ITAT Ranchi Judgments — January 2026

The Tribunal restored the quantum matters to the file of the Assessing Officer for readjudication due to ex parte orders and lack of proper compliance. Consequently, penalties levied were quashed as their foundation no longer survived.

The Tribunal restored the quantum matters to the file of the Assessing Officer for readjudication due to ex parte orders and lack of proper compliance. Consequently, penalties levied were quashed as their foundation no longer survived.

The Tribunal restored the quantum matters to the file of the Assessing Officer for readjudication due to ex parte orders and lack of proper compliance. Consequently, penalties levied were quashed as their foundation no longer survived.

The Tribunal restored the quantum matters to the file of the Assessing Officer for readjudication due to ex parte orders and lack of proper compliance. Consequently, penalties levied were quashed as their foundation no longer survived.

The Tribunal restored the quantum matters to the file of the Assessing Officer for readjudication due to ex parte orders and lack of proper compliance. Consequently, penalties levied were quashed as their foundation no longer survived.

The Tribunal restored the quantum matters to the file of the Assessing Officer for readjudication due to ex parte orders and lack of proper compliance. Consequently, penalties levied were quashed as their foundation no longer survived.

The Tribunal noted that as the quantum assessment was restored to the AO, the basis for levying the penalties no longer existed. Consequently, the penalties levied under sections 271AA and 270A of the Act were quashed.

The Tribunal noted that as the quantum assessment was restored to the AO, the basis for levying the penalties no longer existed. Consequently, the penalties levied under sections 271AA and 270A of the Act were quashed.

The Tribunal noted that the orders under appeal were passed after the assessee's death and that the legal representative had not been substituted. In the interest of justice, the issues in the appeals were restored to the Assessing Officer for readjudication after bringing the legal representative on record.

The Tribunal held that the denial of exempt income claimed by the assessee in the intimation under Section 143(1) was not a prima facie adjustment permissible under the said section. Therefore, the intimation and consequential rectification were quashed.

The tribunal held that the non-supply of approval under section 151 of the Act, which is a mandatory requirement, vitiates the entire reassessment proceedings. The assumption of jurisdiction under section 147 is invalid and bad in law.

The Tribunal held that the assessee was prevented by sufficient cause from filing the appeal within the prescribed time. Consequently, the delay of 184 days was condoned, and the issues were restored to the file of the Id. JCIT(A) for adjudication on merits.

The Tribunal held that unabsorbed depreciation is to be carried forward without limit as per the Finance Act, 2001 amendment. It also confirmed the allowability of contractual expenses where bills were received and work executed, and directed the AO to allow claims for expenses missed in the original computation.

The Tribunal held that the assessee had discharged its onus under Section 68 by providing complete details of share applicants, their creditworthiness, and the genuineness of transactions. The Assessing Officer failed to conduct independent inquiries, making the addition unsustainable.

The Tribunal held that unabsorbed depreciation is to be carried forward without limit as per the amended Section 32(2), following previous decisions. It also confirmed the disallowance of unpaid contractual expenses, finding that the liability had arisen and the CIT(A) correctly applied the Supreme Court's decision. The issue of expenses relating to exempt income was also decided in favour of the assessee based on prior tribunal rulings.

The Tribunal held that unabsorbed depreciation is allowable for carry forward and set off without limit, following previous decisions. It also confirmed the allowance of unpaid contractual expenses as the liability had arisen and the work was executed. The disallowance under Section 14A was also upheld based on sufficient interest-free funds.

The Tribunal condoned the delay in filing the appeal, prioritizing substantial justice over technicality. The appeal was restored to the file of the CIT(A) for fresh adjudication, subject to the assessee paying a cost of Rs. 10,000 and cooperating in the proceedings.

The Tribunal held that unabsorbed depreciation is available for carry forward and set off without limit as per the amended Section 32(2). It also confirmed the disallowance of unpaid contractual expenses as the liability had arisen and the CIT(A) had followed Supreme Court precedent. Finally, the disallowance of expenses related to exempt income was upheld based on prior Tribunal orders.

The Tribunal held that unabsorbed depreciation is available for carry forward and set off without limit, following a coordinate bench decision. It also confirmed the disallowance of unpaid contractual expenses as the liability was incurred and bills were raised. The issue of expenses relating to exempt income was also decided in favour of the assessee based on prior rulings.

The Tribunal held that since the assessee had obtained the necessary relief from the AO, the appeal filed before the CIT(A) no longer survived. Consequently, the appeal before the Tribunal became infructuous.

The Tribunal held that penalty proceedings are contingent on the sustainability of the quantum addition. Since the quantum addition on an identical issue for the same assessment year had already been deleted by the Tribunal, the penalty imposed as a consequence of that addition cannot survive.

The tribunal held that notional interest cannot be added when the assessee has not received any interest and has used personal funds for the loan. However, the addition of Rs. 1,50,000 was upheld as the assessee could not substantiate its source.

The Tribunal held that the disclosure made by the assessee during the survey sufficiently covered the profit element in the excess stock. It also found that adding the short cash separately would amount to double taxation. Furthermore, the change of section by the CIT(A) without notice violated natural justice.

The tribunal observed that the Assessing Officer erroneously referred to the savings bank account but examined transactions from the current account. Furthermore, the figure of ₹2.05 crores was not found in any produced bank accounts. Considering this was an ex parte order before the AO and CIT(A), the tribunal restored the issues to the AO for readjudication to ensure fair opportunity for the assessee.

The tribunal held that the assessment framed under section 153A for Assessment Year 2011-12 was bad in law and barred by limitation. The search was conducted on 23.10.2019, and AY 2011-12 falls beyond the permissible period prescribed under the Act for initiating proceedings under section 153A, especially since the total additions were below ₹50,00,000.

The Tribunal held that the reopening under section 147 was invalid because it was based solely on third-party information without independent verification or application of mind by the AO. The AO failed to examine the nature of the property, the number of purchasers, and the correctness of the stamp duty valuation. Furthermore, even on merits, the addition was unsustainable as the property was leasehold, only superstructure was transferred, and the assessee was one of three co-purchasers.

The Tribunal held that two parallel reassessment proceedings were initiated for the same assessment year without concluding the first one, which is impermissible. Furthermore, the reassessment order was passed without issuing the mandatory notice under Section 143(2) of the Act for the proceedings initiated by the second notice. The absence of such a notice is a jurisdictional defect that cannot be cured.

The Tribunal held that the decisions of the jurisdictional High Court are binding on all subordinate authorities. The assessee had relied on a jurisdictional High Court decision dealing with identical facts, which the CIT(A) failed to distinguish or demonstrate its inapplicability. Suspicion alone cannot replace evidence, and the AO had not disproved the assessee's documentary evidence.

The Tribunal acknowledged the consistent non-representation and non-submission of evidence by the assessee before the lower authorities. However, in the interest of justice, the appeal was restored to the Assessing Officer for readjudication after providing the assessee with an opportunity to be heard and submit evidence.

The tribunal held that the approval for reopening under Section 151 was granted mechanically and without application of mind, as it was a composite approval for multiple assessees. This vitiated the reassessment proceedings.

The inspector's report confirmed that 25 acres of land were being used for agricultural operations, with crops like paddy, wheat, pulses, mustard, and green vegetables being grown. No commercial or residential activities were found on the land.

The Tribunal restored the appeal to the file of the AO for readjudication, granting the assessee an opportunity to be heard and present documents, subject to a cost of Rs. 10,000.

The Tribunal noted that the assessee had eventually complied with the notices, though belatedly. In the interest of justice, the issues were restored to the file of the CIT(E) to grant the assessee an opportunity to substantiate its case. The delay in filing the appeal was also condoned.

The Tribunal held that the denial of exempt income claimed by the assessee in the intimation under Section 143(1) was not a prima facie adjustment permissible under the said section. Therefore, the intimation and consequential rectification were quashed.

The Tribunal, following the decisions of the Jurisdictional High Court and a coordinate bench, held that the notice issued under Section 148A(b) was bad in law because the compliance period was less than the statutory seven days. Consequently, the notice and the consequential assessment order were quashed.

The Tribunal noted that the primary assessment order no longer survived due to the order under Section 263. Since the assessee admitted that a consequential assessment order was also passed and appealed against, the Tribunal considered the appeal infructuous.

The tribunal noted that the assessee had not furnished the necessary details to the CIT(E). Therefore, in the interest of justice, the issues were restored to the file of the CIT(E) for fresh adjudication after providing the assessee with a proper opportunity to be heard.

The Tribunal noted that the orders under appeal were passed after the assessee's death and that the legal representative had not been substituted. In the interest of justice, the issues in the appeals were restored to the Assessing Officer for readjudication after bringing the legal representative on record.

The Tribunal considered the rival submissions and perused the facts and the order of the CIT(E). It was observed that the assessee had not furnished the necessary details. Therefore, in the interest of justice, the issues were restored to the file of the CIT(E) for readjudication after providing the assessee with an adequate opportunity of being heard.

The Tribunal held that the time provided for compliance with the notice under Section 148A(b) of the Act was less than the seven days prescribed by the statute. Following the decision of the Hon'ble Jurisdictional High Court in the case of Satish Kumar, the notice was deemed bad in law and quashed.

The Tribunal restored the issues to the file of the CIT(A) for fresh adjudication. The assessee was granted an adequate opportunity to be heard and directed to cooperate.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.

The Tribunal noted that the assessment order was passed under Section 143(3), implying subsequent cooperation and pardoning of non-compliance by the Assessing Officer. Therefore, the penalty levied and confirmed by the CIT(A) was deleted.

The tribunal noted that the CIT(A) granted only one opportunity, and the assessee could not appear. Therefore, in the interest of justice, the appeals were restored to the CIT(A) for readjudication with a cost of Rs. 5,000/- per appeal.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.

The Tribunal held that lease rent for forest land should be amortized over the lease period. Land and crop compensation was held to be revenue expenditure. Several other issues were decided based on previous rulings.