ITAT Ranchi Judgments — February 2026

The Tribunal considered the application for withdrawal. The revenue's representative had no objection. Therefore, the Tribunal allowed the appellant to withdraw the appeal.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its previous decisions, the Tribunal set aside the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its own precedent, the Tribunal set aside the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being levied. Following its own precedent, the Tribunal set aside the penalty.

The ITAT held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify under which limb of Section 271(1)(c) the penalty was being initiated. Following its previous decisions, the Tribunal set aside the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its own precedent, the Tribunal set aside the penalty order.

The Tribunal found it proper to restore the matter to the Assessing Officer to decide the issue afresh. The assessee was directed to produce all documentary evidence required by the AO.

The Tribunal, considering the principles of natural justice, restored the matter to the Assessing Officer for fresh adjudication. The assessee was directed to avail the opportunity and furnish necessary details, and the Assessing Officer was directed to grant a reasonable opportunity of being heard.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its own precedent, the Tribunal deleted the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being levied. Following its own precedent, the Tribunal set aside the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its own precedent, the Tribunal set aside the penalty order.

The Tribunal condoned the delay in filing the appeal due to the genuine hardship faced by the assessee. On merits, considering the principles of natural justice and the ex parte assessment, the Tribunal restored the matter to the Assessing Officer for readjudication.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its own precedent, the Tribunal set aside the penalty.

The Tribunal found that the CIT(A) had remanded the matter for fresh assessment as the assessee did not appear or provide evidence. While the assessee argued they had submitted details, the Tribunal decided to restore the matter to the Assessing Officer for readjudication, subject to a cost of Rs. 5,000 to be paid by the assessee. The assessee was directed to cooperate and furnish all documents.

The Tribunal condoned the delay in filing the appeal. Considering the principles of natural justice, the matter was restored to the Assessing Officer for a fresh assessment, with a direction to provide a reasonable opportunity of hearing to the assessee.

The ITAT held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify under which limb of Section 271(1)(c) the penalty was being initiated. Following its previous decisions, the Tribunal set aside the penalty.

The Tribunal found that the assessee was prevented by sufficient cause from filing the appeal within the prescribed time. Consequently, the delay of 18 days was condoned, and the issues were restored to the file of the Id. JCIT(A) for adjudication on merits.

The Tribunal acknowledged the assessee's submission of not being provided fair opportunities and the potential for bonafide hardship or lack of awareness. Considering the principles of natural justice, the Tribunal admitted the additional evidence and restored the matter to the Assessing Officer for fresh adjudication.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed, rendering the penalty proceedings void ab initio. Following its own precedent, the Tribunal deleted the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which the penalty was being imposed. Following its previous decisions, the Tribunal set aside the penalty.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) was defective as it did not specify the limb under which penalty was being levied. Following its previous decisions, the Tribunal deleted the penalty.

The Tribunal found the assessee's reasons for non-compliance (partner's illness and managing partner's custody) to be genuine. Consequently, the matter was remanded back to the Assessing Officer for a fresh adjudication, allowing the assessee a reasonable opportunity to be heard and submit necessary documents.

The Tribunal noted the assessee's claim of retirement benefits being tax-exempt and the difficulty in obtaining documentation due to employer non-cooperation, which led to non-filing of returns and inability to explain certain deposits. The Tribunal decided to restore the issue to the AO for fresh assessment.

The Tribunal held that the reassessment proceedings were barred by limitation. It noted that the speed post notice was returned unserved, email service was unsuccessful, and the notice was ultimately served through a process server on April 8, 2018. The assessment order itself recorded that the notice was not served by post. The ITBA portal did not reflect successful service on March 31, 2018. The Tribunal emphasized that service of notice within the limitation period is a jurisdictional requirement, and mere issuance without valid service does not confer jurisdiction. Since the notice was served beyond six years from the end of the relevant assessment year, the reassessment proceedings were deemed invalid. On merits, the Tribunal found that the books of account were not rejected, no material was brought on record to establish stock suppression, and additions were made merely on estimation and a fall in turnover. Furthermore, for AY 2018-19, the AO accepted the opening stock in a scrutiny assessment under Section 143(3). Once the opening stock in a subsequent year is accepted, the closing stock of the earlier year cannot be treated as incorrect. Therefore, additions on account of stock were unsustainable. Regarding commission expenses, the Tribunal noted that TDS was deducted, and payments were made through banking channels. The disallowance was made mechanically without proper appreciation of facts. Accordingly, the addition of ₹3,00,000 for commission expenses was also directed to be deleted. The appeal of the assessee was allowed, and all additions were directed to be deleted.

The Tribunal noted that both the assessment order and the CIT(A)'s order were passed ex parte without adjudicating the issues on merits. In the interest of justice, the assessee was granted one more opportunity to present their case.

The Tribunal held that the notice for reassessment under section 148 was issued beyond the four-year period stipulated in the first proviso to section 147, making it barred by limitation. The Tribunal also noted that the reassessment was based on the same material that was part of the original assessment, constituting a mere change of opinion, which is impermissible.

The Tribunal held that the CIT(A) had dismissed the appeal solely on the technical ground of delay without examining the merits of the case. It is a well-settled legal principle that substantial justice should prevail over technicalities, and appellate authorities should adopt a liberal approach in matters of condonation of delay when issues require adjudication on merits. The Tribunal found that the matter deserved to be restored to the CIT(A) for fresh adjudication on merits. Accordingly, the Tribunal restored the appeal to the file of the CIT(A) with a direction to adjudicate the appeal on merits after granting an adequate opportunity of being heard to the assessee. The assessee was also directed to cooperate and file necessary documents. The appeal was allowed for statistical purposes.

The Tribunal condoned the delay in filing the appeals. Considering the absence of the assessee's representative and the nature of the grounds raised, the Tribunal decided to restore the issue back to the Assessing Officer for readjudication.

The Tribunal held that when reassessment proceedings are initiated on a specific ground (cash deposits) but no addition is made on that ground, the AO cannot make additions on other issues. Reliance was placed on the judgment of CIT v. Jet Airways (I) Ltd. The Tribunal also found that on merits, the opening capital and stock of an ongoing business cannot be treated as unexplained investments, and the additions for expenditure lacked justification.

The Tribunal held that the Assessing Officer failed to specify the reasons and the specific clause under which the penalty under Section 271AAB was being imposed in the notice issued under Section 274. Therefore, the penalty was deleted.

The Tribunal held that penalty under Section 270A cannot be imposed when the income addition is based on an estimation, as per Section 270A(6)(b). The penalty levied was therefore not maintainable.