ITAT Pune Judgments — July 2026

The Tribunal restored the matter to the CIT(A) to condone the delay and decide the appeal on merits. The assessee was directed to cooperate and produce evidence without seeking adjournments.

The Tribunal held that the Ld. CIT(A) erred in dismissing the appeals solely on the ground of delay without condoning it. Citing decisions of the Hon'ble Supreme Court in Collector, Land Acquisition vs. Mst. Katiji & Ors., Inder Singh Vs. The State of Madhya Pradesh, and Vidya Shankar Jaiswal vs. ITO, the Tribunal emphasized a justice-oriented and liberal approach towards condoning delays, especially when substantial justice is at stake. Refusing to condone delay can lead to meritorious matters being thrown out. The Tribunal found that the assessee's explanation for the delay, though not ideal, was due to financial distress. Therefore, the Tribunal restored all the appeals to the file of the Ld. CIT(A) with a direction to condone the delay and decide the issues on merit after giving due opportunity of hearing to the assessees. The assessees were directed to make submissions without seeking adjournments. The grounds raised by the assessees were allowed for statistical purposes.

The Tribunal held that the Ld. CIT(A) erred in dismissing the appeals solely on the ground of delay without condoning it. Citing decisions of the Hon'ble Supreme Court in Collector, Land Acquisition vs. Mst. Katiji & Ors., Inder Singh Vs. The State of Madhya Pradesh, and Vidya Shankar Jaiswal vs. ITO, the Tribunal emphasized a justice-oriented and liberal approach towards condoning delays, especially when substantial justice is at stake. Refusing to condone delay can lead to meritorious matters being thrown out. The Tribunal found that the assessee's explanation for the delay, though not ideal, was due to financial distress. Therefore, the Tribunal restored all the appeals to the file of the Ld. CIT(A) with a direction to condone the delay and decide the issues on merit after giving due opportunity of hearing to the assessees. The assessees were directed to make submissions without seeking adjournments. The grounds raised by the assessees were allowed for statistical purposes.

The Tribunal, following Supreme Court judgments, held that substantial justice should be preferred over technical considerations. It directed the CIT(A) to condone the delay and decide the appeals on merits.

The Tribunal held that the Ld. CIT(A) erred in dismissing the appeals solely on the ground of delay without condoning it. Citing decisions of the Hon'ble Supreme Court in Collector, Land Acquisition vs. Mst. Katiji & Ors., Inder Singh Vs. The State of Madhya Pradesh, and Vidya Shankar Jaiswal vs. ITO, the Tribunal emphasized a justice-oriented and liberal approach towards condoning delays, especially when substantial justice is at stake. Refusing to condone delay can lead to meritorious matters being thrown out. The Tribunal found that the assessee's explanation for the delay, though not ideal, was due to financial distress. Therefore, the Tribunal restored all the appeals to the file of the Ld. CIT(A) with a direction to condone the delay and decide the issues on merit after giving due opportunity of hearing to the assessees. The assessees were directed to make submissions without seeking adjournments. The grounds raised by the assessees were allowed for statistical purposes.

The Tribunal held that the Ld. CIT(A) erred in dismissing the appeals solely on the ground of delay without condoning it. Citing decisions of the Hon'ble Supreme Court in Collector, Land Acquisition vs. Mst. Katiji & Ors., Inder Singh Vs. The State of Madhya Pradesh, and Vidya Shankar Jaiswal vs. ITO, the Tribunal emphasized a justice-oriented and liberal approach towards condoning delays, especially when substantial justice is at stake. Refusing to condone delay can lead to meritorious matters being thrown out. The Tribunal found that the assessee's explanation for the delay, though not ideal, was due to financial distress. Therefore, the Tribunal restored all the appeals to the file of the Ld. CIT(A) with a direction to condone the delay and decide the issues on merit after giving due opportunity of hearing to the assessees. The assessees were directed to make submissions without seeking adjournments. The grounds raised by the assessees were allowed for statistical purposes.

The Tribunal held that the Ld. CIT(A) erred in dismissing the appeals solely on the ground of delay without condoning it. Citing decisions of the Hon'ble Supreme Court in Collector, Land Acquisition vs. Mst. Katiji & Ors., Inder Singh Vs. The State of Madhya Pradesh, and Vidya Shankar Jaiswal vs. ITO, the Tribunal emphasized a justice-oriented and liberal approach towards condoning delays, especially when substantial justice is at stake. Refusing to condone delay can lead to meritorious matters being thrown out. The Tribunal found that the assessee's explanation for the delay, though not ideal, was due to financial distress. Therefore, the Tribunal restored all the appeals to the file of the Ld. CIT(A) with a direction to condone the delay and decide the issues on merit after giving due opportunity of hearing to the assessees. The assessees were directed to make submissions without seeking adjournments. The grounds raised by the assessees were allowed for statistical purposes.

The Tribunal, following Supreme Court judgments, held that substantial justice should be preferred over technical considerations. It directed the CIT(A) to condone the delay and decide the appeals on merits.

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing medical reasons and the principles of substantial justice. The case was remitted back to the CIT(A) for adjudication on merits, providing the assessee with an opportunity to present evidence.

The Tribunal held that the delay in filing Form 10 was condoned by the CIT(Exemption) and directed the AO to grant the benefit of exemption under Section 11.

The Tribunal held that there was a sufficient cause for the delay in filing the appeal before the CIT(A) and that a liberal approach should be adopted. The order of the CIT(A) was set aside, and the issue was remitted back for fresh adjudication.

The Tribunal found that the CIT(A) dismissed the appeal ex-parte without considering potential reasons for non-appearance. Upholding principles of natural justice, the Tribunal decided to grant the assessee one more opportunity to present their case.

The Tribunal held that the notice under Section 148 dated April 6, 2022, for AY 2015-16 was bad in law, following the Supreme Court's decision in Deepak Steel & Power Ltd. and other High Court and ITAT rulings.

The Tribunal set aside the CIT's order and restored the matter to the CIT's file. The CIT was directed to decide the application afresh after providing a reasonable opportunity of hearing to the assessee.

The Tribunal held that the AO's addition was not based on any specific seized documents or evidence. The Tribunal also found that the CIT(A) erred in not deciding the appeal on merits despite the assessee providing necessary facts.

The Tribunal held that the notice under section 148 and the consequential reassessment order were bad in law. This was because the notice was issued after the prescribed time limit and the alleged escapement of income did not meet the threshold for issuing notice beyond three years.

The Tribunal held that since the audit report was filed before the processing of the return, the assessee cannot be denied the deduction under Section 80IAC. The order of the CIT(A) was set aside.

The Tribunal proceeded ex-parte due to the assessee's non-appearance and non-compliance. The appeal was decided without the assessee's participation.

The Tribunal held that the CIT(A) is obligated to decide appeals on merits and does not have the power to dismiss an appeal for non-prosecution. The CIT(A) must provide an opportunity for hearing and adjudicate the grounds of appeal.

The Tribunal held that the approval for issuing the notice under Section 148A(d) was not in accordance with Section 151 of the Act, as it was obtained from the PCIT when the case fell beyond three years from the end of the assessment year. Following the jurisdictional High Court's decision, the Tribunal quashed the reassessment proceedings.

The Tribunal restored the penalty issue to the file of the CIT(A) for fresh adjudication, providing the assessee with another opportunity to be heard and present information. The grounds of appeal were allowed for statistical purposes.

The Tribunal set aside the CIT(A)'s order and remitted the issues back to the CIT(A) for fresh adjudication on merits, providing one more opportunity to the assessee. This was done to uphold the principles of natural justice.

The Tribunal set aside the CIT(A)'s order and remitted the issue back for fresh adjudication, emphasizing the need for an adequate opportunity of hearing and adherence to principles of natural justice.

The Tribunal set aside the CIT(A)'s order and restored the issue to the Assessing Officer. The AO is directed to adjudicate afresh after considering the outcome of the condonation application under Section 119(2)(b) and providing the assessee with adequate opportunity.

The Tribunal held that on identical facts, the ITAT had previously allowed the assessee's appeal for earlier assessment years. Following these precedents, the Tribunal directed the Assessing Officer to delete the addition made.

The Tribunal found that the CIT(A) had not provided the assessee with an adequate opportunity to present submissions on the remand report. Therefore, the Tribunal set aside the CIT(A)'s order and remitted the issue back to the Assessing Officer for fresh adjudication.

The Tribunal held that the CIT(Exemption) rejected the application on hyper-technical grounds without properly examining the documents submitted by the assessee. The objects and activities of the trust were found to be charitable in nature.

The Tribunal noted the assessee's failure to appear before the CIT(A) despite multiple opportunities, leading to the dismissal of the appeal. However, considering the assessee's plea for an opportunity to present his case, the Tribunal restored the issue to the CIT(A) for a final opportunity.

The Tribunal upheld the CIT(A)'s decision, stating that an appeal cannot be filed against a recovery notice as it is not an appealable order under Section 246A of the Income Tax Act. The grounds related to the levy of late fees were also dismissed as they did not emanate from the CIT(A)'s order.

The ITAT found that the CIT(A) violated Rule 46A of the Income Tax Rules by admitting additional evidence without recording reasons and without providing an opportunity to the Assessing Officer to rebut the submissions. Therefore, the order of the CIT(A) was set aside for de-novo adjudication.

The Tribunal held that interest income earned by a cooperative credit society from its investments in other cooperative banks is eligible for deduction under Section 80P(2)(d). The disallowance by the lower authorities was set aside.

The Tribunal set aside the CIT(A)'s order on the disputed issues and restored them to the Assessing Officer for fresh adjudication. The assessee was granted an opportunity to present information and be heard.

The Tribunal held that the CPC, under Section 143(1), has limited powers to make adjustments and cannot disallow exemption claims when the assessee has valid registration. The denial of exemption by the CPC was found to be outside the purview of Section 143(1).

The Tribunal held that Section 167B of the Income Tax Act, which prescribes the MMR, is not applicable to registered societies like the assessee where members' shares are not indeterminate. The Tribunal directed the Assessing Officer to apply normal tax rates.

The Tribunal held that since the audit report in Form 10CCB was filed before the processing of the return, the assessee cannot be denied the deduction under Section 80IB(10). The order of the CIT(A) was set aside.

The Tribunal held that interest income earned by a cooperative credit society from its investments in other cooperative banks is eligible for deduction under Section 80P(2)(d). The disallowance by the lower authorities was set aside.

The Tribunal noted the assessee's failure to appear before the CIT(A) despite multiple opportunities, leading to the dismissal of the appeal. However, considering the assessee's plea for an opportunity to present his case, the Tribunal restored the issue to the CIT(A) for a final opportunity.

The Tribunal noted the assessee's failure to appear before the CIT(A) despite multiple opportunities, leading to the dismissal of the appeal. However, considering the assessee's plea for an opportunity to present his case, the Tribunal restored the issue to the CIT(A) for a final opportunity.

The Tribunal noted the assessee's failure to appear before the CIT(A) despite multiple opportunities, leading to the dismissal of the appeal. However, considering the assessee's plea for an opportunity to present his case, the Tribunal restored the issue to the CIT(A) for a final opportunity.

The Tribunal upheld the CIT(A)'s decision, stating that an appeal cannot be filed against a recovery notice as it is not an appealable order under Section 246A of the Income Tax Act. The grounds related to the levy of late fees were also dismissed as they did not emanate from the CIT(A)'s order.

The Tribunal set aside the assessment order and remanded the case back to the AO for fresh adjudication solely on the applicability of Section 50C. The AO is directed to obtain a proper DVO report and provide it to the assessee.

The Tribunal set aside the ex-parte order of the CIT(A) and restored the matter for fresh adjudication. The assessee was directed to appear and present its case without further adjournments.

The Tribunal held that the AO failed to verify the registered purchase documents before issuing notices, which would have revealed the assessee's actual share in the property. The Tribunal also noted that the AO disregarded CBDT circulars mandating verification of ITBA portal data and relied on a Bombay High Court judgment.

The Tribunal found no infirmity in the CIT(Exemption)'s order, as the assessee had indeed filed the application under the incorrect clause without possessing the necessary regular approval.

The Tribunal set aside the ex-parte order of the CIT(A) and restored the matter for fresh adjudication. The assessee was directed to appear and present its case without further adjournments.

The Tribunal held that the CIT(A) cannot dismiss an appeal for non-compliance or non-prosecution and must decide the appeal on merits. The Tribunal condoned the delay in filing the appeals before it.

The Tribunal held that leave encashment for the period of service in the Department of Telecommunication (Central Government) is fully exempt, and for the period in BSNL (PSU), it is exempt up to Rs. 3,00,000. The addition made by the CPC was directed to be deleted.

The Tribunal held that Section 249(4) of the Act, which requires payment of tax before filing an appeal, should be liberally construed to uphold the assessee's right to appeal. The Ld. CIT(A) erred in dismissing the appeal in limine on this ground.

The Tribunal held that the CIT(A) cannot dismiss an appeal for non-compliance or non-prosecution and must decide the appeal on merits. The Tribunal condoned the delay in filing the appeals before it.

The Tribunal held that the CIT(A) erred in admitting additional evidence without providing an opportunity to the AO. Regarding the Section 80P deduction, the Tribunal relied on Supreme Court and High Court judgments to hold that interest income earned by a cooperative credit society from deposits is eligible for deduction.