ITAT Mumbai Judgments — August 2026

The Tribunal found that the matter required a fresh assessment by the AO, considering the AO must provide all relevant materials to the assessee and allow adequate opportunity for hearing and rebuttal.

The Tribunal held that the assessee had discharged the primary onus by furnishing documentary evidence, including loan confirmation and bank statements, which were verified by the AO. The subsequent repayment of the loan through banking channels further supported the genuineness of the transaction.

The Tribunal noted that an identical issue was decided in a related appeal where the matter was restored to the AO for verification. Therefore, the Tribunal set aside the orders of the lower authorities and allowed the appeal for statistical purposes.

The Tribunal noted that an identical issue was decided in a related appeal where the matter was restored to the AO for verification. Therefore, the Tribunal set aside the orders of the lower authorities and allowed the appeal for statistical purposes.

The Tribunal noted that an identical issue was decided in a related appeal where the matter was restored to the AO for verification. Therefore, the Tribunal set aside the orders of the lower authorities and allowed the appeal for statistical purposes.

The Tribunal noted that an identical issue was decided in a related appeal where the matter was restored to the AO for verification. Therefore, the Tribunal set aside the orders of the lower authorities and allowed the appeal for statistical purposes.

The Tribunal found that the matter required a fresh assessment by the AO, considering the AO must provide all relevant materials to the assessee and allow adequate opportunity for hearing and rebuttal.

The Tribunal restored the matter to the Assessing Officer for limited verification of the source of payments towards the property purchase, considering the additional evidence filed by the assessee. The AO is to examine the contributions of both the assessee and her husband.

The Tribunal restored the appeals to the file of the CIT(E) to provide the assessee with an adequate opportunity of hearing. The CIT(E) is to re-adjudicate the applications for registration u/s 12AB and approval u/s 80G.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to the assessee's explanation. The Tribunal restored the issue to the Assessing Officer for fresh verification and decision, considering previous favorable orders for the assessee.

The Tribunal held that the Assessing Officer had conducted sufficient inquiry and the PCIT failed to demonstrate any specific statutory condition violation. The assessment order was not erroneous and prejudicial to the revenue.

The Tribunal found that the disallowance of labour charges was based on an estimation without specific instances of bogus payments. Regarding GST expenses, the Tribunal held that the non-refundability of input tax credit under GST law does not automatically disallow it as a business expenditure under the Income Tax Act. Both these issues were remitted back to the CIT(A) for fresh verification.

The Tribunal held that the assessee is entitled to deduction under Section 80P(2)(d) for interest earned from cooperative banks. This decision was based on previous judgments in the assessee's own case and other similar cases.

The Tribunal held that the assessee is entitled to deduction under Section 80P(2)(d) on interest income earned from cooperative banks, following its own previous decisions and Supreme Court rulings.

The Tribunal held that once a resolution plan is approved by the NCLT and implemented by the Assessing Officer, all claims not forming part of the plan stand extinguished. Therefore, no live dispute survives for adjudication.

The Tribunal decided to grant the assessee one more opportunity to furnish complete documentary evidence to support its application. The case was remanded to the Commissioner for a fresh decision.

The Tribunal condoned the delay of 608 days in filing the appeal, finding the assessee's explanation plausible and bona fide. The case was remanded to the CIT(A) for adjudication on merits as the appeal was dismissed in limine on limitation.

The Tribunal restored the appeals to the file of the CIT(E) to provide the assessee with an adequate opportunity of hearing. The CIT(E) is to re-adjudicate the applications for registration u/s 12AB and approval u/s 80G.

The Tribunal held that the entire investment in the residential property was made by the assessee, entitling him to the full deduction under section 54F. It also held that the assessee had established the identity, creditworthiness, and genuineness of the loan transactions.

The Tribunal upheld the CIT(A)'s decision to restrict the addition to 10% of the cash deposits, finding it reasonable given the assessee's established business and the Revenue's failure to prove an alternative source. However, the Tribunal directed that the sustained addition would not be taxed under Section 115BBE.

The Tribunal held that the addition made by the AO and confirmed by the CIT(A) was not justified. It found that the gross profit rate disclosed on the disputed purchases was higher than that on genuine purchases, rendering further addition unnecessary.

The Tribunal held that the notice issued under Section 148 was bad in law because the approval for reopening was not obtained from the specified authority under Section 151(ii) of the Act. Consequently, the reassessment framed was void ab initio.

The Tribunal directed the Assessing Officer to verify the challans and delete the principal liability under section 201(1) to the extent tax was deposited. Interest under section 201(1A) was to be recomputed. The issue of REC registration charges was also restored for verification of its nature.

The Tribunal noted that although the assessee failed to comply initially, they later submitted the required documents belatedly. Considering the interest of substantial justice, the Tribunal decided to remand the case back to the Commissioner for a fresh decision.

The Tribunal held that the dominant purpose test should be applied, and NPCI's activities were primarily for charitable purposes, even if some surplus was generated. The mere charging of fees for services did not disqualify it from exemption. The Tribunal also found no substance in the allegations of violating Section 13(1)(c)(ii).

The Tribunal held that the accounting treatment of expenditure as CWIP does not determine its tax character. The expenditure was incurred for running an already established business and did not create a new asset or enhance capacity.

The Tribunal held that the dominant purpose test should be applied, and NPCI's activities were primarily for charitable purposes, even if some surplus was generated. The mere charging of fees for services did not disqualify it from exemption. The Tribunal also found no substance in the allegations of violating Section 13(1)(c)(ii).

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal held that the reassessment notice and the subsequent order were bad in law because the approval for reopening was obtained from an authority not specified under Section 151(ii) of the Act. Consequently, the reassessment was quashed.

The Tribunal held that the reassessment proceedings were bad in law because the approval for reopening the assessment was obtained from the Principal Commissioner of Income Tax instead of the Principal Chief Commissioner of Income Tax, as mandated by Section 151(ii) for reopening beyond three years. Consequently, the reassessment order was quashed.

The Tribunal set aside the CIT(A)'s order and restored the appeal for fresh consideration, directing the CIT(A) to decide the condonation of delay liberally. The assessee was also directed to pay a cost of Rs. 1,000.

The Tribunal condoned the delay in filing the appeal, finding sufficient cause. It further held that the CIT(A) had erred in dismissing the appeal without a proper hearing and restoring the matter to the Assessing Officer for fresh assessment.

The Tribunal held that the proportionate interest disallowance under Section 14A is deleted as the assessee demonstrated sufficient interest-free funds for investments. However, the disallowance for indirect expenditure is confirmed. The addition of Section 14A disallowance to book profits under Section 115JB was not sustained.

The Tribunal noted that although the assessee failed to comply initially, they later submitted the required documents belatedly. Considering the interest of substantial justice, the Tribunal decided to remand the case back to the Commissioner for a fresh decision.

The Tribunal held that the reasons recorded for reopening the assessment beyond four years did not demonstrate any specific failure on the part of the assessee to disclose material facts. Therefore, the assumption of jurisdiction under Section 147 was invalid.

The Tribunal held that the accounting treatment of expenditure as CWIP does not determine its tax character. The expenditure was incurred for running an already established business and did not create a new asset or enhance capacity.

The Tribunal upheld the CIT(A)'s decision to restrict the addition to 10% of the cash deposits, finding it reasonable given the assessee's established business and the Revenue's failure to prove an alternative source. However, the Tribunal directed that the sustained addition would not be taxed under Section 115BBE.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.

The Tribunal held that interest income earned from cooperative banks, including from savings accounts, is eligible for deduction under Section 80P(2)(d). This decision followed previous rulings in the assessee's own cases.

The Tribunal held that once the nexus between borrowed funds and the professional asset is established and the asset is used for profession, the interest deduction under Section 36(1)(iii) cannot be restricted based on the rate of interest earned on other advances. The Tribunal emphasized that the commercial expediency is from the assessee's viewpoint.

The Tribunal condoned the delay in filing the appeal, finding reasonable cause. The Tribunal restored the matter to the Assessing Officer for fresh assessment, subject to the assessee paying Rs. 50,000/- as cost.

The Tribunal condoned the delay in filing the appeal due to medical emergencies and consultant changes. While upholding the validity of reassessment proceedings, the Tribunal restored the issue of unexplained investment to the Assessing Officer for fresh adjudication on merits, allowing the assessee to furnish supporting documents.

The Tribunal set aside the assessments for all years and restored the matters to the Assessing Officer for de novo consideration. This was to allow the assessee an effective opportunity to present its case and for the Assessing Officer to examine all material afresh.