing sufficient evidence, and the AO failed to bring any cogent evidence to disprove the genuineness of the transactions.

The Tribunal upheld the CIT(A)'s decision to delete the additions, finding that the assessee had discharged the onus of proving the genuineness of the transactions with substantial evidence. The AO failed to bring any cogent evidence to counter the assessee's submissions.

The Tribunal upheld the addition made by the Assessing Officer and confirmed by the CIT(A). The assessee failed to discharge its onus of proving the genuineness of the transactions even before the Tribunal.

The Tribunal held that the Assessing Officer failed to conduct independent inquiry and relied solely on investigation reports. The assessee had provided documentary evidence and explanations which were not disproved by cogent material, thus the addition was not sustainable.

The Tribunal held that the unsecured loans were genuine and supported by documentary evidence. Consequently, consequential disallowances of interest and commission were also directed to be deleted.

The Tribunal dismissed the Revenue's appeal on the technical ground that the tax effect was below the prescribed threshold for filing an appeal. Consequently, the assessee's cross-objection became academic and was also dismissed.

The Tribunal held that income accrues only when the right to receive becomes enforceable and crystallized, and based on the mercantile system of accounting and AS-9, the income could not be recognized in AY 2017-18 as services were rendered and invoices raised in AY 2018-19. The addition was deleted as no prejudice was caused to the revenue.

The Tribunal held that the unsecured loans were genuine and supported by documentary evidence. Consequently, consequential disallowances of interest and commission were also directed to be deleted.

The Tribunal held that the unsecured loans were genuine and supported by documentary evidence. Consequently, consequential disallowances of interest and commission were also directed to be deleted.

The Tribunal admitted additional evidence and found that the lower authorities did not properly examine the redevelopment agreement and the nature of the compensation. The matter was restored to the CIT(A) for fresh adjudication.

The Tribunal held that brokerage is payable only after the transaction is complete, making the AO's reasoning for disallowance invalid. Furthermore, relying on jurisdictional High Court precedent, the Tribunal ruled that appellate authorities can entertain claims made for the first time, even if not in the original return, provided they are genuine and supported by evidence.

The Tribunal held that mere handling or transportation of cash does not automatically mean the assessee is the owner. Additions made purely on uncorroborated WhatsApp chats and unsupported third-party statements without independent material were deleted. Additions related to cash transportation/Angadia activity were restricted to commission income.

The Tribunal held that cooperative banks are primarily cooperative societies and interest earned from them is eligible for deduction under Section 80P(2)(d). This decision was based on a series of previous judgments by the Tribunal and various High Courts.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal set aside the CIT(A)'s deletion of Rs. 7,59,16,324 of accommodation entries and restored the issue to the AO for fresh adjudication. For the sustained addition of Rs. 24,72,470, the Tribunal modified the CIT(A)'s order by estimating and adding the differential profit.

The Tribunal held that the CCIT's action was not in accordance with judicial discipline as the issue had already been adjudicated by the ITAT for the same assessment year. The Tribunal found that the CCIT lacked valid jurisdiction to invoke revisional powers under Section 263 after the ITAT had passed its order.

The Tribunal held that the unsecured loans were genuine and supported by documentary evidence. Consequently, consequential disallowances of interest and commission were also directed to be deleted.

The Tribunal set aside the CIT(A)'s deletion of Rs. 7,59,16,324 of accommodation entries and restored the issue to the AO for fresh adjudication. For the sustained addition of Rs. 24,72,470, the Tribunal modified the CIT(A)'s order by estimating and adding the differential profit.

The Tribunal held that for a single executor, the estate's income should be taxed as if the executor were an individual, applying normal slab rates as per Section 168(1)(a). The matter was restored to the AO for verification and assessment at individual rates.

The Tribunal restored several issues, including working capital and risk adjustments for transfer pricing, back to the Assessing Officer/TPO for fresh examination. Other grounds related to capital gains and disallowances were also directed to be adjudicated by the AO.

The Tribunal held that the AO's restriction of wastage to 12% was arbitrary and not supported by cogent material, especially given the assessee's consistent wastage claims in surrounding years and acceptance in a subsequent scrutiny assessment. Similarly, the disallowance under Section 40A(2)(b) was not sustainable as the AO failed to demonstrate that the expenditure was excessive or unreasonable, and the nature of services rendered by related parties was distinct from general casting.

The Tribunal condoned the delay, finding sufficient cause for the late filing. It held that the reassessment notice under Section 148 was issued beyond the prescribed time limit and without proper approval, making it void ab initio.

The Tribunal held that mere handling or transportation of cash does not automatically mean the assessee is the owner. Additions made purely on uncorroborated WhatsApp chats and unsupported third-party statements without independent material were deleted. Additions related to cash transportation/Angadia activity were restricted to commission income.

The Tribunal held that mere handling or transportation of cash does not automatically mean the assessee is the owner. Additions made purely on uncorroborated WhatsApp chats and unsupported third-party statements without independent material were deleted. Additions related to cash transportation/Angadia activity were restricted to commission income.

The Tribunal restored the matter to the file of the CIT(A) to provide the assessee with an adequate opportunity to present their case. This restoration was subject to a cost of ₹2,000/- to be deposited by the assessee.

The Tribunal set aside the CIT(A)'s deletion of Rs. 7,59,16,324 of accommodation entries and restored the issue to the AO for fresh adjudication. For the sustained addition of Rs. 24,72,470, the Tribunal modified the CIT(A)'s order by estimating and adding the differential profit.

The Tribunal held that the authorities below erred in invoking the proviso to Section 2(15) solely based on rental income and license fees. It clarified that such receipts from properties held under trust are not necessarily business income, especially when incidental to charitable objects.

The Tribunal set aside the CIT(A)'s deletion of Rs. 7,59,16,324 of accommodation entries and restored the issue to the AO for fresh adjudication. For the sustained addition of Rs. 24,72,470, the Tribunal modified the CIT(A)'s order by estimating and adding the differential profit.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal condoned the delay in filing the appeal due to sufficient cause. It further held that the PCIT erred in invoking Section 263 when the original assessment order was already under appeal before the CIT(A), and the issues were not erroneous or prejudicial to the revenue.

The Tribunal found merit in the assessee's explanation for non-compliance and decided to restore the matter to the CIT(A) for a fresh adjudication. The assessee was directed to be diligent in future proceedings.

The Tribunal held that the separate agreements for amenities and furniture were integral parts of the principal Leave and Licence Agreement, forming a single composite transaction. Therefore, all receipts should be assessed under 'Income from House Property'.

The Tribunal held that additions cannot be made solely on the basis of third-party information without independent verification or corroboration. The assessee had provided documentary evidence, including GST returns showing no input tax credit was claimed from the supplier, which conclusively demonstrated no transaction occurred.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that the unsecured loans were genuine and supported by documentary evidence. Consequently, consequential disallowances of interest and commission were also directed to be deleted.

The Tribunal held that deemed rental income for unsold stock-in-trade should be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure based solely on a survey statement without corroboration is unsustainable.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that the separate agreements for amenities and furniture were integral parts of the principal Leave and Licence Agreement, forming a single composite transaction. Therefore, all receipts should be assessed under 'Income from House Property'.

The Tribunal held that the reassessment proceedings were initiated prior to the effective date of the e-Assessment Scheme, rendering the assumption of jurisdiction by the AO invalid. Consequently, the assessment order was deemed void ab initio.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that deemed rental income for unsold stock-in-trade must be computed based on the municipal rateable value, not a percentage of cost. It also held that an addition for unexplained expenditure cannot be solely based on a survey statement without corroborative evidence.

The Tribunal held that the addition cannot be sustained solely on the basis of a third party's statement and seized material from the builder's premises without corroborative evidence linking it to the assessee. The revenue failed to discharge its burden of proof.

The Tribunal held that the foreign taxes paid abroad, which are eligible for relief under Section 90/91, are governed by Section 40(a)(ii) of the Act and cannot be allowed as a deduction under Section 37(1). The decision of the Bombay High Court in Reliance Infrastructure Limited was distinguished.

The Tribunal held that the unsecured loans were genuine and supported by documentary evidence. Consequently, consequential disallowances of interest and commission were also directed to be deleted.