ITAT Patna Judgments — March 2026

The Tribunal, considering the assessee's age and ill-health, condoned the 128-day delay in filing the appeal before the CIT(Appeals). The Tribunal found it appropriate to provide another opportunity to the assessee to present their case on merits.

The Tribunal held that the CIT(A)'s failure to call for a remand report before admitting additional evidence violated principles of natural justice. Therefore, the appellate order was set aside.

The Tribunal held that the deposits in the second bank account were part of business activity and not unexplained income, deleting the addition under Section 69A. However, it restricted the addition on interest income to the differential amount not disclosed.

The Tribunal condoned the delay in filing the appeal as the reasons provided were bonafide and genuine. The Tribunal also admitted additional evidence (a lease deed dated 24.01.2011) filed by the assessee, deeming it to have a significant bearing on the issue. The matter was restored to the Assessing Officer (AO) for a fresh decision considering this additional evidence.

The Tribunal held that the reasons provided for the delay in filing the appeal were not substantial. Consequently, the appeal was dismissed in limine on account of the delay.