ITAT Raipur Judgments — January 2026

The ITAT, emphasizing principles of natural justice, set aside the ex-parte orders of the CIT(Appeals)/NFAC and remanded the cases back for de novo adjudication. The assessee was granted one final opportunity to present their case on merits.

The Tribunal, following the principle of natural justice and consistency, set aside the CIT(Appeals) order and remanded the matter for de novo adjudication, granting the assessee one final opportunity to present their case on merits.

The ITAT, noting the ex-parte order by the CIT(Appeals) and the principle of natural justice, decided to remand the case back to the CIT(Appeals) for de novo adjudication, granting the assessee one final opportunity to present their case on merits.

The Tribunal condoned the delay of 219 days, adopting a liberal and justice-oriented approach. It set aside the ex-parte orders of the CIT(Appeals)/NFAC and remanded the matters for de novo adjudication, granting the assessee a final opportunity to present its case on merits.

The tribunal held that the assessee was deprived of a reasonable opportunity to furnish documents due to the short notice period. It ruled that the documents submitted to the CIT(Appeals) should not be treated as additional evidence and remanded the case to the Assessing Officer for a fresh adjudication, considering all submitted evidence.

The ITAT, emphasizing principles of natural justice, set aside the ex-parte orders of the CIT(Appeals)/NFAC and remanded the cases back for de novo adjudication. The assessee was granted one final opportunity to present their case on merits.

The ITAT held that the CIT(A) is obligated to dispose of an appeal on its merits and cannot dismiss it for non-prosecution. The tribunal set aside the CIT(A)'s order and remitted the matter back for a fresh decision on merits after providing the assessee an adequate opportunity to be heard.

The tribunal condoned the delay of 219 days, adopting a liberal and justice-oriented approach. It set aside the ex-parte orders of the CIT(Appeals)/NFAC and remanded the matters for de novo adjudication, granting the assessee a final opportunity to present its case on merits.

The tribunal found no evidence of the alleged prior adjudication order from March 7, 2024. Consequently, it remanded the case back to the CIT(A) for a fresh adjudication, emphasizing compliance with natural justice principles.

The tribunal held that the reopening of assessment was invalid because the Income Tax Department failed to provide the assessee with the information/materials that formed the 'reasons to believe' for initiating the reassessment proceedings. This omission violated the principles of natural justice and rendered the entire proceedings void ab initio.

The Tribunal held that the estimated addition of commission income was unsustainable because the Revenue failed to reject the books of account under Section 145(3) and did not frame the assessment under Section 144 of the Act. The Tribunal emphasized that rejection of books of account is a prerequisite for making a best judgment assessment.

The Tribunal held that the estimated addition of commission income was unsustainable because the Revenue failed to reject the books of account under Section 145(3) of the Act and did not frame the assessment under Section 144 of the Act. The Tribunal relied on various High Court decisions emphasizing that rejection of books is a prerequisite for best judgment assessment.

The tribunal noted that the CIT(A) dismissed the appeals without admitting them due to non-payment of admitted taxes and the absence of an application for exemption under Section 249(4). The tribunal did not provide a final decision on the merits of the case, as the provided text ends before the tribunal's full ruling.

The tribunal noted that the CIT(A) dismissed the appeals without admitting them due to non-payment of admitted taxes and the absence of an application for exemption under Section 249(4). The tribunal did not provide a decision on the merits of the addition but focused on the procedural dismissal by the CIT(A).

The Tribunal, relying on High Court and Supreme Court decisions, held that for AY 2015-16, all Section 148 notices issued on or after April 1, 2021, must be dropped. Since the notices in this case were issued after this date, the reassessment proceedings were invalid and quashed.

The Tribunal upheld the CIT(A)'s decision, ruling that the reassessment notices issued for AY 2015-16 on or after April 1, 2021, were invalid. This was based on the Revenue's concession before the Supreme Court in Union of India v. Rajeev Bansal and subsequent High Court judgments, which stated such notices must be dropped as they do not fall within the period prescribed under TOLA.

The Tribunal condoned the delay in filing the appeal, citing substantial justice. It then ruled that the reassessment proceedings were invalid because the approval for the Section 148 notice, issued more than three years after the relevant assessment year, was granted by the PCIT instead of the Principal Chief Commissioner or Chief Commissioner as mandated by Section 151(ii) of the Act.