ALAGESAN SELVARAJ,CHENNAI vs. INCOME TAX OFFICER, CHENNAI

ITA 717/CHNY/2026Status: DisposedITAT Chennai28 September 2026AY 2023-20243 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that considering the submissions of the assessee's authorized representative and the additional evidence filed, it was proper to remand the matter to the file of the AO for fresh consideration. The AO was directed to consider the additional evidence and pass an order in accordance with the law. The assessee was granted liberty to file further evidence in support of the claim. Consequently, the order of the CIT(A) was set aside, and the grounds raised by the assessee were allowed for statistical purposes. The Tribunal did not decide on the merits of the depreciation claim itself but rather on the procedural aspect of allowing the AO to re-examine the matter with the additional evidence.

What were the facts?

The assessee, Alagesan Selvaraj, filed an appeal against the order dated 12.12.2025 passed by the Commissioner of Income Tax (Appeals), Delhi, for the assessment year 2023-24. The appeal concerns the disallowance of depreciation on machinery. The Assessing Officer (AO) selected the case for scrutiny to examine a large additional depreciation claim. However, the AO disallowed the depreciation as claimed due to the absence of documentary evidence supporting the asset/block, opening WDV, additions, deletions, depreciation charged, details of additional depreciation, date of purchase, and date of put to use for assets acquired during the year. The CIT(A) confirmed the AO's order for non-submission of required documents proving installation and use of the machinery.

What were the issues?

1. Whether the Tribunal had to decide on the validity of disallowing depreciation on machinery due to lack of documentary evidence regarding its installation and put to use. Assessee's contentions: The assessee argued that a certificate regarding the inspection and valuation of the machinery at the borrower's factory site, filed as additional evidence (page 67 of the paper book), was not available before the AO and the CIT(A). The assessee prayed for the matter to be remanded to the AO for fresh examination. Revenue's contentions: The Revenue, represented by the ld. DR, reported no objection to the assessee's prayer.

Which sections of the Income-tax Act were involved?

Section 68

AI-generated summary — verify with the full judgment below

आयकरअपीलीयअिधकरण, ’ए’ "ायपीठ,चे"ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ीयस यस िव"ने" रिव, "ाियक सद" एवं सु"ीपदमावती यस, लेखा सद"के सम" BEFORE SHRI SS VISWANETHRA RAVI, JUDICIAL MEMBER AND MS. PADMAVATHY.S, ACCOUNTANT MEMBER आयकरअपीलसं./I.T.A.No.717/Chny/2026 िनधा"रणवष"/Assessment Year: 2023-24 No.6-B, Dr. Moorthy Nagar, Padi, Chennai. Chennai-600050, Chennai. [PAN: AMFPS7310E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/ Appellant by : Ms. Sharon Elizabeth, Advocate ""थ"कीओरसे/ Respondent by Ms. Anshu Sharatwat, Addl. CIT : सुनवाईकीतारीख/Date of hearing : 24.09.2026 घोषणाकीतारीख /Date of Pronouncement 28.09.2026 : आदेश /O R D E RJ PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

This appeal filed by the assessee is directed against the order dated 12.12.2025 passed by the ld. Commissioner of Income Tax (Appeals), Delhi for the assessment year 2023-24. 2. At the outset, Ld. AR, Ms. Sharon Elizabeth, Advocate, drew our attention to the paper book at page No. 67 of the paper book and submits that the certificate issued by the competent authority regarding the inspection and valuation of the machinery at the factory site of the bo

The order continues below.

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