ITAT Ranchi Judgments — January 2026

The Tribunal, considering the assessee's submission about COVID-19 related difficulties and the lack of serious objection from the Revenue, decided to restore the issue back to the CIT(A) for fresh adjudication. The assessee was directed to provide all supporting documents.

The Tribunal found that the assessee could not avail the opportunities to present its case before the lower authorities. Therefore, the matter was restored to the Assessing Officer for fresh adjudication, allowing the assessee a reasonable opportunity to be heard and provide supporting documents.

The Tribunal held that it is imperative for the CIT(E) to provide the assessee a reasonable and sufficient opportunity to explain its case before rejecting the application for registration. Therefore, the matter was restored back to the file of the CIT(E).

The Tribunal noted that the appeals were filed by the assessees, but none appeared on their behalf. The Revenue's DR supported the CIT's order. However, the Tribunal decided to remand the issue back to the CIT(E) to re-examine the issue after giving the assessee an opportunity to be heard and submit documents.

The Tribunal noted that the CIT(E) rejected the applications for registration under Section 80G due to non-submission of supporting documents. In the interest of justice, the Tribunal decided to remand the issue back to the CIT(E) for a fresh examination, allowing the assessee a reasonable opportunity to be heard and to submit necessary documents.

The Tribunal, noting the assessee's failure to appear and furnish evidence, restored the matter to the CIT(A) for fresh examination on merits. The assessee was directed to provide supporting documents and cooperate.

The Tribunal held that the CIT(A) erred in dismissing the appeal on technical grounds without considering the merits and adhering to principles of natural justice. The matter was restored to the CIT(A) for fresh adjudication.

The Tribunal held that the applications were rejected due to non-submission of documents. In the interest of justice, the matters were remanded back to the CIT(Exemption) for fresh examination after allowing the assessees to submit all relevant documents and provide an opportunity of being heard.

The Tribunal found that the assessees had failed to produce necessary documents before the CIT(E) during the initial application stage. To ensure justice and fair play, the Tribunal decided to remand the matters back to the CIT(E) with a direction to re-examine the applications after allowing the assessees a reasonable opportunity to be heard and submit all required documents.

The Tribunal noted that the assessees were ready to submit the required documents and, in the interest of justice, remanded the cases back to the CIT(E) for re-examination. The assessees were directed to submit all relevant documents during the remand proceedings.

The Tribunal held that the reassessment proceedings were bad in law as they went beyond the scope of the show cause notice. Furthermore, the interest income was consistently treated as business income in earlier years, and the disallowance of expenses was not sustainable.

The Tribunal held that interest income from fixed deposits, maintained as security for mining contracts, should be treated as business income, consistent with past assessments. It also found the addition on account of estimated profit from iron ore trading to be arbitrary.

The Tribunal held that the assessee did not receive a reasonable opportunity of being heard by the CIT(A). Therefore, in the interest of justice, the order of the CIT(A) was set aside, and the matter was restored for fresh adjudication.

The Tribunal noted that the assessee raised a legal objection regarding the non-issuance of a notice under Section 143(2) during assessment proceedings. The revenue contended that the return filed in response to the Section 148 notice was belated. The Tribunal restored the matter to the Assessing Officer to decide afresh after providing opportunities for the assessee to explain the difference.

The Tribunal noted that the statutory notices for the reassessment proceedings were allegedly not properly served on the assessee's registered email ID. Due to this improper service, the assessee was deprived of a reasonable opportunity to be heard.

The Tribunal found that the assessee failed to produce relevant documents before the CIT(E), leading to the rejection of the application. The Tribunal remanded the issue back to the CIT(E) for re-examination.

The Tribunal noted that the assessee's representative claimed a lack of proper opportunities before the lower authorities. Considering the submissions and the fact that the assessment order was passed under Section 147 read with Sections 144 and 144B, the Tribunal decided to restore the matter to the Assessing Officer for a fresh decision on merit, with sufficient opportunities provided. The assessee was also directed to appear before the AO to explain the claims.

The Tribunal noted that the assessee did not appear before the CIT(E) and the application was rejected on grounds of non-submission of documents. The Tribunal decided to remand the issue back to the CIT(E) for a fresh examination, granting the assessee a reasonable opportunity to be heard and submit necessary documents.

The Tribunal observed that the assessee failed to appear before the CIT(E) and did not submit necessary documents, leading to the rejection of the application. Considering the interest of justice, the Tribunal decided to remand the issue back to the CIT(E) for fresh examination after providing the assessee a reasonable opportunity to be heard and submit documents.

The Tribunal held that the assessee had discharged the onus cast upon it under Section 68 by providing sufficient evidence of the identity, creditworthiness, and genuineness of the share transactions. The AO had not conducted sufficient independent inquiry and relied solely on the non-appearance of directors of the investor companies.

The Tribunal noted that the assessee failed to appear and did not furnish supporting documents. However, in the interest of justice, the matter was restored to the CIT(A) for a fresh examination, with a direction to afford the assessee a reasonable opportunity of being heard and to submit supporting documents.

The CIT(A) allowed the assessee's appeal, deleting the additions. The CIT(A) relied on the Tribunal's decision in the assessee's own case for AY 2016-17, where identical issues were decided in favor of the assessee. The Tribunal upheld the CIT(A)'s order, noting that the issue was covered by previous decisions and there was no change in facts or law.

The CIT(A) deleted the addition of ₹ 8.50 lacs, finding the source explained. However, the CIT(A) confirmed the addition of ₹ 3,08,005/- for stamp duty and registration, stating the source was not explained by the assessee. The Tribunal examined the source of ₹ 3,79,888/- credited to the assessee's sister from the deceased father's PF claim.

The Tribunal restored the quantum appeals to the file of the Assessing Officer for readjudication, noting the ex-parte nature of the CIT(A) orders and lack of proper details provided by the assessee. Consequently, the penalties levied were quashed as their foundation no longer survived.

For certain appeals, the issues were restored to the Assessing Officer due to the ex-parte nature of the CIT(A) order and the assessee's failure to provide complete details. For other appeals related to penalties, the penalties were quashed as the quantum appeals were restored and the foundation for penalties no longer survived.

The Tribunal restored the quantum appeals to the Assessing Officer as the CIT(A) orders were ex-parte and the assessee had not provided complete details. For appeals concerning penalties, since the quantum appeals were restored, the penalties were quashed as their foundation no longer survived.

The Tribunal noted that the stock in transit, when considered at Rs.60,05,348/-, showed no difference between the disclosed and found stock. Regarding the cash found, it was clarified as being from cash sales, supported by cash books and auditor's certificate. Therefore, no addition was warranted.

The Tribunal quashed the notice issued under section 148 and the consequential assessment order. It found significant factual inconsistencies and errors in the reasons recorded for reopening, rendering them unsustainable. The Tribunal noted that the original assessment had already examined the issue of share application money.

The Tribunal restored the quantum appeals to the Assessing Officer for readjudication, noting the ex parte nature of the CIT(A)'s orders and the assessee's non-compliance. For the penalty appeals, since the quantum matters were restored, the penalties were quashed.

For quantum appeals (ITA Nos. 138, 141, 143, 145, 146 & 160/Ran/2025), the issues were restored to the Assessing Officer due to ex-parte orders and lack of proper compliance. For penalty appeals (ITA Nos. 139, 140, 142, 144, 147, 152, 153, 154, 155, 156, 157, 158 & 159/Ran/2025), the penalties were quashed as the foundation for their levy no longer survived.

The Tribunal restored the quantum appeals to the Assessing Officer for readjudication, noting the ex-parte nature of the CIT(A) orders and lack of proper compliance. For the penalty appeals, as the quantum appeals were restored, the penalties were quashed, with liberty to the Assessing Officer to initiate fresh proceedings if required.

The Tribunal held that a valid return must exist for a notice under section 143(2) to be issued. In this case, the notices were issued referencing returns that were not filed on the dates specified in the notices, rendering them invalid. The Tribunal relied on Supreme Court decisions in Hotel Blue Moon and Laxman Das Khandelwal, stating that the non-issuance of a valid 143(2) notice is not a curable defect under section 292BB.

The Tribunal observed that the assessee was not granted adequate opportunities to present their case and had not responded to notices. Therefore, the case was restored to the file of the CIT(A) for readjudication, with a direction to grant the assessee a fair opportunity to be heard and to submit all relevant documents.

The Tribunal noted that the CIT(A)'s orders were ex-parte. For quantum matters, the appeals were restored to the Assessing Officer for readjudication in the interest of justice. For penalty appeals, since the quantum matters were restored, the foundation for penalties no longer survived, and the penalties were quashed.

The Tribunal noted that the assessee had not provided complete explanations and details before the CIT(E) regarding the issue raised on the irrevocable clause. Therefore, the appeal was restored to the file of the CIT(E) to provide the assessee another opportunity to substantiate its case.

For the quantum appeals, the Tribunal restored the issues to the Assessing Officer for re-adjudication, noting the ex-parte nature of the CIT(A) order and lack of details from the assessee. For the penalty appeals, since the quantum matters were restored, the foundation for penalties did not survive, and the penalties were quashed.

The Tribunal noted that the grounds related to reopening and reassessment were not previously considered by the CIT(A). Therefore, the issues were restored to the CIT(A) for fresh adjudication with an opportunity for the assessee to be heard.

The Tribunal held that the reasons recorded for reopening did not demonstrate any failure on the part of the assessee to disclose truly and fully all material facts. Furthermore, the reopening was initiated beyond the four-year period without satisfying the conditions precedent. The reassessment was considered to be based on a change of opinion without allegations of suppression of material facts.

The Tribunal restored the quantum appeals to the file of the Assessing Officer in the interest of justice, noting that the assessment orders were ex parte and the assessee had not provided all details. Consequently, the penalties levied were quashed, with liberty granted to the Assessing Officer to initiate fresh proceedings.

The Tribunal noted that these grounds were not raised before the CIT(A). Therefore, the issues were restored to the file of the CIT(A) for readjudication after providing the assessee an adequate opportunity of being heard.

The Tribunal restored the quantum matters to the Assessing Officer for readjudication due to the ex-parte nature of the assessment and CIT(A) orders. Consequently, penalties levied were quashed as their foundation no longer survived.

For the quantum appeals, the Tribunal restored the issues to the Assessing Officer for readjudication, noting the ex parte nature of the CIT(A) orders and lack of proper compliance. For penalty appeals, since the quantum appeals were restored, the penalties were quashed.

The Tribunal noted that the CIT(A) orders were ex-parte and the assessee had not provided full details. For quantum appeals, issues were restored to the Assessing Officer. For penalty appeals, since the quantum matters were restored, the penalties were quashed.

The Tribunal noted that the grounds of reopening and reassessment were not placed before the CIT(A). Therefore, these issues were restored to the CIT(A) for readjudication, with an opportunity for the assessee to be heard.

The Tribunal restored the quantum appeals to the file of the Assessing Officer for readjudication, noting that the assessee had not provided all details and the CIT(A) orders were ex-parte. Consequently, the penalties levied were quashed as their foundation no longer survived.

The tribunal held that the notices issued under Section 143(2) were invalid as they were based on a non-existent return. Consequently, the assessments made pursuant to these invalid notices were also quashed.