ITAT Ranchi Judgments — May 2026

The Tribunal condoned the delay in filing the appeal before the CIT(A) and restored the matter for adjudication on merits. The Tribunal emphasized that substantial justice should prevail over technicalities like limitation.

The Tribunal restored the issues to the file of the Assessing Officer for fresh adjudication, providing the assessee an adequate opportunity to be heard. A cost of Rs. 5,000 was imposed on the assessee for non-cooperation.

The Tribunal restored the issues to the file of the CIT(A) for fresh adjudication, allowing the assessee an opportunity to present evidence. A cost of Rs. 5,000 was imposed on the assessee for non-cooperation.

The Tribunal restored the issues in both appeals to the file of the CIT(A) for fresh adjudication. The assessee was directed to cooperate and submit all required documents and evidence.

The Tribunal restored the issues in both appeals to the file of the CIT(A) for fresh adjudication. The assessee was directed to cooperate and submit all required documents and evidence.

The Tribunal restored the issues to the file of the Assessing Officer for fresh adjudication after providing the assessee an adequate opportunity of being heard. A cost of Rs. 5,000 was imposed on the assessee for non-cooperation.

The Tribunal held that since the quantum addition under Section 69A was already deleted in the assessee's favour on the grounds that the source of cash was duly explained, the penalty under Section 271AAC(1) was not imposable. Therefore, the penalty was deleted.

The Tribunal found that the CIT(A) order was ex parte and dismissed without considering the merits. Therefore, the matter was remanded back to the CIT(A) for fresh adjudication after affording the assessee an opportunity to be heard and present supporting documents for the delay.

The Tribunal found that the CIT(A) order was ex parte and dismissed without considering the merits. Therefore, the matter was remanded back to the CIT(A) for fresh adjudication after affording the assessee an opportunity to be heard and present supporting documents for the delay.

The Tribunal held that the reassessment proceedings initiated under Sections 147/148 of the Act are bad in law and void ab initio for want of valid approval under Section 151 of the Act. The Tribunal found that the approval was issued by the PCIT, Patna, whereas the AO sought approval from the DGIT (Investigation), Patna, indicating a lack of jurisdiction and non-application of mind by the issuing authority. Furthermore, the Tribunal held that the addition made under Section 68/69A of the Act is unsustainable. The assessee had satisfactorily established the identity, genuineness, and creditworthiness of the share applicant company, M/s Smart Tradecomm Private Limited, by producing documentary evidence, including audited balance sheets and bank statements. The Revenue failed to bring any adverse material on record to rebut these evidences. The Tribunal relied on the principles laid down in Pr. CIT (Central)-1 v. NRA Iron & Steel (P.) Ltd. and Income-tax Officer vs. Cornerstone Property Investments (P.) Ltd., emphasizing that once the initial burden of proof by the assessee is discharged, the onus shifts to the Revenue to prove otherwise, which it failed to do. The assessment order passed by the AO and sustained by the CIT(A) was set aside, and the addition of Rs.4,75,00,000/- was deleted. The appeal of the assessee was allowed.

The Tribunal restored the issues to the file of the CIT(A) for fresh adjudication. The assessee was directed to cooperate and submit all required documents to ensure adequate opportunity of being heard.

The Tribunal, while noting the assessee's non-compliance, granted a final opportunity in the interest of justice and fair play. The matter was restored to the CIT(A) for fresh adjudication, with a cost imposed on the assessee for the delay.

The Tribunal, while noting the assessee's non-compliance, granted a final opportunity in the interest of justice and fair play. The matter was restored to the CIT(A) for fresh adjudication, with a cost imposed on the assessee for the delay.

The Tribunal, while noting the assessee's non-compliance, granted a final opportunity in the interest of justice and fair play. The matter was restored to the CIT(A) for fresh adjudication, with a cost imposed on the assessee for the delay.

The Tribunal, while noting the assessee's non-compliance, granted a final opportunity in the interest of justice and fair play. The matter was restored to the CIT(A) for fresh adjudication, with a cost imposed on the assessee for the delay.

The Tribunal, while noting the assessee's non-compliance, granted a final opportunity in the interest of justice and fair play. The matter was restored to the CIT(A) for fresh adjudication, with a cost imposed on the assessee for the delay.

The Tribunal, while noting the assessee's non-compliance, granted a final opportunity in the interest of justice and fair play. The matter was restored to the CIT(A) for fresh adjudication, with a cost imposed on the assessee for the delay.

The Tribunal held that the reassessment proceedings under Section 147 were invalid in law. The notice under Section 148 was issued beyond four years from the end of the assessment year (2012-13), and there was no failure on the part of the assessee to disclose full and true material facts necessary for the assessment. The original assessment under Section 143(3) had already examined the issues related to unsecured loans, and the assessee had furnished all necessary details. Therefore, the reopening was based on a mere change of opinion, which is not permissible. The Tribunal confirmed the CIT(A)'s view that the notice under Section 148 was bad in law. On merits, the Tribunal found that the CIT(A) had rightly deleted the addition. The Assessing Officer's inconsistent treatment of credits from the same entities (treating Rs. 4,08,50,583/- as unexplained while accepting Rs. 1,41,00,000/-) was not justified. Furthermore, the assessee had paid interest on these loans and deducted tax at source, which the Assessing Officer did not question. This indicated acceptance of the genuineness of the transactions. Therefore, treating the principal amount as unexplained was without proper reasons. The Tribunal sustained the order of the CIT(A) by dismissing the Revenue's appeal.

The Tribunal upheld the CIT(A)'s decision to restrict additions to the profit element of disputed purchases, finding it contradictory to accept sales while disallowing corresponding purchases. The deletion of commission income was also affirmed.

The Tribunal upheld the CIT(A)'s decision to restrict additions to the profit element of disputed purchases, finding it contradictory to accept sales while disallowing corresponding purchases. The deletion of commission income was also affirmed.

The Tribunal found that fresh documents submitted before the CIT(A) required examination by the Assessing Officer. Therefore, the matter was restored to the CIT(A) to call for a remand report and re-adjudicate.

The Tribunal upheld the CIT(A)'s decision to restrict additions to the profit element of disputed purchases, finding it contradictory to accept sales from the same parties while disallowing purchases. The Tribunal also upheld the deletion of commission income and the addition for sundry creditors.

The Tribunal set aside the CIT(A)'s ex-parte order, directing a fresh adjudication on merits after providing the assessee with an adequate opportunity of being heard. A cost of Rs. 5,000 was imposed on the assessee for repeated non-compliance.

The Tribunal found that the assessment was completed ex-parte and the CIT(A) dismissed the appeal without adjudicating on merits. In the interest of justice, the assessee was granted another opportunity to present its case.

The Tribunal found that the assessment was completed ex-parte and the CIT(A) dismissed the appeal without adjudicating on merits. In the interest of justice, the assessee was granted another opportunity to present its case.

The Tribunal observed that both the assessment and appellate orders were passed ex-parte due to the assessee's non-compliance. In the interest of justice, the matter was restored to the AO for fresh adjudication, with a direction to provide the assessee with an adequate opportunity to be heard. A cost of Rs. 5,000 was imposed on the assessee for non-compliance.

The Tribunal found that the assessment was completed ex-parte and the CIT(A) dismissed the appeal without adjudicating on merits. In the interest of justice, the assessee was granted another opportunity to present its case.