This compilation indexes twelve orders pronounced by Income Tax Appellate Tribunals across India during September 2026 in which Section 44A of the Income Tax Act, 1961 appears among the sections cited. The rulings span multiple benches — Rajkot, Jaipur, Ahmedabad, Mumbai, Vizag, Pune, Hyderabad, Chennai, and Bangalore — and engage a wide range of substantive issues including reassessment validity, TDS defaults, unexplained cash deposits, penalty proceedings, and procedural grounds such as condonation of delay. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a structured starting point for locating recent ITAT orders touching Section 44A.

Disclaimer: This page is a structured research index, not legal or tax advice. All summaries are drawn from publicly available source previews. Readers must verify against the full judgment text, check for any stays or reversals, and consult qualified professionals before relying on any ruling.

The statutory framework in one paragraph

Section 44A of the Income Tax Act, 1961 governs the application of the provisions of the Act to certain associations of persons and bodies of individuals, providing that where the assessee is such an association or body, the tax chargeable shall be determined in the manner prescribed, ensuring that the income of such entities is computed and assessed in accordance with the general scheme of the Act. The section operates as an enabling and bridging provision that brings specific types of entities within the broader charging and procedural framework of the Act. Researchers should note that Section 44A frequently appears alongside substantive provisions — such as those dealing with reassessment, unexplained income, and TDS — because it is cited as part of the statutory basis for jurisdiction and computation in orders that primarily engage those other provisions.

The 12 rulings

1. Pratikkumar Shashikantbhai vs Income Tax Officer Ward -1(1)(1)

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 15 September 2026
Sections engaged: 115B, 147, 250, 44A, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed against an assessment order passed under Section 147 of the Act, dated 17.09.2021, which was subsequently upheld by the National Faceless Appeal Centre (NFAC), Delhi / Commissioner of Income-tax (Appeals) by order dated 22.05.2026. Per the source preview, the assessee raised the ground that the reopening was bad in law, without jurisdiction, and not sustainable, making jurisdictional validity of the reassessment the central issue before the Tribunal in ITA No. 895/Rjt/2026 for Assessment Year 2013-14.

2. Parvej Sheikh,Jaipur vs ITO Wd 1(4), Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 15 September 2026
Sections engaged: 250, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal before the Tribunal in ITA No. 1885/JPR/2025 for Assessment Year 2018-19 was delayed by 53 days in filing, and the assessee filed a condonation of delay application. Per the source preview, it was submitted that the delay occurred due to a change in counsel/professional consultant and the consequent time taken by the assessee in obtaining proper professional advice regarding the appellate proceedings; the Tribunal considered the submissions and the application for condonation before proceeding on merits.

3. Voltamp Transformers Ltd.,Ahmedabad vs The DCIT, TDS Circle, Vododara

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 14 September 2026
Sections engaged: 133A, 194C, 194C(6), 201(1), 250, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 797/AHD/2026 for Assessment Year 2021-2022 was directed against the order dated 27/01/2026 passed by the Commissioner of Income Tax (Appeals), ADDL/JCIT(A) — Faridabad under Section 250, whereby the CIT(A) had dismissed the appeal against the order dated 19/06/2023 passed by the Assessing Officer under Section 201 and 201(1A) of the Act. The matter accordingly involves a TDS-related default proceeding, with the Tribunal examining the challenge to the CIT(A)'s dismissal order.

4. Bhagwandas Parvani,Nadiad vs Income Tax Office, , Nadiad

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 14 September 2026
Sections engaged: 115B, 139(1), 144, 147, 148, 274, 44A, 69C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 674/AHD/2026 for Assessment Year 2020-2021 was preferred against the order dated 23/09/2025 of the NFAC, Delhi, which had dismissed the appeal against an assessment order dated 27/03/2025 passed under Section 147 read with Section 144 of the Act. The source preview further notes a delay of 93 days in filing the present appeal before the Tribunal, with the Tribunal recording that it took into consideration the explanation offered by the assessee for the delay.

5. Hetaal Jaswantrai Parekh,Mumbai vs Income Tax Officer, Wd-33(1)(5)

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 11 September 2026
Sections engaged: 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed as ITA 4294/MUM/2026 for Assessment Year 2017-18 before the SMC Bench of the Mumbai Tribunal. The source preview is primarily procedural in nature, setting out the cause title, party addresses, representative details, and dates of hearing and pronouncement; no substantive ground or holding is discernible from the available preview text.

6. Bhupendra Meena,Jaipur vs ITO, Ward-1(1), Jaipur, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 10 September 2026
Sections engaged: 250, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 918/JPR/2026 for Assessment Year 2016-17 was filed against the order of the NFAC, Delhi dated 06.02.2026 under Section 250. Per the source preview, the solitary issue in the appeal relates to cash found deposited in the bank account of the assessee to the tune of Rs. 40,99,325/-, the source of which remained allegedly unexplained; the preview further notes that this was the second round before the Tribunal, as in the first round the ITAT had restored the matter back to the Assessing Officer to consider the explanation of the assessee afresh.

7. Shri Hitesh Ugamraj Mehta ,Mumbai vs Assessing Officer- 23.1.6, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 9 September 2026
Sections engaged: 131, 133(6), 145(3), 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 223/MUM/2026 for Assessment Year 2022-2023 was filed against the order of the NFAC, Delhi (Order No. ITBA/NFAC/S/250/2025-26/1082454734(1) dated 11.11.2025), which was passed against the assessment order by the Assessment Unit, Income Tax Department, for Assessment Year 2022-23. The source preview confirms the matter reached the Tribunal after the second-tier appellate process, with the assessee raising multiple grounds; the substantive content of those grounds is not fully set out in the available preview.

8. Abbayi Sunkara,Anaparthi vs Income Tax Officer, Ward-1, Kakinada

Bench: Income Tax Appellate Tribunal - Vizag
Date: 9 September 2026
Sections engaged: 143(1), 143(3), 269S, 271D, 271E, 273B, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 302/VIZ/2026 for Assessment Year 2017-18 was filed by the assessee before the Visakhapatnam Bench. The source preview is primarily procedural, containing the cause title, party and representative details, and the date of pronouncement; the substantive grounds raised by the assessee are not reproduced in the available preview text.

9. Sayyad Javed Sayyad Khaja Bagawhan vs ITO Wd-1(1), Aurangabad

Bench: Income Tax Appellate Tribunal - Pune
Date: 9 September 2026
Sections engaged: 44A, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 806/PUN/2026 for Assessment Year 2014-15 was directed against the order dated 04-12-2025 of the Commissioner of Income Tax (Appeals). The source preview includes a table listing multiple named trading entities along with amounts in crores, suggesting the matter involves examination of transactions with several counterparties; however, the precise nature of the issue and the Tribunal's holding are not discernible from the available preview text.

10. Aslam Chous,Karimnagar vs ITO, Ward-2, , Karimnagar

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 9 September 2026
Sections engaged: 147, 148, 148A, 149, 151, 153A, 153C, 163, 44A, 69A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 1577/HYD/2026 for Assessment Year 2015-2016 was filed before the SMC Bench, Hyderabad. Per the source preview, one of the grounds raised by the assessee was that the CIT(A), NFAC erred in sustaining an estimation of income at 8% of turnover by invoking section 44AD, without appreciating that the appellant had not opted for the presumptive taxation scheme and that such estimation was made arbitrarily without rejecting the turnover or bringing any cogent material on record; the preview also references a dispute as to whether certain amounts constitute unexplained money.

11. Grs Property Holdings vs ITO, Ward-1,, Kanchipuram

Bench: Income Tax Appellate Tribunal - Chennai
Date: 8 September 2026
Sections engaged: 142(1), 144B, 147, 148, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA No. 3558/Chny/2026 for Assessment Year 2013-14 was directed against the order passed by the NFAC, Delhi dated 17.02.2026, which confirmed the assessment order passed under Section 147 of the Act for AY 2013-14. The source preview notes issues around compliance, with the reassessment framework under Section 147 and the faceless assessment mechanism under Section 144B being the core procedural backdrop of the dispute.

12. Pintu Babulal Purohit,Bangalore vs Income Tax Officer,Ward 5(2)(2)

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 8 September 2026
Sections engaged: 133(6), 139(9), 142(1), 144, 234A, 234B, 250, 44A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal in ITA 136/BANG/2026 for Assessment Year 2017-18 was filed against an order under Section 250, with the source preview indicating that the matter involved a best-judgment assessment under Section 144, interest provisions under Sections 234A and 234B, and inquiries under Section 142(1). The substantive grounds and the Tribunal's holding are not reproduced in the available preview text.

Patterns across these 12 rulings

Reassessment challenges are the most recurrent theme. Cases 1, 4, 11, and 10 all involve proceedings initiated or sustained under the reassessment framework (Section 147 and related provisions). In multiple instances, the assessee challenged the jurisdictional validity of the reopening, reflecting the continued litigation pressure on reassessment orders post the 2021 amendments.
NFAC orders as the immediate trigger for ITAT appeals. Across cases 1, 2, 4, 6, 7, 9, and 11, the immediate order appealed before the Tribunal is an order of the National Faceless Appeal Centre (NFAC), Delhi. This pattern reflects the institutional reality that first-level appellate disposal increasingly flows through the faceless mechanism, making NFAC orders the proximate subject of ITAT scrutiny.
Condonation of delay as a threshold issue. Cases 2 and 4 both surface delay-in-filing issues — 53 days and 93 days respectively — as preliminary hurdles that the Tribunal addressed before reaching the merits. This is a recurring procedural pattern in ITAT matters and signals that limitation compliance remains a practical risk for assessees navigating the appellate hierarchy.
Unexplained income and cash deposit disputes appear in multiple cases. Cases 6, 9, and 10 each touch on disputed cash amounts or alleged unexplained income, with the source data for case 6 specifically noting a cash deposit of Rs. 40,99,325/- whose source was alleged to be unexplained. This cluster of cases indicates that income characterisation disputes remain a significant driver of ITAT litigation.
Diverse geographic spread with Section 44A as a common citation. The 12 rulings span nine distinct ITAT benches across India (Rajkot, Jaipur, Ahmedabad, Mumbai, Vizag, Pune, Hyderabad, Chennai, Bangalore), suggesting that Section 44A is cited as a standard jurisdictional or enabling provision across the country rather than being concentrated in any particular circuit or fact-pattern.

How to use this compilation

This index is a first-level research tool. Each entry above identifies the bench, date, ITA number (where visible in the source preview), assessment year (where stated), sections engaged, and a brief procedural note drawn strictly from the available source text. Researchers should treat this as a pointer list, not as a substitute for reading the full order. The outcome direction for all twelve cases is listed as "Outcome not specified in source," meaning the dispositive result — whether the appeal was allowed, dismissed, partly allowed, or remanded — cannot be confirmed from the preview data alone. Before relying on any of these rulings for a legal position, researchers must retrieve and read the complete order from the relevant court portal (ITAT.nic.in, indiankanoon.org, or the official ITAT upload system).

Researchers should also verify whether any of these orders have been subjected to a further challenge — for example, a writ petition before the relevant High Court or a Special Leave Petition before the Supreme Court — or whether a stay has been granted against the Tribunal's order. Tax litigation at the ITAT level frequently generates parallel proceedings, and an ITAT order that appears final in this index may have been stayed or reversed at a higher forum. Checking the High Court cause-list and the Supreme Court's case status portal for the same parties and assessment years is recommended.

Finally, researchers should cross-reference the statutory provisions cited in each case against the current text of the Income Tax Act, 1961, including any amendments introduced by Finance Acts subsequent to the date of the order, and check for relevant CBDT circulars, instructions, and notifications that may bear on the interpretation of the sections engaged. This is particularly important for provisions relating to reassessment (Sections 147, 148, 148A, 149, 151), TDS defaults (Sections 201, 194C), and penalty proceedings (Sections 271D, 271E, 273B), all of which have seen legislative and administrative activity in recent years.

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 44A Income Tax: 12 ITAT Rulings Across India (Sep 2026)