ASST. COMMISSIONER OF INCOME TAX, CHENNAI vs. TRUE FRIEND MANAGEMENT SUPPORT SERVICES PVT LTD, CHENNAI
What were the facts?
The Revenue appealed against the deletion of additions made by the AO on account of software maintenance service costs paid to a foreign entity. The AO disallowed the expenses, alleging sham transactions designed to move trust funds out of India. The CIT(A) deleted the disallowance, finding the payments genuine.
What did the Tribunal hold?
The Tribunal held that the AO's observation that the transactions were sham was contrary to the facts on record, citing email evidence of services rendered and training provided by the foreign entity. The Tribunal also found the allegation of fund diversion to family members factually incorrect.
What were the issues?
Whether the expenses claimed for software maintenance services to a related foreign entity were genuine or sham transactions, and whether the CIT(A) was justified in deleting the AO's disallowance.
Which sections of the Income-tax Act were involved?
Section 143(2),Section 142(1),Section 139(5),Section 143(3),Section 153B(1)(b)
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, ‘B’ BENCH: CHENNAI
Before: HON’BLE SHRI INTURI RAMA RAO & BEFORE SHRI SS VISWANETHRA RAVI
Heard together (3 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER SS VISWANETHRA RAVI, J.M :
These three appeals by the Revenue are against the separate
orders dated 08.09.2025, passed by the Learned Commissioner of Income
Tax [herein after “CIT(A), Chennai-20, for the assessment years 2019-20,
2020-21 & 2021-22, respectively.
ITA No. 3642, 3643 & 3644 /Chny/2025
2
The order continues below.
Read the full judgment
A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.
The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.
More judgments on Section 142(1)
- Assistant Commissioner of Income Tax… vs M/S Rajguru Foods, BijapurITA 77/PAN/2025[2018-19]Status: Disposed9 Oct 2026AY 2018-19
- S R P Jutha 13 Rajkot VI and Gr S Ma, Rajkot vs ITO WD 1(2)(1) Rajkot, RajkotITA 951/RJT/2025[2017-18]Status: Disposed9 Oct 2026AY 2017-18
- Dineshkumar Chhaganlal Manavadaria, Junagadh vs ITO Ward 1, JunagadhITA 837/RJT/2025[2020-21]Status: Disposed9 Oct 2026AY 2020-21
- Shri Dineshkumar Chhaganlal Manavadaria… vs Income Tax Officer, Ward - 1, JunagadhITA 836/RJT/2025[2019-20]Status: Disposed9 Oct 2026AY 2019-20
- Rajeshkumar Shah, Navagam, Udhana vs Income Tax Officer, AdajanITA 283/SRT/2026[2022-23]Status: Disposed9 Oct 2026AY 2022-23
Recent GST High Court judgments
Search GST case law →- Shaik Mohammed Abdul Jabbar vs. The Principal Commissioner/CommissionerTelangana · 7 Oct 2026
- Kamalakanta Nayak vs. The Additional CT And GST Officer, Mayurbhanj Circle,BalasoreOrissa · 7 Oct 2026
- Jagadish Prasad Agrawala vs. State Of OdishaOrissa · 7 Oct 2026
- M/S.Shree Jagannath Engineering Co.,Kendujhar vs. Assistant Commissioner Central GST And Customs, KeonjharOrissa · 7 Oct 2026
- Gagan Kumar Das vs. State Tax Officer, CT And GST Jagatsinghpur CircleOrissa · 7 Oct 2026
