ITAT Patna Judgments — April 2026

The Tribunal noted that the AO had not examined the issue in light of relevant CBDT and RBI notifications. Following a coordinate bench's decision in a similar case, the Tribunal remitted the issue back to the AO for fresh adjudication.

The Tribunal held that the AO failed to properly examine issues related to subsidies and grants impacting depreciation claims, and prior period expenses. Therefore, the PCIT rightly exercised powers under Section 263 to direct a fresh assessment.

The Tribunal found that the assessee failed to correlate the disputed figures with their declared turnover. Therefore, the CIT(A)'s decision to include 8% net profit on the unaccounted turnover for both assessment years was upheld.

The Tribunal found that the assessee failed to correlate the disputed figures with their declared turnover. Therefore, the CIT(A)'s decision to include 8% net profit on the unaccounted turnover for both assessment years was upheld.

The Tribunal upheld the CIT(A)'s finding that Section 44AD is not applicable to professionals. However, it agreed with the CIT(A)'s direction to compute the professional income at 60% of the gross receipts, considering it a reasonable estimation in the absence of detailed accounts.

The Tribunal condoned the delay in filing the appeal and, considering the ex-parte nature of the orders and in the interest of justice, remitted the issue back to the AO for fresh consideration. The assessee was directed to provide substantiating documents and avoid unnecessary adjournments.

The Tribunal found that the documentary evidence for the disallowance of expenses and the explanation for the bank deposits (including past savings) were not properly appreciated by the lower authorities. Therefore, the issues were remanded back to the CIT(A) for fresh examination.

The Tribunal upheld the order of the CIT(A) and dismissed the assessee's appeals. The assessee failed to establish the source of investments with cogent documentary evidence, making the deposits in the bank account and the share purchases unexplained.

The Tribunal upheld the addition of Rs. 9,56,210/- as undisclosed income. The assessee's admission during the survey and failure to provide justification for the lower declared income were considered decisive.

The Tribunal held that the delay of 7 days was marginal and deserved to be condoned in the interest of justice. Dismissing the appeal without adjudicating on merit is contrary to law.

The Tribunal upheld the order of the CIT(A) and dismissed the assessee's appeals. The assessee failed to establish the source of investments with cogent documentary evidence, making the deposits in the bank account and the share purchases unexplained.

The Tribunal noted that the assessment was completed ex-parte by the AO and the appeal was also dismissed ex-parte by the CIT(A) due to non-response from the assessee. Therefore, in the interest of justice, the Tribunal remitted the issue back to the CIT(A) for a fresh decision after providing a reasonable opportunity of being heard to the assessee.

The Tribunal observed that the AO had rightly applied Section 145(3) of the Act. However, in the interest of justice, the issue was remanded back to the AO for a fresh decision, directing the assessee to substantiate its claims with cogent documents.

The Tribunal noted that the assessee had been given ample opportunities but failed to explain the source of the cash deposits. However, in the interest of justice, the case was remitted back to the AO to provide one more chance to the assessee to substantiate the source with cogent documents.

The Tribunal held that the CIT(A) should have adopted a liberal approach to condone the marginal delay and examine the merits of the case. Dismissing the appeal solely on delay without considering the substantive issues was deemed incorrect.

The Tribunal acknowledged the assessee's plea for a fresh opportunity due to non-receipt of notices and the complexity of capital gains taxation under Section 45(5A) concerning JDA completion certificates. Therefore, the case was remitted back to the Assessing Officer for a fresh decision.

The Tribunal noted that the case was decided ex-parte at both lower levels due to the assessee's non-compliance. In the interest of justice, the Tribunal decided to remit the issue back to the AO for a fresh decision after providing the assessee a reasonable opportunity to be heard.

The Tribunal noted that it was unclear if the funds deposited in the trustee's account were utilized for charitable purposes or personal benefit. Therefore, the issue was remitted back to the CIT(A) for fresh adjudication.

The Tribunal, while acknowledging the assessee's negligence, granted one final opportunity for a de novo adjudication by the Assessing Officer in the interest of natural justice and fair play.

The ITAT set aside the CIT(A)'s order and restored the matter to the CIT(A) for adjudication on merits. The tribunal emphasized the principle of natural justice and the need for appeals to be decided on merit.

The Tribunal noted a subsequent Civil Court order cancelling the development agreement and restoring the land to the assessee. This new evidence was not examined by lower authorities.

The Tribunal, considering the assessee's offer to surrender a portion of the income to avoid litigation and the fact that a substantial part of the investment was explained, restricted the addition. The balance addition was directed to be deleted.

The ITAT set aside the CIT(A)'s order and restored the matter to the CIT(A) for adjudication on merits. The tribunal emphasized the principle of natural justice and the need for appeals to be decided on merit.

The Tribunal found that the delay, though significant and due to negligence, should not prevent examination of the core issue of TDS credit. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal found that the delay, though significant and due to negligence, should not prevent examination of the core issue of TDS credit. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal, while acknowledging the assessee's consistent failure to provide evidence, granted one final opportunity for substantiation due to principles of natural justice. The case was restored to the Assessing Officer for fresh adjudication.

The Tribunal held that the CIT(E) erred in rejecting the application based on an inconsistency in the Articles of Association, as the Memorandum of Association prevails in such cases. The Tribunal also noted that the winding-up clause in the Articles of Association had since been corrected.

The Tribunal set aside the CIT(A)'s order and restored the matter for fresh adjudication. The assessee was granted an opportunity to present their case and documents, provided they cooperated fully.

The Tribunal condoned the delay in filing the appeal and, while acknowledging the assessee's non-compliance, decided to provide one more opportunity to present the case and evidence to uphold natural justice.

The Tribunal condoned the delay in filing the appeal and, while acknowledging the assessee's non-compliance, decided to provide one more opportunity to present the case and evidence to uphold natural justice.

The Tribunal found that the delay, though significant and due to negligence, should not prevent examination of the core issue of TDS credit. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal found that the delay, though significant and due to negligence, should not prevent examination of the core issue of TDS credit. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal found that the delay, though significant and due to negligence, should not prevent examination of the core issue of TDS credit. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal noted that the AO computed income on GP basis ignoring incriminating documents found during search. Considering the interest of justice, the issue is remitted back to the AO for in-depth examination with a direction to the assessee to substantiate with credible evidence.

The Tribunal held that while Rs. 57,00,000/- of the deposit was reasonably explained by prior withdrawals in the same denomination, the remaining Rs. 52,00,000/- remained unexplained due to the denomination mismatch and lack of supporting evidence.

The Tribunal condoned the delay in filing the appeal and, while acknowledging the assessee's non-compliance, decided to provide one more opportunity to present the case and evidence to uphold natural justice.

The Tribunal held that the CIT(E) erred in rejecting the application based on an inconsistency in the Articles of Association, as the Memorandum of Association prevails in such cases. The Tribunal also noted that the winding-up clause in the Articles of Association had since been corrected.

The Tribunal found that the delay, though significant and due to negligence, should not prevent examination of the core issue of TDS credit. In the interest of justice, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal held that Section 43CA applies to the transfer of tangible immovable property (land or building). Transferable Developmental Rights (TDRs) are intangible rights and not land or building per se. Following judicial precedents, the Tribunal found no infirmity in the CIT(A)'s order deleting the addition.

The Tribunal held that Section 50C is applicable only to capital assets and not to stock-in-trade. Based on documentary evidence and consistent accounting treatment, the land was considered stock-in-trade, making Section 50C inapplicable.

The Tribunal upheld the CIT(A)'s deletion of the addition for disallowed purchases, finding them to be genuine transactions with individual customers not registered under GST. It also upheld the deletion of the addition for capital introduction, as it was a return of stock previously withdrawn by the proprietor.

The Tribunal upheld the CIT(A)'s decision to restore the matter to the Assessing Officer. This was because the assessee failed to comply with notices and properly present their case before the lower authorities, and no supporting evidence was provided to the Tribunal.

The Tribunal noted that the assessee failed to provide credible evidence to support the cash deposits. Therefore, the issue was remanded back to the Assessing Officer for a deeper examination.

The Tribunal condoned the delay in filing the appeal for one case but dismissed the appeal against the revision order due to lack of bona fides. For the other appeal, it was restored to the Assessing Officer for re-adjudication.

The Tribunal condoned the delay in filing the appeal for one case but dismissed the appeal against the revision order due to lack of bona fides. For the other appeal, it was restored to the Assessing Officer for re-adjudication.

The ITAT condoned the delay in filing the appeal before the CIT(A) based on the assessee's illness, citing a liberal interpretation of 'sufficient cause'. The matter was restored to the CIT(A) for denovo adjudication on merits.

The Tribunal, following the principles of natural justice and a Bombay High Court judgment, decided to provide the assessee with one final opportunity to present their case. The matter was remitted back to the CIT(A) for fresh adjudication.

The Tribunal restored the issue to the file of the Jurisdictional Assessing Officer (JAO) to provide the assessee with another opportunity to present evidence for the cash deposits. The JAO was directed to adjudicate the matter on merits after considering the submitted documents.

The Tribunal upheld the CIT(A)'s deletion of disallowance for departmental recoveries from Orissa Mining Corporation, finding it a contractual adjustment. However, it sustained the disallowance for Hindalco Industries' overloading charges as penal. The issue of excess provision by NALCO was remanded to the AO for verification.