ITAT Panaji Judgments — November 2025

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The tribunal held that cooperative societies registered under relevant acts are eligible for deduction under Section 80P(2)(a)(i) even if they deal with nominal/associate members. Interest earned from cooperative banks is deductible under Section 80P(2)(d), but interest from nationalized banks is not.

The ITAT held that the NFAC erred in dismissing the appeal in-limine as 'infructuous', stating that each proceeding under the Income Tax Act is distinct and the outcome of one does not automatically determine another. The NFAC was legally mandated by Sections 251(1)(a) and 250(6) to adjudicate the issues on merit. Therefore, the tribunal set aside the NFAC's order and remanded the matter for de-novo adjudication and a speaking order.

The tribunal, after perusing the assessee's application to withdraw the appeal and finding no reasons to reject the request, permitted the withdrawal. Consequently, the appeal was dismissed as withdrawn.

The Tribunal condoned the 43-day delay in filing the appeal, finding 'sufficient cause'. It held that the NFAC erred in dismissing the appeal ex-parte, as the newly inserted proviso to section 251(1) of the Act mandates setting aside a section 144 assessment for de-novo assessment by the AO. Therefore, the Tribunal set aside the NFAC's order and remanded the case back to the NFAC for fresh adjudication and to pass a speaking order as per section 250(6) of the Act.

The Tribunal noted the assessee had a pending condonation application u/s 119(2)(b) with the CIT(E). It set aside the CIT(A)'s order and restored the matter to the Assessing Officer to consider the outcome of the condonation application before deciding the exemption claim under Section 11, granting the assessee an adequate opportunity of hearing.

The Tribunal held that the NFAC failed to properly adjudicate the first issue regarding the validity of the disallowance under section 14A and entirely omitted the third issue concerning the computation of disallowance without reducing non-exempt income investments, thereby contravening section 250(6) of the Income-tax Act. Citing judicial precedents, the Tribunal ruled that it lacks jurisdiction to decide grounds not previously adjudicated by the first appellate authority. Consequently, the Tribunal set aside the NFAC's order concerning these non-adjudicated issues and remitted the matter back to the NFAC for fresh adjudication in accordance with law.

The Tribunal found that the CIT(A) dismissed the appeal ex-parte without providing an adequate opportunity of hearing, despite the assessee raising valid grounds challenging the denial of section 80P deduction. Upholding the principles of natural justice, the Tribunal set aside the CIT(A)'s order. The matter was remitted back to the CIT(A) for fresh adjudication after granting the assessee a proper opportunity to submit evidence and information.

The Tribunal held that the CIT(A) erred in admitting additional evidence without following Rule 46A of the IT Rules and without giving the AO an opportunity to examine it. The Tribunal found the impugned adjudications to be devoid of evidence and lacking merit.

The Tribunal held that the CIT(A) erred in admitting additional evidence without following Rule 46A of the IT Rules and without giving the AO an opportunity to examine it. The Tribunal found the impugned adjudications to be devoid of evidence and lacking merit.

The Tribunal held that the CIT(A) erred in admitting additional evidence without following Rule 46A of the IT Rules and without giving the AO an opportunity to examine it. The Tribunal found the impugned adjudications to be devoid of evidence and lacking merit.

The Tribunal held that the CIT(A) erred in admitting additional evidence without following Rule 46A of the IT Rules and without giving the AO an opportunity to examine it. The Tribunal found the impugned adjudications to be devoid of evidence and lacking merit.

The Tribunal held that the CIT(A) erred in admitting additional evidence without following Rule 46A of the IT Rules and without giving the AO an opportunity to examine it. The Tribunal found the impugned adjudications to be devoid of evidence and lacking merit.

The Tribunal found that the CIT(A) erred in partly confirming the addition of estimated profit on securities transactions. Considering the assessee's application for admission of additional evidence under Rule 29 of ITAT Rules, which included substantial new documents, the Tribunal decided to admit the additional evidence. The disputed issues, along with the additional evidence, were restored to the Assessing Officer for fresh adjudication with adequate opportunity of hearing for the assessee.

The Tribunal allowed the assessee's application for admission of additional evidence under Rule 29 of the ITAT Rules, noting that such evidence was crucial for a fair decision and could not be presented before lower authorities. Consequently, the disputed issues, including the additions under Section 69A and interest income, were restored to the Assessing Officer for fresh adjudication on merits, providing the assessee with an opportunity to submit the new information.

The Tribunal noted that the assessee had submitted voluminous documentary evidence online to the CIT(A) which was overlooked, constituting a violation of the principles of natural justice. Citing judicial precedents, the Tribunal set aside the CIT(A)'s order and remitted the case back to the CIT(A) for a fresh decision, directing consideration of all evidence already on record and the issuance of a speaking order under section 250(6).

The Tribunal allowed the assessee to produce letters/certificates related to the subsidized interest scheme as additional evidence under Rule 29 of the ITAT Rules. Considering this new evidence vital for assessing the eligibility of the Section 80P deduction, the Tribunal remanded the case back to the AO. The AO is directed to consider these additional evidences for their taxability and eligibility while re-computing the 80P deduction.

The ITAT condoned the 89-day delay in filing the appeal before itself. It set aside the CIT(A)'s order, remitting the matter for fresh adjudication, instructing the CIT(A) to provide an opportunity to the assessee to file a condonation of delay application and consider it pragmatically, and then decide the appeal on its merits.

The Tribunal acknowledged the ex-parte dismissal by the CIT(A) but emphasized the principles of natural justice. It decided to set aside the CIT(A)'s order and remitted the matter back to the CIT(A) to provide the assessee with an adequate opportunity of hearing to substantiate its case regarding the Section 80P deduction.

The Tribunal, considering the principles of natural justice, set aside the ex-parte order passed by the CIT(A). It remitted the disputed issues back to the CIT(A) for fresh adjudication, providing the assessee with another opportunity to present its case and cooperate in submitting information.

The Tribunal acknowledged that the CIT(A) dismissed the appeal for non-compliance, but noted that the assessee's AR claimed a good case on merits and sought an opportunity to present evidence. Considering the principles of natural justice, the Tribunal set aside the CIT(A)'s order and remitted the disputed issues back to the CIT(A) for fresh adjudication, providing the assessee an adequate opportunity of hearing.

The Tribunal remanded the issue of addition u/s 68 back to the AO, directing re-verification and an opportunity for the assessee to present evidence, noting the CIT(A) had overlooked submissions. For the denial of u/s 80P deduction, the Tribunal, relying on judicial precedents, ruled that Section 80AC and Section 80A(5) were not applicable for AY 2017-18 and earlier, allowing the deduction even if the return was filed late. It set aside the CIT(A)'s order on this point and directed the AO to allow the 80P claim.

The ITAT acknowledged the assessee's grounds of appeal and claim of having material evidence, noting that the CIT(A) dismissed the appeal for non-compliance without fully considering the merits. Upholding principles of natural justice, the ITAT set aside the CIT(A)'s order and remitted the disputed issues back to the CIT(A) for fresh adjudication, providing the assessee another opportunity to present its case.