ITAT Rajkot Judgments — January 2026

The ITAT condoned the delay, finding sufficient cause due to the previous consultant's error. It then set aside the CIT(A)'s ex-parte order and remitted the matter back to the Assessing Officer for a fresh adjudication on merits, ensuring the assessee is given a reasonable opportunity of hearing.

The ITAT found that the assessee had submitted sufficient evidence for a cost of improvement of Rs. 5,00,000. Therefore, the tribunal directed the Assessing Officer to further reduce the addition by Rs. 5,00,000, bringing the final addition to Rs. 3,45,360.

The tribunal, with no objection from the Revenue, restored the matter to the Assessing Officer. The AO was directed to admit the new evidence, correct the error, and pass a speaking order after giving the assessee an opportunity to be heard.

The ITAT found the assessee's explanation of residing in a small village and lacking technical awareness to be a sufficient cause for the delay. Consequently, the tribunal condoned the delay and remitted the matter back to the Ld. CIT(A) for fresh adjudication on merits.

The Tribunal found that the assessee had provided substantial documentation for the cash deposits and loans, but some documents were self-serving. Therefore, the entire additions were not sustained, and a profit element was to be taxed.

The tribunal set aside the CIT(A)'s ex-parte order and remitted the matter back to the Assessing Officer for fresh adjudication. It was held that the assessee was not given a sufficient opportunity to be heard, violating principles of natural justice, and the Assessing Officer must pass a speaking order after hearing the assessee.

The tribunal found that the CIT(A)'s order indeed did not pertain to the correct assessee or assessment year, being a copy-paste of another assessee's order. The tribunal cancelled the erroneous CIT(A) order and remitted the matter back to the CIT(A) to pass a fresh order considering the correct facts and grounds of appeal of the assessee.

The Tribunal noted that similar appeals related to 'Angadiya Shroff Business' had been remitted back to the Assessing Officer. Lacking necessary facts to adjudicate, the Tribunal set aside the CIT(A)'s order and remitted all appeals back to the Assessing Officer for fresh adjudication.

The Tribunal noted that similar appeals related to 'Angadiya Shroff Business' had been remitted back to the Assessing Officer. Lacking necessary facts to adjudicate, the Tribunal set aside the CIT(A)'s order and remitted all appeals back to the Assessing Officer for fresh adjudication.

The Tribunal noted that similar appeals related to 'Angadiya Shroff Business' had been remitted back to the Assessing Officer. Lacking necessary facts to adjudicate, the Tribunal set aside the CIT(A)'s order and remitted all appeals back to the Assessing Officer for fresh adjudication.

The Tribunal held that the penalty notice issued under Section 271(1)(c) was vague and defective as it did not clearly specify whether the penalty was for concealment of income or furnishing inaccurate particulars. Relying on High Court judgments, the Tribunal concluded that such a defective notice vitiates the penalty proceedings and deleted the penalty.

The tribunal held that the assessee was not given sufficient opportunity to be heard, violating principles of natural justice. It set aside the CIT(A)'s orders and remitted the matter back to the Assessing Officer for fresh adjudication, imposing a cost of Rs. 3,000 on the assessee for negligence. The delays in filing appeals were also condoned.

The tribunal noted that the CIT(A)'s order was ex-parte and non-speaking, violating principles of natural justice. It remitted the matter back to the CIT(A) for fresh adjudication, directing that the assessee be given a sufficient opportunity to be heard and a speaking order be passed on merits.

The tribunal noted that the CIT(A)'s order was ex-parte and non-speaking, violating principles of natural justice. It restored the matter back to the CIT(A) for fresh adjudication, directing that the assessee be given a sufficient opportunity of being heard and a speaking order be passed on merits.

The tribunal noted that the CIT(A)'s order was ex-parte and non-speaking, violating principles of natural justice. It restored the matter to the Assessing Officer for de novo adjudication, directing that the assessee be given sufficient opportunity to present evidence and be heard.

The tribunal held that the assessee was not given sufficient opportunity to be heard, violating principles of natural justice. It set aside the CIT(A)'s orders and remitted the matter back to the Assessing Officer for fresh adjudication, imposing a cost of Rs. 3,000 on the assessee for negligence. The delays in filing appeals were also condoned.

The tribunal condoned the 57-day delay, finding sufficient cause due to the assessee's death and the resulting family uncertainty. It also set aside the ex-parte order of the CIT(A) and remitted the matter back for de novo adjudication, emphasizing the violation of natural justice as the assessee was not given a proper opportunity to be heard.

The tribunal noted that the assessee was not given sufficient opportunity of being heard by the CIT(A), violating principles of natural justice. Therefore, the matter was restored to the CIT(A) for fresh adjudication on merits after providing the assessee a proper opportunity to be heard.

The tribunal held that the assessee was not given sufficient opportunity to be heard, violating principles of natural justice. It set aside the CIT(A)'s orders and remitted the matter back to the Assessing Officer for fresh adjudication, imposing a cost of Rs. 3,000 on the assessee for negligence. The delays in filing appeals were also condoned.

The tribunal noted that the CIT(A)'s order was ex-parte and non-speaking, violating principles of natural justice. It restored the matter to the CIT(A) for fresh adjudication after affording the assessee a sufficient opportunity of being heard, imposing a cost of Rs. 1,000 on the assessee for non-compliance.

The tribunal held that the assessee was not given sufficient opportunity of being heard, violating principles of natural justice, as the CIT(A) order was ex-parte and non-speaking. The matter was remitted back to the Assessing Officer for fresh adjudication after imposing a cost of Rs. 3,000 on the assessee for negligence.

The tribunal noted that the CIT(A)'s order was ex-parte and non-speaking, violating principles of natural justice. It restored the matter to the CIT(A) for de novo adjudication, directing a speaking order after providing the assessee sufficient opportunity to be heard and present evidence.

The tribunal held that the assessee was not given sufficient opportunity of being heard, violating principles of natural justice, as the CIT(A) order was ex-parte and non-speaking. The matter was remitted back to the Assessing Officer for fresh adjudication after imposing a cost of Rs. 3,000 on the assessee for negligence.

The tribunal held that the Assessing Officer erred by sending notices to the assessee's husband's email ID instead of her own registered email ID. Since the law requires things to be done in a specific manner, and the assessee had a sufficient cause (unawareness due to incorrect notice delivery and husband's illness), the penalty was deleted.

The Tribunal noted that agricultural university data might not be fully applicable due to varying conditions and that some of the assessee's documents were self-serving. Considering the smallness of the amount and the agreement of both parties, the Tribunal directed an ad-hoc addition of Rs. 50,000.

The ITAT acknowledged that agricultural expenses were overlooked in the original return and that the assessee had consistently shown agricultural income. While noting some self-serving evidence, the Tribunal allowed a partial relief by estimating a net agricultural income and making an ad-hoc addition of 10% on this amount, directing the AO to add Rs. 2,16,809.

The tribunal held that the assessee was not given sufficient opportunity of being heard, violating principles of natural justice, as the CIT(A) order was ex-parte and non-speaking. The matter was remitted back to the Assessing Officer for fresh adjudication after imposing a cost of Rs. 3,000 on the assessee for negligence.

The ITAT remanded the case back to the Assessing Officer to verify if the assessee had actually paid the taxes under the VSVS. If not, the AO was directed to frame a fresh assessment order on merits after giving the assessee an opportunity to submit details and documents.

The tribunal noted that the assessee's appeal was a duplication of a previously adjudicated matter. Given the prior adjudication and the assessee's request for withdrawal, the tribunal dismissed the current appeal as withdrawn.

The ITAT noted procedural lapses by the AO, including not providing the assessee with a copy of the third-party statement or allowing cross-examination. Considering the smallness of the amount and the agreement of both parties for an estimated addition, the Tribunal directed the AO to make an ad-hoc disallowance of 30% of Rs. 80,000 (i.e., Rs. 24,000) as the profit element of the 'on-money'.

The tribunal noted that the CIT(A)'s order was ex-parte and non-speaking, violating principles of natural justice. It restored the matter to the CIT(A) for fresh adjudication after affording the assessee a sufficient opportunity of being heard, imposing a cost of Rs. 1,000 on the assessee for non-compliance.

The Tribunal found no direct evidence linking the assessee to the alleged scam and noted the donation was made through proper banking channels to a registered political party. However, to address revenue leakage and considering the small amount, an estimated addition of 10% of the disallowed amount (Rs. 40,000) was made to the assessee's income.

The Tribunal held that the reassessment proceedings were invalid because the notices were issued by the Jurisdictional Assessing Officer (JAO) manually, instead of through the mandatory faceless mechanism as per the Faceless Reassessment Scheme, 2022. Consequently, the reassessment order was quashed.

The Tribunal held that the AO's order was neither erroneous nor prejudicial to the interest of the revenue. The issues raised by the PCIT regarding disallowance under section 14A and section 36(1)(iii) were not sustainable based on the facts and legal precedents.

The ITAT condoned the 165-day delay in filing the appeal before the CIT(A), finding it was not deliberate or due to negligence. It set aside the CIT(A)'s order and remitted the matter back to the AO for fresh adjudication on merits, granting the assessee an opportunity to present their case.

The Tribunal noted that the assessee did not adequately explain the source of the cash deposit and that the flat booking details and builder's confirmation were missing. Consequently, the Tribunal set aside the case back to the AO for proper adjudication.

The tribunal condoned the 25-day delay in filing the appeal, finding sufficient cause due to the lack of notice service. It remanded the case back to the CIT(A) for fresh adjudication, instructing the assessee to participate in future hearings.

The Tribunal noted that the notice for reassessment was unsigned and that the Assessing Officer (AO) had all the necessary information. Therefore, the matter was remitted back to the AO for fresh assessment.

The Tribunal noted that the notice for reassessment was unsigned and that the Assessing Officer (AO) had all the necessary information. Therefore, the matter was remitted back to the AO for fresh assessment.

The Tribunal remitted the issue of carbon credits back to the AO for further examination due to lack of clarity and supporting evidence from the assessee. The disallowance of washing salt loss was deleted as the assessee provided expert reports justifying higher losses.

The Tribunal remitted the issue of carbon credits back to the AO for further examination due to lack of clarity and supporting evidence from the assessee. The disallowance of washing salt loss was deleted as the assessee provided expert reports justifying higher losses.