INCOME TAX OFFICER, CHENNAI vs. SHRI CHINNASAMY RAMACHANDRAN (DECEASED) L/H GOWTHAM CHANDHAR, CHENNAI

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ITA 1634/CHNY/2026Status: DisposedITAT Chennai03 August 2026AY 2016-178 pages
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What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal. The appeal was then disposed of on merits, with the Revenue challenging the deletion of an addition made under Section 56(2)(vii)(b) and the allowance of deduction under Section 80TTA.

What were the facts?

The Revenue filed an appeal against the CIT(A)'s order, which was delayed by 83 days. The assessee, a HUF, had declared a total income of Rs. 4,18,440/- for AY 2016-17. The Assessing Officer had made an addition of Rs. 2,62,50,000/-.

What were the issues?

Whether the CIT(A) erred in deleting the addition made under Section 56(2)(vii)(b) and allowing deduction under Section 80TTA without proper evidence and opportunity to the AO.

Which sections of the Income-tax Act were involved?

Section 56(2)(vii)(b),Section 80TTA,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & MS PADMAVATHY S

Hearing: 28.07.2026Pronounced: 03.08.2026

आयकर अपील"य अ"धकरण, ‘बी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी जॉज" जॉज" के, उपा"य" एवं सु"ी प"मावती एस, लेखा सद"य के सम" BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND MS PADMAVATHY S, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.: 1634/CHNY/2026 "नधा"रण वष"/Assessment Year: 2016-17 The Income Tax Officer, Late Shri Chinnasamy Non-Corporate Ward 1(6), Vs. Ramachandran Chennai. Rep. by L/H Gowtham Chandhar, New No.3, Old No.1, First Trust Link Street, Mandaveli, Chennai – 600 028. PAN: AAIHR 4930E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Ms. D. Nithya, Addl. CIT ""यथ" क" ओर से/Respondent by : Ms. R. Pushpavalli, IT Consultant सुनवाई क" तार"ख/Date of Hearing : 28.07.2026 घोषणा क" तार"ख/Date of Pronouncement : 03.08.2026 आदेश/ O R D E R PER GEORGE GEORGE K, VICE PRESIDENT: This appeal filed by the Revenue is directed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 17.10.2026 passed under section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2016-17. Late Shri Chinnasamy Ramachandran 2. The appeal filed by the Department is delayed by 83 days. The AO has filed an affidavit stating therein the reasons for belated filing of the appeal. On perusal of the reasons stated in the condonation petition, we are of the view that there is sufficient cause for late filing of the appeal and no latches can be attributed to the Department. Hence, we condone the delay in filing the appeal and proceed to dispose off the appeal on merits.

3.

The grounds raised by the Revenue read as under:- i) The order of the Ld. CIT(A) is contrary to law and facts of the case. ii) The Ld. CIT(A) erred in deleting the addition of Rs. 2,62,50,000/- made u/s 56(2)(vii)(b) of the Act. iii) The Ld. CIT(A) failed to appreciate that the assessee had not furnished necessary evidences during assessment proceedings to establish that the property did not belong to the HUF. iv)The Ld. CIT(A) erred in admitting and relying upon additional evidences in violation of Rule 46A of the Income Tax Rules, 1962 without affording opportunity to the Assessing Officer. v)The Ld. CIT(A) erred in allowing deduction u/s 80TTA without verifying eligibility in the absence of proper examination during assessment. vi) For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the learned CIT(A) may be set aside and that of the Assessing Officer restored.

4.

Brief facts of the case are as follows: The assessee is a HUF. For the assessment year 2016-17, the assessee filed its return of income on 12.10.2016 declaring total income of Rs.4,18,440/-. Subsequently, based on information received by the Revenue, it was noticed that an immovable property had been Late Shri Chinnasamy Ramachandran purchased for a consideration of Rs.10,00,000/-, whereas the value adopted by the Sub-

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