ITAT Panaji Judgments — January 2026

The Tribunal rejected the assessee's legal ground regarding the jurisdiction of reassessment proceedings as it was raised for the first time without sufficient supporting facts. However, it noted a potential violation of natural justice by the CIT(A) and deemed it crucial for determining the correct tax liability, implying a need for further examination of the merits.

The tribunal noted that the assessee submitted evidence, including a gift confirmation and bank statements, after the assessment order was passed but before the CIT(A) decision. Citing principles of natural justice, the tribunal remanded the case back to the Assessing Officer for a fresh adjudication, allowing the assessee another opportunity to present evidence.

The Tribunal found that the CIT(A) did not properly consider the assessee's submissions and evidence. It decided to restore the disputed issues to the Assessing Officer for fresh adjudication, ensuring the assessee is given adequate opportunity to be heard and present evidence.

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing sufficient cause and the principles of natural justice. It set aside the CIT(A)'s order and remitted the entire disputed issues back to the CIT(A) for fresh adjudication on merits, providing the assessee an opportunity to present its case.

The Tribunal found that the CIT(A) failed to consider the assessee's evidence and submissions regarding the validity of the Section 148 notice and the denial of the Section 80P deduction. Therefore, the case was remanded back to the CIT(A) for fresh adjudication, ensuring the assessee is given an adequate opportunity to be heard.

The tribunal noted the substantial delay of 802/803 days in filing the appeals. The assessee claimed unawareness of the NFAC orders due to corporate restructuring and centralization of the tax department post-merger. However, the tribunal observed that the assessee had confirmed receipt of the impugned orders on the date of their passing in Form No. 36 and an affidavit, contradicting the claim of unawareness. The tribunal did not condone the delay.

The Tribunal condoned a 77-day delay in filing the appeal and, noting the ex-parte order by CIT(A) despite non-compliance, decided to provide the assessee another opportunity. The case was remitted back to the CIT(A) for fresh adjudication on merits, subject to the assessee paying a cost of Rs. 5,000.

The tribunal noted that the appeals were filed with a delay of 802/803 days. The assessee claimed unawareness of the first appellate orders due to corporate restructuring and centralization of the tax department post-merger. However, the tribunal observed that the assessee had confirmed receipt of the impugned orders on the date of their passing in Form No. 36 and an affidavit, contradicting their claim of unawareness. The tribunal did not condone the delay.

The tribunal noted that the assessee admitted to receiving the impugned orders on the date they were passed, contradicting their claim of unawareness. The reasons cited for the delay, such as corporate restructuring and centralization of the tax department, were deemed insufficient as the restructuring occurred before the latest assessment and all impugned orders. The tribunal found a lack of bonafide reasons and negligence on the part of the assessee, a large commercial bank, in pursuing its tax litigation.

The Tribunal admitted additional evidence submitted by the assessee, including financial statements and cash books, which were not presented to lower authorities. It remitted the case back to the CIT(A) to verify these new evidences and adjudicate the matter afresh on merits, ensuring the assessee is given an adequate opportunity of hearing.

The Tribunal allowed the Revenue's request to withdraw its appeal, finding no reason to reject the petition. Consequently, the appeal filed by the Revenue was dismissed as withdrawn.

The Tribunal condoned the delay in filing the appeals. It restored the issue of deduction under Section 80P(2)(a)(i) for dealings with nominal/associate members to the AO for re-verification, citing judicial precedent. The disallowance of prior period income tax was confirmed, while the disallowance of provision for bad and doubtful debts was also restored to the AO for verification.

The Tribunal condoned the delay in filing the appeals. It restored the issue of deduction under Section 80P(2)(a)(i) for dealings with nominal/associate members to the AO for re-verification, citing judicial precedent. The disallowance of prior period income tax was confirmed, while the disallowance of provision for bad and doubtful debts was also restored to the AO for verification.

The Tribunal condoned the delay in filing the appeals. It remanded the issue of deduction under Section 80P(2)(a)(i) for dealings with nominal/associate members back to the AO for verification, citing a judicial precedent. The disallowance of prior period income tax was confirmed, but the disallowance of provision for bad and doubtful debts was also remanded to the AO for re-verification.

The Tribunal condoned the delay in filing the appeal and noted that crucial details of interest income were submitted for the first time during the appeal. Citing the need for detailed verification of the nature and source of income to determine deductibility, the Tribunal set aside the impugned order and remanded the case to the Assessing Officer for de-novo adjudication.