ITAT Panaji Judgments — February 2026

The Tribunal found that the CIT(A) erred in sustaining the disallowance without providing proper opportunity and overlooking the fact that the assessee's case did not satisfy the conditions under Section 115BAD(2). The matter was restored to the Assessing Officer for fresh adjudication on merits, allowing the assessee an opportunity to present its case.

The Tribunal held that interest income from cooperative banks is eligible for deduction under Section 80P(2)(d). For interest income from scheduled banks, the matter was restored to the Assessing Officer for fresh adjudication based on whether it's attributable to the society's core business.

The Tribunal partly allowed the Revenue's appeal. It restricted one addition due to potential double counting and upheld the deletion of another addition made solely on a retracted 'admission' without corroborative evidence.

The tribunal held that the assessees failed to provide conclusive evidence that the share transactions occurred in AY 2010-11. The shareholder lists as of March 31, 2011, included the assessees' names, while the list for March 31, 2010, did not. Therefore, the additions made under Section 56(2)(vii) for AY 2011-12 were confirmed.

The tribunal held that the assessees failed to provide conclusive evidence that the share transactions occurred in AY 2010-11. The shareholder lists as of March 31, 2011, included the assessees' names, while the list for March 31, 2010, did not. Therefore, the additions made under Section 56(2)(vii) for AY 2011-12 were confirmed.

The Tribunal held that community development expenses were not covered by CSR provisions for companies and were incurred for village welfare, directing their deletion. Regarding stamp duty, it was deemed a capital expenditure for acquiring a capital asset, but the assessee was allowed depreciation on this amount.

The Tribunal set aside the CIT(A)'s order, remitting the entire disputed issues back to the CIT(A) for fresh adjudication. It emphasized providing the assessee with another opportunity to present their case and evidence, citing principles of natural justice.

The Tribunal set aside the CIT(A)'s order and remitted the issue of unexplained stock back to the CIT(A) for fresh adjudication. This was due to the CIT(A) not adequately considering the assessee's submissions and evidence that the chilli powder stock belonged to another entity, M/s Home Spices, and was recorded in their books.

The Tribunal found that both PANs belonged to the same entity (CIL/CIPL) and that the assessment order was uploaded against the new PAN as per a High Court directive. Therefore, the NFAC erred in dismissing the appeal in limine, and the appeal should be admitted and adjudicated on merits, treating the new PAN as the successor of the old PAN.

The Tribunal found that the notices were indeed received by the assessee after the rejection order. Therefore, it set aside the CIT(E)'s order and remanded the case for a de novo consideration, granting the assessee another opportunity to present its case.

The Tribunal set aside the CIT(A)'s ex-parte order, remitting the case back to the CIT(A) for fresh adjudication on merits. This was done to provide the assessee another opportunity to present their case and evidence, subject to payment of a cost of Rs. 2,000 to the Income Tax Department.

The Tribunal, relying on previous judgments and the principle that the situs of the Assessing Officer determines jurisdiction, dismissed the appeal as not maintainable before the Panaji Bench. It granted leave to the assessee to file the appeal before the appropriate ITAT bench that has territorial jurisdiction over the Assessing Officer.

The Tribunal restored the issue of deduction for dealings with nominal/associate members to the Assessing Officer for verification. It directed the Assessing Officer to allow deduction for interest income from cooperative banks and to re-examine interest income from scheduled/other banks.

The Tribunal restored the issue of deduction for dealings with nominal/associate members to the Assessing Officer for verification. It directed the Assessing Officer to allow deduction for interest income from cooperative banks and to re-examine interest income from scheduled/other banks.

The Tribunal dismissed the appeal as not maintainable due to lack of territorial jurisdiction, citing previous judgments and ITAT rules that establish the situs of the Assessing Officer as the decisive factor for appellate jurisdiction. The assessee was granted leave to file the appeal before the appropriate bench.

The Tribunal found that the CIT(A) did not properly consider the assessee's submissions and evidence, nor did it address the request for a virtual hearing. Therefore, the Tribunal restored the issue to the CIT(A) for fresh adjudication, emphasizing the need for adequate opportunity of being heard.

The Tribunal held that the issue regarding dealings with nominal members needs further verification by the Assessing Officer. It also directed the Assessing Officer to allow deduction for interest income from cooperative banks and restore the issue of interest income from scheduled banks for adjudication on merits, with the total deduction restricted to the original claim.

The ITAT found that the non-compliance was accidental, as the assessee mistakenly sent documents to the jurisdictional ITO instead of the registering authority. Therefore, the ITAT set aside the rejection orders and remanded one application back to the CIT(E) for de-novo consideration, granting the assessee further opportunities to comply.

The Tribunal held that the assessee failed to provide sufficient cause for the inordinate delay in filing the appeals. The reasons provided by the assessee, such as unawareness of the orders and issues with professional services, were found to be lacking in bonafide and supported by cogent evidence.

The Tribunal held that the assessee failed to provide sufficient cause for the inordinate delay in filing the appeals. The reasons provided by the assessee, such as unawareness of the orders and issues with professional services, were found to be lacking in bonafide and supported by cogent evidence.

The Tribunal held that the assessee failed to provide sufficient cause for the inordinate delay in filing the appeals. The reasons provided by the assessee, such as unawareness of the orders and issues with professional services, were found to be lacking in bonafide and supported by cogent evidence.

The ITAT found that the non-compliance was accidental, as the assessee mistakenly sent documents to the jurisdictional ITO instead of the registering authority. Therefore, the ITAT set aside the rejection orders and remanded one application back to the CIT(E) for de-novo consideration, granting the assessee further opportunities to comply.

The Tribunal found that the CIT(A) dismissed the appeal ex-parte without sufficient consideration of the assessee's reasons for non-compliance. Citing principles of natural justice, the Tribunal remitted the case back to the CIT(A) for a fresh adjudication on merits, granting the assessee another opportunity to present its case.

The Tribunal held that interest income from cooperative banks is eligible for deduction under Section 80P(2)(d). The issue of interest from scheduled banks was restored to the Assessing Officer for further examination. The Tribunal also directed the Assessing Officer to allow deduction for interest on income tax refund under Section 80P(2)(a)(i).

The Tribunal held that the delay in filing the appeal was inordinate and not supported by sufficient cause. The explanations provided by the assessee for the delay were found to be vague and contradicted by evidence.

The Tribunal held that the assessee failed to provide sufficient cause for the inordinate delay in filing the appeals. The reasons provided by the assessee, such as unawareness of the orders and issues with professional services, were found to be lacking in bonafide and supported by cogent evidence.

The Tribunal set aside the CIT(A)'s order on this specific issue and remitted the matter back to the Assessing Officer for a de novo consideration. The assessee is to be given an adequate opportunity to substantiate their claim, and the appeal was allowed for statistical purposes.

The Tribunal restored the disputed issue of unexplained investment to the CIT(A) for fresh adjudication. It allowed the admission of additional evidence by the assessee, which included details of loan sanction and property acquisition due to borrower default, as these evidences were crucial for a fair decision and were not previously examined by lower authorities.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the assessee failed to demonstrate a 'sufficient cause' for the inordinate delay in filing the appeals. The reasons provided were not supported by evidence and lacked bonafide, leading to the rejection of the condonation of delay.

The Tribunal held that the stamp duty paid for the renewal of the mining lease was a consideration for acquiring a capital asset, hence not deductible as revenue expenditure. However, it qualified for depreciation as an intangible asset.

The Income Tax Appellate Tribunal allowed the assessee's request to withdraw the appeal, as the Revenue had no objection. Consequently, the appeal was dismissed as withdrawn.

The Tribunal held that the Certificate of Commencement (CoC) granted on 04/04/2007 by the Ministry of Corporate Affairs was sufficient proof that the assessee's business had commenced. The subsequent change in name and object did not require a fresh CoC. Therefore, the disallowances of audit fees and miscellaneous expenses, which were predicated on the non-commencement of business, were incorrect. The Tribunal noted that similar expenses were allowed in the preceding AY 2008-09 without scrutiny. Regarding the disallowance of interest expenditure (Rs. 3,56,51,678/-), the Tribunal found that the assessee had advanced interest-free ICDs to its subsidiary from interest-bearing borrowed funds. The waiver of accrued interest income from the subsidiary was considered a post-facto action that broke the nexus between the borrowed funds and their application for business purposes. The Tribunal relied on the decision in CIT Vs Reliance Utilities & Power Ltd. and held that the interest expenditure was not incurred wholly and exclusively for the purpose of business. The disallowance was upheld.

The ITAT found that the CIT(A) did not adequately consider the evidence and submissions provided by the assessee regarding the source of cash deposits, including agricultural income. Therefore, the ITAT remitted the case back to the CIT(A) for fresh adjudication after providing the assessee a proper opportunity to be heard.

The Tribunal set aside the CIT(A)'s order and remitted the case back to the CIT(A) to reconsider the condonation of delay application and adjudicate the appeal afresh. It emphasized providing adequate opportunity to the assessee and adopting a pragmatic approach.

The Tribunal dismissed the appeal as not maintainable, citing the principle that the situs of the assessing officer determines the appellate forum's jurisdiction. It granted leave to the assessee to file the appeal before the appropriate ITAT bench that has jurisdiction over the Mumbai Assessing Officer.