ITAT Pune Judgments — April 2026

The Tribunal held that the voluntary contributions were specifically received as corpus donations for building construction and renovation. As these were capital receipts, they were not liable to tax, even for an unregistered trust.

The Tribunal allowed the assessee's request to withdraw the appeal as the grievance raised had become infructuous. The Departmental Representative had no objection to the withdrawal.

The Tribunal held that interest income earned by a cooperative society from investments with another cooperative society is eligible for deduction under Section 80P(2)(d). It also held that surplus arising from transactions with members is not taxable due to the mutuality concept.

The Tribunal dismissed all grounds of appeal raised by the Revenue. For grounds 1 and 2 concerning procedural aspects, the Tribunal found them to be academic as the core issues were decided in favour of the assessee by following earlier ITAT orders. For grounds related to Advertisement and Sales Promotion Expenses, Marketing Support Charges, and Service Charges, the Tribunal noted that the Assessing Officer's disallowances were deleted by the CIT(A). The Tribunal found that these issues were covered in favour of the assessee by the coordinate bench of the ITAT in the assessee's own case for earlier assessment years, and the Revenue had not presented any distinguishing factors. Therefore, the Tribunal saw no reason to interfere with the CIT(A)'s findings. Regarding depreciation on coolers, the Tribunal noted that the CIT(A) had followed the decision of a coordinate bench in the assessee's own case for multiple earlier assessment years. The CIT(A)'s reasoning, which highlighted the assessee's ownership and control over coolers, the interlinked nature of the businesses, and consistency in allowing such claims in preceding years, was upheld. The Tribunal found no new facts to rebut the CIT(A)'s findings. For transfer pricing adjustments related to AMP expenses, the Tribunal noted that the CIT(A) held the TPO's mark-up was arbitrary and that the assessee's overall profitability provided adequate compensation. Following the ITAT order in the assessee's own case for earlier years, the CIT(A) allowed the assessee's ground. The Tribunal found no reason to deviate from these findings. Consequently, all grounds raised by the Revenue were dismissed.

The Tribunal held that interest income earned by a cooperative society from its investments with another cooperative society is eligible for deduction under Section 80P(2)(d). It also held that surplus arising from transactions with members is not taxable due to the mutuality concept.

The Tribunal held that the AO failed to provide sufficient evidence to prove direct transactions between the assessee and the entities providing accommodation entries. It also found that additions for payments to related parties lacked a basis in tangible material, such as comparative market rates.

The Tribunal held that the addition for unexplained cash deposit was uncalled for as the assessee consistently received cash from its members and maintained proper records. It also held that the deduction under Section 80P was allowable as the amendment to Section 80AC making it mandatory to file a return was applicable from AY 2018-19 onwards.

The Tribunal held that interest income earned by a cooperative society from investments with another cooperative society is eligible for deduction under Section 80P(2)(d). It also held that surplus arising from transactions with members is not taxable due to the mutuality concept.

The Tribunal held that the credit card payments were for business purposes, sourced from the assessee's gross receipts declared under Section 44AD. Therefore, the penalty was not sustainable.

The Tribunal held that even in cases of voluntary retirement compensation, the assessee is entitled to relief under Section 89(1) for arrears of salary received. The quantum of relief was not disputed and Form 10E was filed.

The Tribunal held that the AO failed to provide sufficient evidence to prove direct transactions between the assessee and the entities providing accommodation entries. It also found that additions for payments to related parties lacked a basis in tangible material, such as comparative market rates.

The Tribunal held that the interest-free funds available with the assessee were more than the advances made to the related parties. Therefore, the charging of a lower interest rate of 6% to related parties was acceptable, and the Assessing Officer's disallowance was uncalled for.

The Tribunal held that interest income earned by a cooperative society from investments with another cooperative society is eligible for deduction under Section 80P(2)(d). It also held that surplus arising from transactions with members is not taxable due to the mutuality concept.

The Tribunal held that the addition was made solely on the basis of a retracted statement and an uncorroborated excel sheet, without providing an opportunity for cross-examination. The builder also issued a letter denying cash receipts from the assessee.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the CIT(A) is obliged to decide an appeal on merit and does not possess the power to dismiss an appeal for non-prosecution. Citing the Hon'ble Bombay High Court's decision in Pr.CIT(Central) Vs. Premkumar Arjundas Luthra (HUF), the Tribunal emphasized that Section 250(4) and 250(6) of the Income Tax Act, 1961, mandate the CIT(A) to make further inquiries if necessary and dispose of the appeal in writing, stating points for determination and rendering decisions on each point with reasons. Section 251(1)(a) and (b) grant powers to confirm, reduce, enhance, or annul an assessment/penalty, and the Explanation to Section 251(2) allows consideration of any issue arising in the proceedings. Therefore, the CIT(A) must apply their mind to all issues, and dismissing an appeal for non-prosecution is not permitted. In the interest of justice, the Tribunal set aside the order of the CIT(A) and remanded the case for denovo adjudication, directing the CIT(A) to provide an opportunity to the assessee and for the assessee to file necessary documents. The grounds of appeal were allowed for statistical purposes.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.

The Tribunal held that the compensation received under the BSNL Voluntary Retirement Scheme was in the nature of retrenchment compensation and thus exempt from tax under Section 10(10B) of the Income Tax Act. The impugned orders of the CIT(A) were set aside.