ITAT Pune Judgments — April 2026

The Tribunal allowed the deletion of additions related to interest on loans, following its previous orders. For supervision charges and other TDS-related disallowances, the issues were restored to the Assessing Officer for fresh adjudication. Additions for estimated profits were also directed to be deleted.

The Tribunal allowed the deletion of additions related to interest on loans, following its previous orders. For supervision charges and other TDS-related disallowances, the issues were restored to the Assessing Officer for fresh adjudication. Additions for estimated profits were also directed to be deleted.

The Tribunal allowed the deletion of additions related to interest on loans, following its previous orders. For supervision charges and other TDS-related disallowances, the issues were restored to the Assessing Officer for fresh adjudication. Additions for estimated profits were also directed to be deleted.

The Tribunal held that the amendment to Rule 8D of the IT Rules, effective from 02.06.2016, was prospective and not applicable to AY 2016-17. The Tribunal also allowed the assessee's ground regarding disallowance under Section 36(1)(vii) based on consistency. The additional ground regarding Section 40(a)(ia) was restored to the CIT(A) for adjudication.

The Tribunal condoned the significant delay in filing the appeal before the CIT(A), relying on judicial precedents that emphasize substantial justice over technicalities and that delay should not be condoned only if it is deliberate. The Tribunal noted that the delay was not intentional and occurred due to reasonable cause.

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing reasonable cause and the ongoing COVID-19 pandemic which was accounted for by the Supreme Court. The Tribunal held that substantial justice should be preferred over technical considerations for non-deliberate delays.

The Tribunal noted the delay and, considering the larger interest of justice, decided to grant the assessee one more opportunity. The issue was remitted back to the CIT(Exemption) for fresh adjudication.

The Tribunal condoned the 13-day delay in filing the appeal, citing sufficient reasons related to personal hardship and administrative processes. It held that the Assessing Officer exceeded the scope of limited scrutiny and that the assessee had sufficient cash in hand from previous savings and withdrawals to explain the cash deposits, including those during the demonetization period.

The Tribunal held that the assessee had sufficiently explained the sundry creditors with confirmations and subsequent payments. The additions for opening stock and opening capital were also deemed uncalled for, considering the assessee's business history and explanations for capital accumulation. The Tribunal accepted the tuition fee payment through banking channels as evidence for the s.80C deduction.

The Tribunal noted that the previous order of the CIT, Exemption, which had cancelled the registration, was set aside by the ITAT for fresh consideration. In light of this, the Tribunal set aside the current impugned order and remanded the matter back to the CIT, Exemption, for fresh adjudication of both the registration and approval applications.

The Tribunal observed that the denial of deduction was primarily because the return indicated the assessee was a Partnership Firm, not due to delay in filing. Therefore, the issue was restored to the Assessing Officer for fresh adjudication, treating the assessee as a Cooperative Housing Society and examining the 80P deduction claim.

The Tribunal held that the closing stock was work-in-progress and not finished goods, as construction was not completed. Therefore, the Assessing Officer erred in invoking Section 23(4)(b) of the Act for notional rent.

The Tribunal held that the order of the CIT(A) was not a speaking order and failed to adjudicate the crucial legal issue regarding the notice under section 143(2). Therefore, the Tribunal decided to set aside the order.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the amendment to Section 200A by the Finance Act, 2015, which empowered the levy of fees under Section 234E while processing TDS statements, was effective from June 1, 2015. Therefore, no such fee could be levied for periods prior to this date due to the absence of an enabling provision.

The Tribunal held that the amendment to Section 200A by the Finance Act, 2015, which empowered the levy of fees under Section 234E while processing TDS statements, was effective from June 1, 2015. Therefore, no such fee could be levied for periods prior to this date due to the absence of an enabling provision.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the CIT(A) erred in enhancing the sale value and suggesting penalty proceedings without issuing a mandatory notice to the assessee. The matter was restored to the Assessing Officer for fresh assessment, allowing the benefit of indexed cost of acquisition and verification of the agricultural land claim.

The Tribunal held that income from transactions with nominal members qualifies for deduction under Section 80P(2)(a)(i) as per the Maharashtra Cooperative Societies Act. It also held that interest income from investments with cooperative and other banks is eligible for deduction under Section 80P(2)(a)(i) and 80P(2)(d).

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal noted that the previous order of the CIT, Exemption, which had cancelled the registration, was set aside by the ITAT for fresh consideration. In light of this, the Tribunal set aside the current impugned order and remanded the matter back to the CIT, Exemption, for fresh adjudication of both the registration and approval applications.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The Tribunal held that the CIT(Exemptions) rejected the application without providing an opportunity for a hearing on the specific issue of the incorrect code. The Tribunal, considering the principle of natural justice, decided to grant the assessee another opportunity to substantiate their claim.

The Tribunal held that the assessee, being a primary credit cooperative society, is eligible for deduction under Section 80P(2) on interest income earned from deposits with cooperative banks, following pronouncements by the jurisdictional High Court and the Supreme Court. The Tribunal set aside the CIT(A)'s order.

The Tribunal noted that the CIT(A) dismissed the appeal ex-parte due to non-compliance despite opportunities. However, considering principles of natural justice, the Tribunal set aside the CIT(A)'s order and remanded the issue back to the Assessing Officer for fresh adjudication.

The Tribunal held that the amendment to Section 200A by the Finance Act, 2015, which empowered the levy of fees under Section 234E while processing TDS statements, was effective from June 1, 2015. Therefore, no such fee could be levied for periods prior to this date due to the absence of an enabling provision.

The Assessing Officer's rectification order resolved the issues raised by the assessee. Consequently, the assessee's authorized representative requested to withdraw the appeal.

The Tribunal condoned the delay in filing the appeal, adopting a justice-oriented approach. Regarding the ex-gratia payment, the Tribunal found that crucial evidence, such as a certificate from the employer and details on how the payment was treated in the company's accounts, was not placed before the lower authorities.

The Tribunal condoned the delay of 199 days in filing the appeal before the CIT(A), citing reasonable cause and a justice-oriented approach. The issues were remitted back to the CIT(A) for denovo adjudication on merits.

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing a liberal and pragmatic approach as per Supreme Court judgments. It also noted that the delay had reasonable cause and was not deliberate. The Tribunal set aside the CIT(A)'s order and remitted the issues back to the Assessing Officer for fresh adjudication on merits.

The Tribunal held that the amendment to section 200A of the Income Tax Act, 1961, which enabled the levy of fees under section 234E, was effective from June 1, 2015. Therefore, no such fee could be levied for defaults committed prior to this date, as there was no enabling provision in section 200A before June 1, 2015.

The tribunal held that the CIT(A) is obliged to decide the appeal on merits and cannot dismiss it for non-prosecution. The CIT(A) failed to consider the grounds raised by the assessee.

The Tribunal held that the compensation paid by the assessee to other parties was a prudent business decision to fulfill contractual obligations and sell shares at a higher price, not a breach of contract. The recipient companies were reputed, declared the compensation, and paid taxes.

The Tribunal restored the issue to the file of the CIT(A)/NFAC, directing them to grant one final opportunity to the assessee to substantiate their case. The assessee is also directed to submit the requisite details without seeking adjournments.

The Tribunal condoned the delay in filing the appeal, citing the principle of substantial justice. It further restored the issue to the CIT(A) to decide the appeal on merits after granting the assessee a reasonable opportunity to present its case.

The Tribunal held that penalty under Section 271AAB could only be levied on the unexplained cash amount of Rs. 58,323, as the larger portion of cash was accepted as regular sales and the excess stock was not properly considered. The penalty on excess stock was deleted.

The Tribunal held that substantial justice should be preferred over technical considerations, especially when the delay is not deliberate. The CIT(A) should have condoned the delay and decided the appeal on merits.

The Tribunal restored the issue to the file of the CIT(Exemption) to decide afresh. This was based on a previous decision in the assessee's own case where a similar rejection of a 12AB application was set aside and restored for fresh adjudication.

The Tribunal held that Section 234E late fees could only be levied for statements processed after June 1, 2015, as the amendment to Section 200A making this possible was prospective. Therefore, the levy in this case, processed prior to that date, was invalid.

The Tribunal held that the assessee should not be considered in default for furnishing inaccurate particulars or concealment of income, as the excess refund was voluntarily repaid with interest before the notice under section 148. The Tribunal followed its previous decisions where similar penalties were deleted under identical circumstances.

The Tribunal held that the assessee should not be considered in default for furnishing inaccurate particulars or concealment of income, as the excess refund was voluntarily repaid with interest before the notice under section 148. The Tribunal followed its previous decisions where similar penalties were deleted under identical circumstances.

The Tribunal held that the assessee should not be considered in default for furnishing inaccurate particulars or concealment of income, as the excess refund was voluntarily repaid with interest before the notice under section 148. The Tribunal followed its previous decisions where similar penalties were deleted under identical circumstances.

The Tribunal noted that the assessee claimed the LTCG of Rs. 2,64,91,594/- was already declared in the return and the addition led to double taxation. The CIT(A) had upheld the addition due to lack of documentation. The Tribunal restored the issue to the CIT(A) to verify the claim after affording the assessee an opportunity to submit necessary documents.

The Tribunal held that the filing of Form No. 10DA is a procedural requirement and its delayed submission does not warrant the denial of an otherwise allowable deduction. Relying on Supreme Court decisions, the Tribunal found that non-compliance with procedural requirements should not result in the denial of deductions.

The Tribunal noted that the CIT(A) dismissed the appeal solely on the ground of delay without condoning it. Citing Supreme Court judgments, the Tribunal held that substantial justice should be preferred over technicalities, and meritorious matters should not be dismissed at the threshold due to non-deliberate delay. Therefore, the appeal should be decided on merit.