This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) orders pronounced between 20 August 2026 and 25 August 2026, all of which engage Section 115B of the Income Tax Act, 1961, alongside a cluster of related provisions — principally the unexplained-income sections (69, 69A, 69C), assessment provisions (143(3), 144, 144B, 147, 148, 148A), and revisionary jurisdiction under Section 263. The rulings span five ITAT benches (Ahmedabad, Delhi, Bangalore, Mumbai, and Jabalpur) and cover a range of assessment years from 2012-13 through 2022-23. The compilation is intended for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a structured reference point for identifying live disputes involving the applicable tax rate on unexplained or deemed income and the procedural framework surrounding such additions.

Research index only. This page is a structured case-law reference, not legal or tax advice. Readers must consult the full text of each judgment and verify the current status of each order — including any stays, appeals, or reversals — before relying on any ruling in a professional context.

The statutory framework in one paragraph

Section 115B of the Income Tax Act, 1961, as it stands in the current statutory scheme, is one of several special rate provisions housed in Chapter XII of the Act, which prescribes tax rates applicable to certain categories of income outside the normal slab-based computation. Practitioners and tribunals frequently engage Section 115B alongside Section 115BBE — the latter being the provision that mandates a flat tax rate (currently 60%, plus surcharge) on income referred to in Sections 68, 69, 69A, 69B, 69C, and 69D of the Act where such income is not satisfactorily explained by the assessee. The interaction between these special-rate provisions and the assessment and revisionary machinery (Sections 143(3), 144, 147, 263, etc.) is the central tension reflected across the rulings indexed in this compilation. The statutory text of all referenced sections should be read from the official consolidated version of the Income Tax Act, 1961, as amended.

The 12 rulings

1. Mitesh Shah,Ahmedabad vs ITO, Ward 1(2)(3), Ahmedabad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 25 August 2026
Sections engaged: 115B, 263, 37(1), 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed against an order dated 18-03-2026 passed by the Principal Commissioner of Income Tax-1, Ahmedabad under Section 263 of the Act, relating to Assessment Year 2019-20. Per the source preview, the assessee had filed a return of income admitting total income of Rs. 17,23,300/-, and consequent to receipt of information indicating bogus purchases of Rs. 40,80,71,780/-, a reopened assessment was completed determining substantially higher assessed income; the revisionary order under Section 263 arising from that assessment is the subject of the appeal before the Tribunal in ITA No. 1304/Ahd/2026.

2. Jay Ace Technologies Ltd,Delhi vs DCIT, Central Circle-13, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 August 2026
Sections engaged: 115B, 143(3), 263, 68
Outcome: Outcome not specified in source
Procedural / substantive ground: The source preview reflects a consolidated set of appeals (ITA Nos. 3220 to 3224/DEL/2024) for Assessment Year 2013-14, involving multiple related entities — including Jay Ace Technologies Limited (PAN: AACCJ2030N) — all arrayed against DCIT, Central Circle 13, New Delhi. The appeals appear to arise from assessment orders and related proceedings engaging Sections 143(3), 263, and 68; the substantive details of the Tribunal's findings are not further elaborated in the available source preview.

3. Asia International Advertisement & vs DCIT, Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 August 2026
Sections engaged: 115B, 250
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 5064/Del/2026 was filed by the assessee challenging an order passed by the Commissioner of Income Tax (Appeals) under Section 250 of the Act for Assessment Year 2013-14. Per the source preview, the appeal was accompanied by a condonation application, as the appeal was filed with a delay of 369 days beyond the prescribed limitation period; the Tribunal's ruling on the condonation application and the substantive grounds are not further elaborated in the available preview.

4. Prakash Palgota ,Hubli vs DCIT Circle-1(1) & Tps, Hubli

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 24 August 2026
Sections engaged: 115B, 143(3), 144B, 194A, 40(a), 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 2710/BANG/2025 relates to Assessment Year 2022-23 and was heard by the Bangalore Bench. Per the source preview, the Tribunal's order explicitly notes that "the orders passed are bad in law and such orders are liable to be quashed," indicating a finding adverse to the Revenue on the validity of the impugned assessment orders, which engaged multiple provisions including Sections 143(3), 144B, and 69C.

5. Moon Herbal Laboratories Private vs ITO Ward-17(3), Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 24 August 2026
Sections engaged: 115B, 143(3), 145
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 4550/Del/2025) was preferred against an order of NFAC, Delhi dated 3.7.2025, which arose from an assessment order dated 30.12.2019 under Section 143(3) for Assessment Year 2017-18. Per the source preview, a ground of appeal contests an addition of Rs. 1,57,46,344/- characterised as being made on false assumption and presumption, with the assessee contending that the addition is mathematically wrong on facts; the Tribunal's resolution of this ground is not further elaborated in the available preview.

6. Veeraganti Subbaraju vs Income Tax Officer Ward 5(1)(1)

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 21 August 2026
Sections engaged: 115B, 142(1), 143(2), 144, 144B, 147, 148, 148A, 234F, 249, 250, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 2545/BANG/2026 was filed against an impugned order dated 02/02/2025, relating to Assessment Year 2020-21. The breadth of sections engaged — spanning reassessment initiation under Sections 147, 148, and 148A, faceless assessment machinery under Section 144B, best-judgement assessment under Section 144, and appellate procedure under Sections 249 and 250 — indicates a dispute involving multiple procedural challenges to the reassessment proceedings; the substantive findings of the Tribunal are not further elaborated in the available source preview.

7. Mahesh Singh Baghel,Shadol vs Income Tax Officer, Shadol

Bench: Income Tax Appellate Tribunal - Jabalpur
Date: 21 August 2026
Sections engaged: 115B, 69
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 165/JAB/2025 for Assessment Year 2012-13, the assessee had not filed any income tax return for the year under consideration. Per the source preview, the AO received information through AIR that the assessee had deposited cash of Rs. 13,00,000/- in a bank account with Central Bank of India, Shahdol, and accordingly the assessment was reopened; the AO proceeded to treat Rs. 13,00,000/- as unexplained investment under Section 69 and also subjected the addition to tax under Section 115BBE of the Act, a position upheld by the CIT(A), leading to the present appeal before the Tribunal.

8. Creative Thinks Media Private vs Assessing Officer, Circle 4(2), Cr

Bench: Income Tax Appellate Tribunal - Delhi
Date: 21 August 2026
Sections engaged: 115B, 143(3), 144B, 263, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 2724/Del/2025 for Assessment Year 2021-22, the source preview reveals that the PCIT, upon examination of assessment records, found that the assessee had made substantial purchases of Rs. 2,818.00 lakh in FY 2020-21; in the absence of basic verification documents, the AO had made an addition of 25% of the said purchases (Rs. 704.50 lakhs) taxed at normal rates, whereas the PCIT took the view that the purchases being bogus, 100% thereof should have been disallowed, leading to revision proceedings under Section 263 that are the subject of the appeal.

9. Siriwara Sanna Rudrappa,Kappagal vs Income Tax Officer, Ward 1, Ballari

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 21 August 2026
Sections engaged: 115B, 127, 133(6), 142(1), 144, 250, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 1071/BANG/2026 relates to Assessment Year 2017-18 and was filed before the Bangalore Bench against an order under Section 250 of the Act. The sections engaged suggest proceedings that involved transfer of jurisdiction under Section 127, notices or requisitions under Section 133(6) and Section 142(1), a best-judgement assessment under Section 144, and an unexplained money addition under Section 69A; the substantive findings of the Tribunal are not further elaborated in the available source preview.

10. Prime Mine O Jewels Private Ltd,Mumbai vs ITO Ward 5(2)(1), Mumbai, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 20 August 2026
Sections engaged: 115B, 143(3), 147, 250, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 3212/Mum/2026) for Assessment Year 2019-20 was preferred against the order dated 05.01.2026 passed by the CIT(A), NFAC, Delhi. Per the source preview, the addition made by the Assessing Officer under Section 69C of the Act was the subject of the CIT(A)'s order, and the assessee's challenge to the confirmation of that addition — arising from an assessment framed under Sections 143(3) and 147 — is the matter before the Tribunal.

11. Kalpesh Harish Ahuja,Ulhasnagar vs Income Tax Officer, Ward 2(2), Kalyan

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 20 August 2026
Sections engaged: 115B, 143(1), 144, 147, 250, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The source preview reflects two consolidated appeals (ITA 6088/MUM/2026 for Assessment Year 2016-17 and ITA 6090/MUM/2026 for Assessment Year 2017-18) pertaining to the same assessee, arising from orders of NFAC, Delhi passed under Section 250 of the Act. The sections engaged indicate that the matters involve unexplained money additions under Section 69A, with assessments framed or reopened under Sections 143(1), 144, and 147; the Tribunal's substantive findings are not further elaborated in the available source preview.

12. Lilaran And Sons Private Limited,Katni vs ACIT Central Circle, Jabalpur

Bench: Income Tax Appellate Tribunal - Jabalpur
Date: 20 August 2026
Sections engaged: 115B, 40(b), 68, 69, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: In ITA No. 67/JAB/2025 for Assessment Year 2020-21, the assessee had filed a return declaring total income of Rs. 28,81,668/-; per the source preview, a survey action under Section 133A was carried out at the assessee's business premises on 06.03.2020, during which the assessee voluntarily offered excess stock of Rs. 21,13,417/- and excess cash of Rs. 5,12,744/- as undisclosed income. The AO, while framing the assessment under Section 143(3), accepted the return of income but directed that tax on the surrendered income be charged at 60% with surcharge at 25% by invoking Section 115BBE of the Act, which forms the core dispute before the Tribunal.

Patterns across these 12 rulings

Section 115B as a gateway citation alongside 115BBE. Across all twelve cases, Section 115B appears as a cited provision in conjunction with unexplained-income sections (69, 69A, 69C, 68). This pattern reflects that disputes about the applicable tax rate on unexplained or deemed income invariably require the Tribunal to examine both the special-rate charging framework and the underlying addition provisions together.
Bogus-purchase and unexplained-expenditure additions under Section 69C recur across multiple benches. Cases 1 (Mitesh Shah, Ahmedabad), 4 (Prakash Palgota, Bangalore), 8 (Creative Thinks Media, Delhi), and 10 (Prime Mine O Jewels, Mumbai) all engage Section 69C in the context of disputed purchase transactions, suggesting that bogus-purchase additions remain a high-frequency trigger for litigation over the applicable tax rate and the extent of disallowance.
Revisionary jurisdiction under Section 263 generates a distinct sub-stream. Cases 1, 2, and 8 involve orders passed under Section 263 by the PCIT/CIT, with the assessee challenging the revision before the Tribunal. The common thread is a disagreement between the original AO and the PCIT on the quantum of disallowance or the rate of tax applicable to the disputed income.
Reassessment procedure provisions (147, 148, 148A) feature prominently in cases involving non-filers or cash-deposit information. Cases 6 (Veeraganti Subbaraju), 7 (Mahesh Singh Baghel), 10 (Prime Mine O Jewels), and 11 (Kalpesh Harish Ahuja) all engage reassessment machinery alongside Section 115B, indicating that the special-rate dispute frequently arises at the reassessment stage where information from AIR or other sources triggers the reopening.
Delay-condonation and procedural admissibility issues co-exist with substantive rate disputes. Case 3 (Asia International Advertisement) illustrates that even in Section 115B-linked matters, threshold procedural questions — such as a 369-day delay in filing the appeal before the CIT(A) — can occupy the Tribunal before any substantive rate question is reached, underscoring the layered procedural complexity of this category of litigation.

How to use this compilation

This index is organised by pronouncement date (most recent first within each bench) and is intended as a starting point for identifying live ITAT disputes that engage Section 115B and related unexplained-income provisions. Researchers should use the ITA numbers, PAN references, and bench identifiers listed in each entry to retrieve the full text of each order from the official ITAT website (ITAT.gov.in), the Income Tax Department's e-filing portal order-lookup tools, or indiankanoon.org. The text previews reproduced here are partial extracts from source data and do not represent the complete operative portions of any order.

Before placing reliance on any ruling listed in this compilation, researchers must verify: (a) whether the order has been appealed to the High Court or Supreme Court and whether any stay has been granted; (b) whether the order has been recalled, modified, or subject to miscellaneous application proceedings before the same Tribunal bench; and (c) whether CBDT has issued any circular, instruction, or notification that modifies the statutory provisions engaged by the ruling, including any amendments to the Finance Act that may alter the applicable tax rate under the relevant charging sections.

Researchers should also note that all twelve orders indexed here record "Outcome not specified in source" — meaning the dispositive direction (allowed, dismissed, partly allowed, remanded) has not been captured in the structured data extract available to this database at the time of publication. The full operative paragraph of each order must be read from the primary source before any conclusion is drawn about the outcome.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 115BBE & 115B: 12 ITAT Rulings on Unexplained Income Tax Rate Disputes (2026)