ITAT Raipur Judgments — February 2026

The Tribunal held that the assessee, being a Credit Co-operative Society and not a Credit Co-operative Bank, is eligible for exemption under Section 80P(2)(a)(i) and 80P(2)(d) on interest income. It also held that the society's role in enabling marketing of agricultural produce by its members qualifies for deduction under Section 80P(2)(a)(iii).

The Tribunal condoned the delay in filing the appeal and, following principles of natural justice and previous judgments, set aside the ex-parte order of the CIT(A)/NFAC. The matter was remanded back for denovo adjudication on merits, with a final opportunity for the assessee to comply.

The Tribunal condoned the delay, citing the welfare nature of tax legislation and the principle of natural justice. The matter was set aside and remanded to the CIT(A)/NFAC for denovo adjudication on merits, providing a final opportunity to the assessee.

The Tribunal held that interest income earned by a cooperative credit society from bank deposits is attributable to its business of providing credit facilities and is therefore eligible for deduction under Section 80P(2)(a)(i) and 80P(2)(d). The assessee is not considered a 'bank' for the purposes of Section 80P(4).

The Income Tax Appellate Tribunal (ITAT) permitted the assessee to withdraw the appeal. Consequently, the appeal filed by the assessee was dismissed as withdrawn.

The ITAT set aside the CIT(A)'s order and remanded the matter back, directing the assessee to explain the 'sufficient cause' for the delay. If satisfied, the CIT(A) should then decide the issue on merits.

The Tribunal, noting the ex-parte dismissal and in adherence to natural justice principles, set aside the CIT(Appeals)'s order and remanded the matter for de novo adjudication. The assessee was granted one final opportunity to comply with the CIT(Appeals)'s notices.

The ITAT, following principles of natural justice and a similar precedent, set aside the ex-parte order of the CIT(Appeals) and remanded the matter for de novo adjudication. The assessee was granted one final opportunity to comply with the hearing notices.

The ITAT, following principles of natural justice and a similar precedent, set aside the ex-parte order of the CIT(Appeals) and remanded the matter for de novo adjudication. The assessee was granted one final opportunity to comply with the hearing notices.

The Tribunal set aside the CIT(A)'s order and remanded the matter to the Assessing Officer for de novo adjudication. This was due to the assessee's claim of not receiving remand notices and the need for proper verification of evidence regarding the source of cash deposits.

The ITAT set aside the ex-parte order of the CIT(A) and remanded the matter back for de novo adjudication, providing one final opportunity to the assessee to comply with the hearing notices, in adherence to natural justice principles.

The tribunal condoned the delay in filing the appeal due to the assessee's severe medical condition and lack of communication from his previous counsel. It set aside the ex-parte order of the CIT(A) and remanded the matter to the Assessing Officer for a de novo adjudication, emphasizing the principles of natural justice and a humanitarian approach.

The Tribunal held that an unsigned notice under Section 143(2) is violative of Section 282A(1) and is therefore invalid, void ab initio. Consequently, the Assessing Officer lacked valid jurisdiction to complete the assessment.

The Tribunal set aside the CIT(A)'s order and remanded the matter to the Assessing Officer for de novo adjudication. This was due to the assessee's claim of not receiving remand notices and the need for proper verification of evidence regarding the source of cash deposits.

The Tribunal condoned the delay in filing the appeal. It held that the unsigned notice under Section 148 was violative of Section 282A(1) of the Act and was therefore invalid, arbitrary, and void ab initio.

The Tribunal condoned the 64-day delay, finding no deliberate misconduct. It set aside the ex-parte order of the CIT(Appeals)/NFAC and remanded the matter for de novo adjudication, granting the assessee a final opportunity to comply with hearing notices.

The tribunal condoned the 367-day delay, acknowledging the circumstances of the Karta's death and the subsequent legal procedures. It set aside the ex-parte order of the CIT(Appeals) and remanded the matter back for de novo adjudication, granting the assessee a final opportunity to present their case on merits.

The ITAT noted the ex-parte dismissal and, in the interest of natural justice, remanded the case back to the CIT(A) for a de novo adjudication. The assessee was granted one final opportunity to comply with hearing notices.

The Tribunal held that the addition was arbitrary and bad in law because the assessee had already included the sales in his return and provided supporting documents. The Revenue failed to dispute the total sales or provide corroborative material to justify a separate addition, leading to a double addition.

The Tribunal held that the Assessing Officer cannot estimate profit and make additions without first rejecting the assessee's books of account, as per established legal principles. The addition made without rejecting the books was deemed illegal and unsustainable.

The ITAT observed that the CIT(Appeals) did not properly adjudicate the 'sufficient cause' for the delay. To ensure natural justice and allow for a full examination of substantive rights, the ITAT set aside the CIT(Appeals) order and remanded the matter back for fresh consideration of the delay and then the merits.

The ITAT condoned the 466-day delay in filing the appeal before itself, finding no malafide intent. However, it upheld the CIT(Appeals)'s decision to dismiss the appeal due to the 1886-day delay, citing gross negligence and lack of sufficient cause on the part of the assessee.

The tribunal set aside the ex-parte orders of the CIT(Appeals)/NFAC and remanded the matters back for de novo adjudication, providing a final opportunity to the assessee to comply with hearing notices, in adherence to principles of natural justice.

The tribunal set aside the ex-parte orders of the CIT(Appeals)/NFAC and remanded the matters back for de novo adjudication, providing a final opportunity to the assessee to comply with hearing notices, in adherence to principles of natural justice.

The ITAT set aside the ex-parte order of the CIT(Appeals)/NFAC and remanded the matter for de novo adjudication, providing the assessee one final opportunity to comply with hearing notices, in adherence to the principles of natural justice.

The ITAT set aside the ex-parte order of the CIT(Appeals)/NFAC and remanded the matter back for de novo adjudication, emphasizing the principles of natural justice and providing the assessee a final opportunity to comply with notices.

The tribunal noted the CIT(A) had decided the appeal on merits, not just for non-compliance. However, in the interest of justice, and with the revenue's reluctant admission, the tribunal set aside the CIT(A)'s order and remanded the case back for a fresh decision after providing the assessee adequate opportunity to be heard.

The tribunal held that since the AO considered the return of income filed by the assessee in response to the Section 148 notice as valid for reassessment, the issuance of a notice under Section 143(2) was mandatory. The tribunal found that the absence of this mandatory notice made the reassessment order arbitrary, bad in law, and void ab initio, and therefore quashed it.

The Tribunal held that prior to June 1, 2015, there was no enabling provision in Section 200A of the Act for levying fees under Section 234E. Therefore, the levy of late fees for AY 2013-14 was unsustainable.

The Tribunal, relying on the Delhi High Court's decision in Pr. CIT Vs. N.C Cables Ltd., held that merely writing 'Approved' without recording satisfaction or reasons makes the approval mechanical and invalid. Consequently, the approval under Section 151 was quashed, rendering all subsequent reassessment proceedings non-est.

The Tribunal held that the rejection of books of account under Section 145(3) is not a mandatory condition for invoking Section 69C. The Tribunal found that the CIT(A)'s deletion was not justified based on the facts.

The Tribunal held that prior to June 1, 2015, there was no enabling provision in Section 200A of the Act for levying fees under Section 234E. Therefore, the levy of late fees for AY 2013-14 was unsustainable.

The Tribunal held that the unsigned approval under Section 151 of the Act violates Section 282A(1), rendering it void ab initio. Consequently, all subsequent proceedings were deemed non-est.

The tribunal held that the CIT(A) is obligated to dispose of an appeal on merits, even in cases of non-prosecution, and cannot dismiss it solely for non-compliance. Citing a Bombay High Court decision, the tribunal set aside the CIT(A)'s order and remanded the case for a fresh decision on merits after providing the assessee with an adequate opportunity to be heard.

The Tribunal held that the assessee had established the identity, creditworthiness, and genuineness of the transactions by providing bank statements, ITRs, and cash books of the shareholders. The AO and CIT(Appeals) failed to conduct proper inquiry or negate the evidence provided, making the addition under Section 68 arbitrary and bad in law. The addition was directed to be deleted.

The Tribunal held that since the CPC had already accepted the tax relief claim of Rs. 1,43,214/-, the Assessing Officer should coordinate with the CPC to ensure the proper credit of this amount to the assessee, provided all legal parameters are met.

The ITAT set aside the ex-parte order of the CIT(Appeals) and remanded the matter back for de novo adjudication, providing the assessee one final opportunity to comply with hearing notices, in adherence to principles of natural justice.

The Tribunal held that the CIT(A) erred in not admitting crucial additional evidence (an affidavit) under Rule 46A(3) of the IT Rules, 1962, which was vital for a just decision. Citing a jurisdictional High Court ruling, the Tribunal remanded the case back to the CIT(A) to admit the additional evidence, obtain a remand report from the AO, and re-adjudicate the matter de novo, ensuring compliance with natural justice principles.

The ITAT, citing High Court precedents, held that the CIT(Appeals) cannot dismiss an appeal solely on the ground of delay without considering the merits. The case was remanded to the CIT(Appeals) to first decide on the condonation of delay and then adjudicate the appeal on merits.

The ITAT set aside the ex-parte order of the CIT(Appeals) and remanded the matter back for de novo adjudication, granting the assessee one final opportunity to comply with hearing notices, in adherence to natural justice principles.

The ITAT condoned the delay in filing the appeal and, noting the ex-parte dismissal by the CIT(A), remanded the case back to the CIT(A) for a de novo adjudication on merits, providing the assessee a final opportunity to comply.

The Tribunal, following the Supreme Court's decision in Ahmedabad Urban Development Authority, held that the matter needs to be examined by the AO to determine if the consideration charged for housing units was significantly above cost plus a nominal mark-up.

The Tribunal held that the case is covered by the Supreme Court's decision in Ahmedabad Urban Development Authority. The matter was remanded to the AO to determine if the consideration charged for units/plots was substantially above cost plus a nominal mark-up.

The ITAT held that the power to decide the admission of an appeal, including condonation of delay, under the Faceless Appeal Scheme lies with the National Faceless Appeal Centre (NFAC) or Regional Faceless Appeal Centres (RFACs), not the Appeal Unit (AU) which the CIT(A) was part of. Therefore, the CIT(A) erred in rejecting the delay condonation application.

The tribunal held that the penalty under Section 271(1)(c) was not sustainable as the assessee had voluntarily disclosed the income and paid taxes, thus not jeopardizing the revenue. The AO failed to provide specific evidence that the disclosure was not voluntary or how inaccurate particulars were furnished, making the penalty arbitrary and bad in law.

The Tribunal condoned the 106-day delay, finding it not deliberate or mala fide, and remanded the case back to the CIT(Appeals) for a de novo adjudication on merits. It emphasized that appellate authorities should not dismiss appeals in limine for non-prosecution or delay.

The Tribunal held that the case is covered by the Supreme Court's decision in Ahmedabad Urban Development Authority. The matter was remanded to the AO to determine if the consideration charged for units/plots was substantially above cost plus a nominal mark-up.

The Tribunal, following the Supreme Court's decision in Ahmedabad Urban Development Authority, held that the matter needs to be examined by the AO to determine if the consideration charged for housing units was substantially above cost plus a nominal mark-up.

The Tribunal held that the case is covered by the Supreme Court's decision in Ahmedabad Urban Development Authority. The matter was remanded to the AO to determine if the consideration charged for units/plots was substantially above cost plus a nominal mark-up.

The ITAT upheld the decision of the CIT(Appeals)/NFAC, stating that the assessee failed to provide sufficient cause or evidence to justify the huge delay and demonstrated negligence. The tribunal emphasized that a 'justice-oriented approach' requires bonafideness and sufficient cause, which were absent in this case, and that condoning such a delay would be unfair to the Revenue.