ITAT Rajkot Judgments — August 2026

The Tribunal held that the assessment order was invalid because the mandatory notice under section 143(2) of the Income-tax Act was not issued after the assessee filed a return in response to a notice under section 148.

The Tribunal condoned the delay in filing the appeal. It held that the assessee deserved another opportunity to contest the case on merit due to the lower appellate authority's ex-parte order and the need to examine the additional evidence.

The Tribunal found that the cash deposited in the bank account represented genuine transactions from members' savings accounts and loan repayments. The assessee, a credit co-operative society, provided evidence like ledger extracts and cash books to substantiate the source of funds. Therefore, the addition under Section 68 was not justified.

The Tribunal held that the approval for reopening under Section 151 was mechanical and lacked application of mind. It also found no live nexus between the cash deposits and escaped income, especially as the accounts were jointly held and deposits could be linked to agricultural income.

The Tribunal held that the approval for reopening under Section 151 was mechanical and lacked application of mind. It also found no live nexus between the cash deposits and escaped income, especially as the accounts were jointly held and deposits could be linked to agricultural income.

The Tribunal held that the Assessing Officer's rejection of the assessee's books of accounts was not tenable, especially when purchases were accepted and the books were audited. Consistency with previous years' treatment of accounts was also a significant factor.

The Tribunal held that the Assessing Officer's rejection of the assessee's books of accounts was not tenable, especially when purchases were accepted and the books were audited. Consistency with previous years' treatment of accounts was also a significant factor.

The Tribunal held that the Assessing Officer's rejection of the assessee's books of accounts was not tenable, especially when purchases were accepted and the books were audited. Consistency with previous years' treatment of accounts was also a significant factor.

The tribunal noted that the assessee did not wish to press the appeal and the Departmental Representative had no objection. Therefore, the appeal was treated as withdrawn by the tribunal.

The ITAT held that the addition under Section 68 was beyond the scope of limited scrutiny and deleted it. The addition under Section 56(2)(vii)(b) was restored to the Assessing Officer for fresh adjudication.

The Tribunal found that the cash deposited in the bank account represented genuine transactions from members' savings accounts and loan repayments. The assessee, a credit co-operative society, provided evidence like ledger extracts and cash books to substantiate the source of funds. Therefore, the addition under Section 68 was not justified.

The Tribunal found that the cash deposited in the bank account represented genuine transactions from members' savings accounts and loan repayments. The assessee, a credit co-operative society, provided evidence like ledger extracts and cash books to substantiate the source of funds. Therefore, the addition under Section 68 was not justified.

The tribunal noted that the assessee failed to appear for multiple hearings despite repeated notices. Consequently, the tribunal concluded that the assessee was not interested in pursuing the appeal.

The Tribunal held that since the assessee followed the cash system of accounting and the Work Contract Tax was actually paid during the relevant previous year, the deduction was allowable. The interest on delayed payment was also held to be compensatory and deductible.

The Tribunal held that the AO had conducted sufficient inquiry, distinguishing between 'lack of inquiry' and 'inadequate inquiry'. The PCIT cannot invoke Section 263 merely because he has a different opinion or believes further inquiry was needed.

The tribunal noted the assessee's consistent absence and failure to prosecute the appeal. Considering the conduct of the assessee, the tribunal decided to dismiss the appeal for non-prosecution.

The Tribunal held that the AO had conducted a proper inquiry by calling for and examining all necessary documents and details from the assessee. The PCIT's finding of a 'lack of inquiry' was therefore incorrect, and the assessment order was not erroneous or prejudicial to the revenue.

The Tribunal restored the issue of the alleged cash gift from the father to the Assessing Officer for fresh adjudication. The Assessing Officer is to re-examine the documentary evidence supporting the gift, which was allegedly not duly considered earlier.

The Tribunal held that the PCIT was not justified in invoking Section 263 as the Assessing Officer had clearly recorded the non-availability of crucial reopening material. The PCIT failed to demonstrate a specific error in the assessment order or prejudice to revenue based on material actually available to the AO.

The Tribunal held that the AO had conducted an inquiry and taken a possible view, which cannot be treated as erroneous simply because the PCIT held a different opinion. The conditions for invoking section 263 were not met.

The Tribunal held that the addition of Rs. 2,65,59,500/- was unsustainable. The cash deposits were explained as proceeds from genuine cash sales recorded in audited books, corroborated by stock and sales registers and VAT returns, and taxing the same receipt again would amount to double taxation.

The Tribunal condoned the delay in filing the appeal. The Tribunal found that the CIT(A) order was ex-parte and non-speaking, violating principles of natural justice.

The Tribunal held that the Assessing Officer had already examined the issue during the original assessment, considering the assessee's denial and confirmation from the developer. The PCIT's revision was based on a change of opinion without new material, thus not satisfying the conditions for Section 263.

The Tribunal condoned the delay in filing the appeal and set aside the CIT(A)'s order. The matter was restored to the CIT(A) for a fresh adjudication on merits, with directions for the assessee to comply with notices.

The Tribunal condoned the delay in filing the appeal. It restored the matter to the Assessing Officer to decide the issue afresh after considering the outcome of the assessee's pending application under Section 119(2)(b) for condonation of delay in filing the return.

The Tribunal held that the reassessment proceedings were invalid due to lack of proper approval under Section 151 and violation of principles of natural justice by not providing an opportunity for cross-examination. Consequently, the reassessment order was quashed.

The Tribunal condoned the delay in filing the appeal before the CIT(A) after finding the reasons provided to be sufficient. The Tribunal restored the matter to the Assessing Officer for de novo adjudication, emphasizing the need for a speaking order and adequate opportunity for the assessee to be heard.

The Tribunal condoned the delay in filing the appeal before the CIT(A) as the reasons provided were convincing. The Tribunal set aside the CIT(A)'s order and remitted the matter back for de novo adjudication, citing violation of natural justice.

The tribunal noted that the assessee did not wish to press the appeal and the Departmental Representative had no objection. Therefore, the appeal was treated as withdrawn.

The Tribunal found that the CIT(A)'s order was passed ex-parte and violated the principles of natural justice. Therefore, the matter was restored to the Assessing Officer for de novo adjudication.

The Tribunal found that the CIT(A) failed to consider the assessee's written submissions and comparable cases, violating the principles of natural justice. Therefore, the matter was restored to the CIT(A) for fresh adjudication.

The Tribunal condoned the delay in filing the appeals. Considering the ex-parte and non-speaking nature of the CIT(A)'s order and violation of natural justice, the matter was restored to the Assessing Officer for de novo adjudication.

The Tribunal condoned the delay in filing the appeal. It held that the CIT(A)'s order was ex-parte and a violation of natural justice, and therefore set aside the order.

The Tribunal held that the assessee was not given a sufficient opportunity to be heard and present their case. To ensure principles of natural justice and fair play, the matter was restored to the Assessing Officer for fresh adjudication.

The tribunal condoned the delay and admitted the appeal. Finding the CIT(A) order to be ex-parte and non-speaking, violating natural justice, the matter was restored for de novo adjudication.

The Tribunal held that the CIT(A)'s order violated the principles of natural justice as the assessee was not afforded sufficient opportunity to be heard. The matter was restored to the Assessing Officer for de novo adjudication.

The Tribunal held that the addition made by the AO was not sustainable as the assessee was not provided an opportunity to cross-examine the witness whose statement was relied upon, violating principles of natural justice. Furthermore, on merits, the Tribunal found no cogent evidence to link the assessee with the accommodation entry provider.

The Tribunal upheld the CIT(A)'s decision to delete the addition, following the Gujarat High Court's precedent that once loan repayment is established through documentary evidence, the transaction cannot be viewed in isolation.

The Tribunal held that the assessee had provided sufficient documentary evidence to establish the identity, genuineness, and creditworthiness of the lenders. The mere mismatch between loan amount and returned income, or non-response to section 133(6) notices, was not sufficient to reject the evidence.

The Tribunal condoned the delay in filing the appeal. It held that the CIT(A) order was ex-parte and non-speaking, violating natural justice, and therefore restored the matter to the Assessing Officer for de novo adjudication.

The tribunal condoned the delay in filing the appeal before the CIT(A). The tribunal set aside the CIT(A)'s ex-parte order and restored the matter to the Assessing Officer for de novo adjudication.

The Tribunal held that the CIT(A)'s order was ex-parte and non-speaking, violating the principles of natural justice. The matter was restored to the Assessing Officer for de novo adjudication.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to sufficient cause. The matter was restored to the Assessing Officer for de novo adjudication to provide the assessee with an opportunity to present evidence and plead their case.

The Tribunal condoned the delay in filing the appeals. Considering the ex-parte and non-speaking nature of the CIT(A)'s order and violation of natural justice, the matter was restored to the Assessing Officer for de novo adjudication.

The Tribunal condoned the delay in filing the appeal and, following a precedent, directed the Assessing Officer to restrict the addition to 10% of the disputed amount (Rs. 17,600/-). The addition was to be taxed under normal provisions, not under section 115BBE.

The Tribunal held that the notice issued under Section 148 of the Act on 28.06.2022 was barred by limitation. Consequently, the reassessment proceedings were invalid, and the assessment order was quashed.

The Tribunal set aside the assessment order and restored the matter to the Assessing Officer for fresh adjudication, directing them to examine all issues including the validity of reassessment proceedings. The revisionary order under Section 263 was also set aside as the underlying assessment order was nullified.

The Tribunal set aside the assessment order and restored the matter to the Assessing Officer for fresh adjudication, directing them to examine all issues including the validity of reassessment proceedings. The revisionary order under Section 263 was also set aside as the underlying assessment order was nullified.

The Tribunal found no infirmity in the CIT(A)'s order to set aside the assessment and restore the matter to the AO for fresh examination, as the genuineness of purchases required verification. The assessee was directed to furnish necessary documents.

The Tribunal set aside the CIT(A)'s order and restored the matter to the Assessing Officer for fresh adjudication. A cost of ₹5,000 was imposed on the assessee for non-compliance.