ITAT Rajkot Judgments — April 2026

The Tribunal held that the CIT(A)'s decision to restrict the addition to the profit element embedded in bogus purchases, following jurisdictional High Court rulings, was correct. The appeal by the revenue was dismissed.

The Tribunal held that the transactions between the assessee and the company constituted a mutual, open, and current account, not a loan or advance. Therefore, Section 2(22)(e) was not applicable.

The Tribunal found that the rectification order was passed on a debatable issue and that interest under Section 234C had already been charged. Therefore, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal noted that the Assessing Officer passed the rectification order without considering the assessee's submissions and that the levy of interest might be erroneous. Therefore, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal restored the matter to the Assessing Officer for de novo adjudication. This was done because the assessee was not given a proper opportunity of being heard by both the AO and CIT(A), violating principles of natural justice.

The Tribunal condoned the delay in filing the appeals before the CIT(A), citing the advocate's mistake and the need for a liberal approach in such matters. Since the CIT(A) had not adjudicated on merits, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal found that the AO and CIT(A) did not establish deliberate non-compliance by the assessee. The notices were not clearly specified as to how they were served, and the assessee had submitted replies. Therefore, the penalty was deleted.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal held that the notice under section 148 of the Act was issued beyond the surviving period, making it invalid. Consequently, the reassessment proceedings were quashed.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal noted that the assessment order was contradictory as it was framed under Section 143(3) but the AO had rejected the books of accounts, indicating a proceeding under Section 144. Since no proper adjudication was made by the AO, the matter was restored back to the AO for a fresh assessment.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal held that the earlier order quashing the Section 263 assessments was effective, as there was no stay from the High Court. Consequently, the appeals filed by the revenue were deemed infructuous.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The CIT(A) deleted the addition, holding that the cash payments were made before the existence of the assessee firm (formed on 06.01.2018). The Tribunal noted the Revenue's argument that even if some payments were before the firm's existence, a part of the addition might still be valid.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal held that the assessee was not liable to deduct TDS on payments made to foreign agents for services rendered outside India, as these payments were not taxable in India. Therefore, the disallowance made by the Assessing Officer was not justified.

The Tribunal followed a coordinate bench's decision and jurisdictional High Court rulings, finding that the assessee had provided sufficient documentation for the share transactions. The additions made by the Assessing Officer were based on assumptions and lacked concrete evidence.

The Tribunal noted that the assessee failed to adequately explain the melting loss with documentary evidence. Therefore, the matter was restored to the Assessing Officer for fresh consideration, allowing the assessee to submit further evidence.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.

The Tribunal noted that the CIT(Exemption) had passed ex-parte orders. Accepting the assessees' request for an opportunity to represent their case and submit additional documents, the Tribunal remitted the matters back to the CIT(Exemption) for fresh adjudication.