ITAT Raipur Judgments — February 2026

The tribunal condoned the 80-day delay, finding no mala fide intent. It set aside the ex-parte order of the Ld. CIT(A)/NFAC and remanded the case back for de novo adjudication on merits, granting the assessee a final opportunity to present their case, emphasizing principles of natural justice.

The tribunal held that the assessee, being a Credit Co-operative Society and not a Credit Co-operative Bank, is outside the purview of Section 80P(4). It is entitled to exemption under Section 80P(2)(a)(i) for interest earned from other co-operative banks, citing previous judgments and the Supreme Court's decision that primary agricultural credit societies are not co-operative banks.

The tribunal condoned the 18-day delay, finding no mala fide intent by the assessee. It remanded the case back to the CIT(A)/NFAC for a fresh adjudication on merits, emphasizing the principles of natural justice and providing a final opportunity to the assessee to present their case.

The tribunal held that primary agricultural credit societies are not cooperative banks under the Banking Regulation Act and are entitled to deduction under Section 80P(2)(a)(i) and Section 80P(2)(d) for interest income earned from deposits with other banks. This interest income is attributable to the business of providing credit facilities to members.

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 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 Consequently, the appeal filed by the assessee was dismissed as withdrawn.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 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, 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 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 the unsigned notice under Section 143(2) was invalid, arbitrary, and void ab initio, as it violated Section 282A(1) of the Act. Consequently, the Assessing Officer lacked valid jurisdiction to complete the assessment under Section 143(3), and thus, the assessment was quashed. The Tribunal relied on previous judgments affirming the mandatory nature of a signed notice.

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 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 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 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 Tribunal held that an unsigned notice under Section 148 is invalid and void ab initio, citing Section 282A(1) which mandates signing of notices, whether in paper or electronic form. The Tribunal distinguished the Department's reliance on Section 282A(2) regarding authentication, stating it does not override the mandatory signing requirement.

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 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 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 tribunal held that the AO's estimated GP addition on unrecorded sales was unsustainable because the books of account were not rejected under Section 145(3) of the Income Tax Act. Without rejecting the books, the AO cannot make additions based on estimation over and above the recorded transactions.

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 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 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 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 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 Tribunal held that prior to June 1, 2015, Section 200A of the Income Tax Act did not have an enabling provision for levying fees under Section 234E during the processing of TDS statements. Therefore, the imposition of the late filing fee for the assessment year 2013-14 was beyond the scope of permissible adjustments under Section 200A at that time.

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 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 prior to June 1, 2015, Section 200A of the Income Tax Act did not have an enabling provision to levy fees under Section 234E during the processing of TDS statements. Therefore, the imposition of the late filing fee for the assessment year 2013-14 was beyond the scope of Section 200A as it stood at the relevant time.

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 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 CIT(A) held that since the sales were not doubted and payments for purchases were made through banking channels, the addition for alleged bogus purchases could not be sustained. The tribunal found that the AO merely relied on the Verification Unit's report without further inquiry into the genuineness of the purchases, despite the assessee providing supporting evidence.

The Tribunal held that the unsigned approval under Section 151 of the Act was violative of Section 282A(1) and therefore invalid. Relying on previous ITAT decisions, it quashed the assessment order, rendering the merits of the case academic.

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 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 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 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 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 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 CIT(A), as an Appeal Unit, was not authorized to decide on the admission of appeals or condonation of delay under the Faceless Appeal Scheme. This power rests with the National Faceless Appeal Centre or Regional Faceless Appeal Centres. Therefore, the rejection of the delay condonation was unjustified.

The tribunal upheld the disallowance of exemption under Section 11. It found that the Board's contract receipts exceeded the statutory limit for activities not considered general public utility, and its activities were commercial, similar to a builder/developer, thus falling outside the scope of charitable purposes under Section 2(15) of the Act.

The tribunal upheld the disallowance of exemption under Section 11, agreeing with the lower authorities that the assessee's activities were commercial and profit-oriented, thus not qualifying as 'general public utility' under Section 2(15) of the Act. The contract receipts exceeded the statutory limit, indicating a non-charitable nature of activities.

The tribunal upheld the disallowance of exemption under Section 11, agreeing that the assessee's activities, including contract receipts from government and other agencies, were commercial and exceeded the monetary limits specified in the proviso to Section 2(15) for charitable organizations engaged in general public utility.

The tribunal upheld the disallowance of exemption under Section 11, agreeing that the Board's activities, including construction for other agencies and sale of properties, had a commercial element and the receipts from these activities exceeded the statutory limit for charitable organizations engaged in general public utility.

The tribunal upheld the disallowance of exemption under Section 11, agreeing that the Board's activities, particularly contract receipts exceeding the statutory limit, were commercial in nature and not solely for general public utility. The CIT(A)'s decision to treat the net surplus as business income was confirmed.

The ITAT upheld the CIT(A)'s decision to estimate the net profit rate at 0.70%. The tribunal found the CIT(A)'s order well-reasoned, as it considered the assessee's submissions, average profitability, and industry performance, and applied the highest net profit rate from the three preceding years.