ITAT Pune Judgments — July 2026

The Tribunal held that the re-assessment order is invalid because the Assessing Officer failed to issue a notice under section 143(2) after the assessee filed a return in response to the notice under section 148, even if the return was filed belatedly. This failure renders the assessment proceedings a nullity.

The Tribunal condoned the delay in filing the appeal and set aside the CIT(A)'s order. The case was remitted back to the CIT(A) for fresh adjudication, granting the assessee one more opportunity to present material evidence and ensuring principles of natural justice.

The Tribunal allowed the assessee's claim for deduction under Section 80P(2)(a)(i). This decision was based on the Tribunal's own prior ruling in the assessee's case for a different assessment year under identical circumstances.

The Tribunal upheld the order of the CIT(A)/NFAC, who had sustained an addition of Rs. 35,36,875/-. The Tribunal found no infirmity in the CIT(A)'s detailed and reasoned order.

The Tribunal held that the reasons recorded for reopening were based on surmises and lacked a live link to tangible material. The AO did not apply his mind to the information received and did not bring any document on record to prove the alleged loan transaction.

The Tribunal held that penalty was not leviable on the VSI contribution as the issue was decided in favour of the assessee by previous Tribunal orders. For the interest on IT refund, it was considered a human error due to non-availability of breakup, not a deliberate concealment.

The Tribunal condoned the delay in filing the appeal before the CIT(A), finding sufficient cause. It set aside the CIT(A)'s order and remitted the issues back to the Assessing Officer for fresh adjudication.

The Tribunal upheld the addition made by the Assessing Officer under section 69A as unexplained cash deposits, noting the assessee's consistent non-compliance at all stages of the assessment and appeal proceedings.

The Tribunal upheld the addition made by the Assessing Officer under section 69A as unexplained cash deposits, noting the assessee's consistent non-compliance at all stages of the assessment and appeal proceedings.

The Tribunal admitted additional evidence, including the cancellation deed and subsequent tax filings, which were not considered by the lower authorities. The Tribunal set aside the CIT(A)'s order and restored the issues to the Assessing Officer for fresh adjudication.

The Tribunal upheld the CIT(A)'s decision, allowing the exemption for dividend income. It was held that the assessee had rightly claimed the exemption as per law, relying on judicial precedents and the fact that SEBI had not taken action against the dividend-paying entity.

The Tribunal held that the estimated income addition should be restricted to 3% of the bank credits, considering the assessee's role as a commission agent and the nominal profit margin. The grounds related to the validity of the reassessment notice were withdrawn.

The Tribunal upheld the addition made by the Assessing Officer under section 69A as unexplained cash deposits, noting the assessee's consistent non-compliance at all stages of the assessment and appeal proceedings.

The Tribunal held that the activities of the assessee fall within the ambit of 'education' under Section 2(15) and are not hit by the proviso thereto. It noted that the assessee had incurred deficits in several years, indicating that activities were not profit-driven, aligning with the ratio in Ahmedabad Urban Development Authority. The Tribunal found that the assessee is engaged in skill development training, a flagship project of the Government of India, and distinguished the cases relied upon by the revenue. In Mahatma Gandhi Charitable Society, the assessee executed contracts for cleaning, which was not a public utility service. In Annadan Trust, the assessee was an implementing agency for government schemes funded by the state. The Tribunal concluded that the Pr.CIT was not justified in cancelling the registration. Consequently, the registration granted earlier was directed to be restored. The grounds raised by the assessee were partly allowed.

The Tribunal found that the CIT(A) had erred in sustaining the addition on under-valuation of closing Work-in-Progress (WIP) without fully appreciating the evidence. The Tribunal decided to provide the assessee with another opportunity to present their case.

The Tribunal condoned the delay of 1130 days in filing the appeals, finding the assessee's explanation to be bonafide and genuine, supported by the principles laid down by the Hon'ble Apex Court in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy & Others. The Tribunal noted that the CIT(A) had dismissed the appeals for non-prosecution without adjudicating on merits, and the assessee had not received notices due to an incorrect email address. In the larger interest of justice, the Tribunal restored all issues for the impugned assessment years to the file of the CIT(A)/NFAC for necessary adjudication. The CIT(A)/NFAC was directed to provide a reasonable opportunity of hearing and pass a speaking order. The assessee was directed to update contact details and remain vigilant. The impugned order of the CIT(A)/NFAC was set aside.

The Tribunal condoned the delay in filing appeals before both the ITAT and the CIT(A), finding the reasons for delay to be genuine and not intentional. The appeals were remitted back to the CIT(A) for fresh adjudication on merits.

The Tribunal held that weighted deduction under Section 35(2AB) cannot be allowed without Form No. 3CL. However, it allowed the revenue expenditure to be examined under Section 37(1) and depreciation on capital expenditure under Section 32.

The Tribunal condoned the delay in filing the appeal before the CIT(A) and noted that the incorrect interest claim appeared to be an unintentional clerical mistake. The penalty was levied incorrectly on under-reported income instead of tax payable.

The Tribunal condoned the delay in filing appeals before both the ITAT and the CIT(A), considering the reasons provided were not intentional. The matters were remitted back to the CIT(A) for fresh adjudication.

The Tribunal condoned the delay in filing appeals before both the ITAT and the CIT(A), finding the reasons for delay to be genuine and not intentional. The appeals were remitted back to the CIT(A) for fresh adjudication on merits.

The Tribunal condoned the delay in filing appeals before both the ITAT and the CIT(A), finding the reasons for delay to be genuine and not intentional. The appeals were remitted back to the CIT(A) for fresh adjudication on merits.

The Tribunal set aside the CIT(A)'s order and remitted the issue back to the Assessing Officer for fresh adjudication. The assessee was granted one more opportunity to present evidence and cooperate with the proceedings.

The Tribunal condoned the delay in filing the appeal before the CIT(A), citing sufficient cause and the need for substantial justice. The order of the CIT(A) was set aside, and the case was remitted back for fresh adjudication.

The Tribunal condoned the delay of 1130 days in filing the appeals, finding the assessee's explanation to be bonafide and genuine, supported by the principles laid down by the Hon'ble Apex Court in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy & Others. The Tribunal noted that the CIT(A) had dismissed the appeals for non-prosecution without adjudicating on merits, and the assessee had not received notices due to an incorrect email address. In the larger interest of justice, the Tribunal restored all issues for the impugned assessment years to the file of the CIT(A)/NFAC for necessary adjudication. The CIT(A)/NFAC was directed to provide a reasonable opportunity of hearing and pass a speaking order. The assessee was directed to update contact details and remain vigilant. The impugned order of the CIT(A)/NFAC was set aside.

The Tribunal condoned the delay of 1130 days in filing the appeals, finding the assessee's explanation to be bonafide and genuine, supported by the principles laid down by the Hon'ble Apex Court in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy & Others. The Tribunal noted that the CIT(A) had dismissed the appeals for non-prosecution without adjudicating on merits, and the assessee had not received notices due to an incorrect email address. In the larger interest of justice, the Tribunal restored all issues for the impugned assessment years to the file of the CIT(A)/NFAC for necessary adjudication. The CIT(A)/NFAC was directed to provide a reasonable opportunity of hearing and pass a speaking order. The assessee was directed to update contact details and remain vigilant. The impugned order of the CIT(A)/NFAC was set aside.

The Tribunal condoned the delay of 1130 days in filing the appeals, finding the assessee's explanation to be bonafide and genuine, supported by the principles laid down by the Hon'ble Apex Court in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy & Others. The Tribunal noted that the CIT(A) had dismissed the appeals for non-prosecution without adjudicating on merits, and the assessee had not received notices due to an incorrect email address. In the larger interest of justice, the Tribunal restored all issues for the impugned assessment years to the file of the CIT(A)/NFAC for necessary adjudication. The CIT(A)/NFAC was directed to provide a reasonable opportunity of hearing and pass a speaking order. The assessee was directed to update contact details and remain vigilant. The impugned order of the CIT(A)/NFAC was set aside.

The Tribunal condoned the delay of 1130 days in filing the appeals, finding the assessee's explanation to be bonafide and genuine, supported by the principles laid down by the Hon'ble Apex Court in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy & Others. The Tribunal noted that the CIT(A) had dismissed the appeals for non-prosecution without adjudicating on merits, and the assessee had not received notices due to an incorrect email address. In the larger interest of justice, the Tribunal restored all issues for the impugned assessment years to the file of the CIT(A)/NFAC for necessary adjudication. The CIT(A)/NFAC was directed to provide a reasonable opportunity of hearing and pass a speaking order. The assessee was directed to update contact details and remain vigilant. The impugned order of the CIT(A)/NFAC was set aside.

The Tribunal condoned the delay of 1130 days in filing the appeals, finding the assessee's explanation to be bonafide and genuine, supported by the principles laid down by the Hon'ble Apex Court in Esha Bhattacharjee v. Managing Committee of Raghunathpur Nafar Academy & Others. The Tribunal noted that the CIT(A) had dismissed the appeals for non-prosecution without adjudicating on merits, and the assessee had not received notices due to an incorrect email address. In the larger interest of justice, the Tribunal restored all issues for the impugned assessment years to the file of the CIT(A)/NFAC for necessary adjudication. The CIT(A)/NFAC was directed to provide a reasonable opportunity of hearing and pass a speaking order. The assessee was directed to update contact details and remain vigilant. The impugned order of the CIT(A)/NFAC was set aside.

The Tribunal, following Supreme Court and coordinate bench decisions, held that primary credit cooperative societies are eligible for deduction under Section 80P(2)(d) on interest income earned from other cooperative banks. Therefore, the denial of the claim was set aside.

The Tribunal, following Supreme Court and coordinate bench decisions, held that primary credit cooperative societies are eligible for deduction under Section 80P(2)(d) on interest income earned from other cooperative banks. Therefore, the denial of the claim was set aside.

The Tribunal condoned the delay in filing the appeal and set aside the CIT(A)'s order. The issue was remitted back to the CIT(A) for fresh adjudication, providing the assessee with an adequate opportunity to be heard.

The Tribunal upheld the rejection of books of account but reduced the estimated Gross Profit rate to 2%, considering the historical GP rates of the assessee and its sister concerns. This resulted in a sustained addition of Rs. 27,68,202/-.

The Tribunal held that the failure to grant a personal hearing to the assessee, despite a request, vitiated the assessment order. Following judicial precedents, the assessment order was set aside for de-novo adjudication with an opportunity for personal hearing.

The Tribunal found that the CIT(A) accepted additional evidence without giving the AO a fair opportunity to examine them, violating Rule 46A of the IT Rules. Therefore, the order of the CIT(A) was set aside.

The Tribunal held that the notice for reassessment was indeed barred by limitation, following the Supreme Court's judgment in Union of India Vs. Rajeev Bansal. Consequently, the reassessment proceedings were quashed.

The Tribunal found that the CIT(A) had erred in sustaining the addition on under-valuation of closing Work-in-Progress (WIP) without fully appreciating the evidence. The Tribunal decided to provide the assessee with another opportunity to present their case.