ITAT Chennai Judgments — September 2025

The Tribunal held that the notice for reopening was invalid as it was issued by the jurisdictional AO instead of the Faceless Assessment Mechanism, as mandated by the e-assessment scheme. Consequently, the assessment order was also deemed invalid.

The Tribunal held that the issue is covered by previous decisions. While the assessee provided a Tax Residency Certificate (TRC) from the US as additional evidence, the Assessing Officer needs to verify its genuineness.

The ITAT held that the CIT(Exemptions) erred in rejecting the registration application by delving into issues of taxability, which is beyond his scope at the registration stage. The Tribunal found that the assessee's activities fall within the ambit of 'advancement of any other object of general public utility'.

The Tribunal noted that the AO passed an ex-parte order and the CIT(A) dismissed the appeal due to non-participation. To meet the ends of justice, the Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for de novo assessment.

The Tribunal condoned the delay in filing the appeal due to the assessee's lack of awareness of online compliance. The Tribunal noted errors in the CIT(A)'s order and, to meet the ends of justice, set aside the CIT(A)'s order.

The Tribunal noted that for registration under Section 12AB, the CIT(E) can only verify the genuineness of activities and compliance with other laws, not conduct a detailed assessment. The appeal was filed against the CIT(E)'s order.

The Tribunal allowed the assessee's claim for provision for customer loyalty, finding it to be based on a scientific method. Regarding transfer pricing, the Tribunal deleted the adjustment made by the TPO, stating that the TPO's approach of comparing net margins without considering differences in product mix and market dynamics was not in accordance with established principles.

The Tribunal held that the reassessment proceedings were initiated without proper sanction from the competent authority as prescribed under Section 151 of the Act. Consequently, the reassessment order was considered invalid, and the PCIT's revisionary order was also set aside.

The Tribunal held that the reassessment was initiated based on the same material available during the original assessment and amounted to a mere change of opinion, which is impermissible. The reassessment proceedings were quashed.

The Tribunal held as follows: 1. On the issue of provision for consumer loyalty: The assessee's method of creating provisions based on an estimated percentage of redemption, derived from analyzing customer redemption trends, is considered scientific. The Tribunal noted that any excess provision is offered to tax. Citing the principle of consistency and the scientific basis of the provision, the Tribunal allowed the deduction, following its own order in the assessee's case for earlier AYs and the Supreme Court's decision in Rotork Controls India Pvt. Ltd. The Tribunal stated that the provision is an allowable deduction. 2. On the issue of disallowance under Section 14A: The judgment does not record the Tribunal's specific finding or reasoning on this issue for the assessment years under appeal. It only refers to the assessee's grounds and the AO's action. The detailed discussion on Section 14A appears to be from an earlier assessment year (AY 2009-10) in the context of the assessee's own case, but the final decision for AYs 2013-14 and 2014-15 on this point is not explicitly stated. 3. On the issue of transfer pricing adjustment related to Section 80IC: The Tribunal found that the assessee had undertaken a detailed TP study using TNMM. It held that the TPO's approach of comparing net margins without considering differences in product mix, production processes, and market dynamics was not in accordance with established TP principles. The Tribunal noted that the assessee provided segmental P&L accounts showing variations were due to product mix. It also found that benchmarking inter-unit transfers of semi-finished goods against third-party sales of finished goods was inappropriate. The Tribunal deleted the TP adjustment of Rs. 63,17,93,601/- for AY 2014-15, relying on the principle of consistency and various case laws, including Radhasoami Satsang vs CIT.

The Tribunal held that the non-deposit of unutilized sale consideration in the capital gains account scheme before the due date of filing the return is not fatal and does not warrant denial of deduction under Section 54. The assessee had invested the sale proceeds within the stipulated period.

The Tribunal held that the notice issued under Section 148 by the JAO was invalid, making the subsequent reassessment order void. Consequently, the PCIT's revision order, which interfered with a void order, was also deemed null and void.

The tribunal held that the AO's action to reopen the assessment was without jurisdiction because it was not based on any tangible material that came into possession after the original assessment order. The reopening was based on a review of existing records, which amounts to a change of opinion.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal held that the assessees had a reasonable cause for not complying with the notice as they were pursuing settlement proceedings and had obtained legal advice. Furthermore, subsequent developments, including the quashing of assessment orders by the High Court, supported the deletion of penalties.

The Tribunal condoned the delay, considering it a matter of natural justice. The impugned order was set aside, and the appeal was restored to the CIT(A) for hearing on merits.

The Tribunal condoned the delay in filing the appeal. The Tribunal noted that the First Appellate Authority (FAA) passed an ex-parte order without considering the assessee's detailed explanation. Therefore, the matter was restored to the FAA for fresh adjudication to provide the assessee an opportunity of being heard.

The Tribunal noted the FAA's ex-parte order and the assessee's failure to respond to notices, but also acknowledged that the assessee's submissions were not considered. The matter was restored to the FAA for fresh adjudication.

The Tribunal held that the FAA has no jurisdiction to dismiss an appeal for non-compliance without adjudicating on merits. The FAA is bound to decide the appeal on merits even in the absence of the assessee.

The Tribunal held that the additional evidence sought to be admitted (patta, chitta, adangal extracts) regarding the agricultural nature of the lands sold was necessary for adjudication. The Tribunal also noted that the FAA had erroneously referred to irrelevant sections of the Act.

The Tribunal held that the disallowance of Rs. 16,84,761/- was erroneous. The loss was incurred due to employee fraud, substantiated by a police complaint and journal entries, and was allowable as bad debt under Section 36(1)(vii) and as a business loss under Section 37(1).

The Tribunal noted that the assessee did not appear, did not file an adjournment petition, and the appeal was filed with a considerable delay without a condonation petition. Therefore, the appeal was deemed not maintainable and was dismissed.

The Tribunal condoned the delay in filing the appeal before the FAA, considering the reason provided by the assessee (auditor's demise) as reasonable. The Tribunal set aside the order of the FAA and remitted the matter back to the AO for fresh adjudication.

The Tribunal condoned the delay after finding sufficient cause. However, it noted that the First Appellate Authority's order was ex-parte due to non-compliance with notices. The Tribunal restored the matter to the AO for fresh adjudication, imposing a cost of Rs. 10,000/- on the assessee.

The Tribunal held that while the assessee had the donor details in its books, it failed to produce them during assessment and provided only an uncertified list during appeal. However, in the interest of justice, one more opportunity is granted.

The Tribunal acknowledged the assessee's non-compliance and the resulting ex-parte orders but, in the interest of justice, restored the matter to the AO for fresh adjudication. This was conditioned upon the assessee paying a cost of Rs. 5,000/-.

The Tribunal noted the assessee's nonchalant attitude but, in the interest of justice, decided to restore the matter to the AO. This was conditional upon the assessee paying a cost of Rs. 10,000/- to the Tamil Nadu State Legal Services Authority.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to reasonable cause and health reasons. The case was remitted back to the CIT(A) for fresh adjudication on merits after providing a reasonable opportunity to the assessee.

The Tribunal held that the impugned sum was received as an advance for land purchase, as confirmed by the payer's documentation. The Revenue failed to provide corroborative material to establish it as commission income. Therefore, the deletion of the addition by the Ld. CIT(A) was upheld.

The Tribunal noted that the assessee's Authorized Representative (AR) had filed a letter seeking withdrawal of the appeal, stating it was filed before the wrong bench. Consequently, the Tribunal dismissed the appeal as withdrawn.

The tribunal condoned the delay in filing the appeals, finding it non-wilful and due to circumstances beyond the assessee's control, including improper service of notices for the CIT(A) proceedings. Citing the interest of justice, the tribunal set aside all ex-parte orders of the CIT(A) and remitted the matters back for fresh adjudication on merits, with a direction for the assessee to be diligent.

The tribunal condoned the delay in filing the appeals, finding it non-wilful and due to circumstances beyond the assessee's control, including improper service of notices for the CIT(A) proceedings. Citing the interest of justice, the tribunal set aside all ex-parte orders of the CIT(A) and remitted the matters back for fresh adjudication on merits, with a direction for the assessee to be diligent.

The tribunal condoned the delay in filing the appeals, finding it non-wilful and due to circumstances beyond the assessee's control, including improper service of notices for the CIT(A) proceedings. Citing the interest of justice, the tribunal set aside all ex-parte orders of the CIT(A) and remitted the matters back for fresh adjudication on merits, with a direction for the assessee to be diligent.

The tribunal condoned the delay in filing the appeals, finding it non-wilful and due to circumstances beyond the assessee's control, including improper service of notices for the CIT(A) proceedings. Citing the interest of justice, the tribunal set aside all ex-parte orders of the CIT(A) and remitted the matters back for fresh adjudication on merits, with a direction for the assessee to be diligent.

The Tribunal held that interest on enhanced compensation for compulsory acquisition of agricultural land partakes the character of compensation itself and is thus eligible for exemption under Section 10(37) of the Income Tax Act. Consequently, Section 56 of the Act is not attracted.

The Tribunal held that the scope of Section 154 is limited and does not permit inquiries or verification. Therefore, the AO could not be faulted for not conducting such inquiries before passing the rectification order. The PCIT's direction to conduct further inquiries under Section 263 was also found to be beyond statutory powers.