ITAT Chennai Judgments — October 2025

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs DCIT, INTL TAX CIRCLE-2(1), CHENNAI

ITA 1520/CHNY/2025[2012-13]Status: Disposed29 Oct 2025AY 2012-13Allowed

The Tribunal held that the assessee was not given an effective opportunity of being heard before the CIT(A), which is a violation of the principles of natural justice. The CIT(A) relied on judgments like CIT vs. Sun Engineering Works (P.) Ltd. and DCIT vs. Simplex Concrete Piles (India) Ltd. without allowing the assessee to distinguish them in light of the present case's facts. Furthermore, the CIT(A) did not provide a specific finding on the applicability of the Supreme Court's decision in Engineering Analysis Centre of Excellence (P) Ltd. vs. CIT, as relied upon by the assessee. Consequently, the Tribunal set aside the impugned order and restored the appeals to the file of the CIT(A) for de novo appellate proceedings. The CIT(A) was directed to provide a proper and adequate opportunity of hearing to the assessee and to examine all legal issues afresh. The Tribunal clarified that its decision was not a finding on the merits of the case. All legal issues were kept open.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1806/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs ACIT, CIRCLE 3(1), TRICHY, TRICHY

ITA 1303/CHNY/2025[2011-12]Status: Disposed28 Oct 2025AY 2011-12Remanded

The Tribunal held that the AO's failure to correctly give effect to the CIT(A)'s order constituted a patent error rectifiable under Section 154. The AO's inaction was seen as a disregard of judicial discipline and a misinterpretation of the appellate order.

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs ACIT, CIRCLE 3(1), TRICHY, TRICHY

ITA 1302/CHNY/2025[2010-11]Status: Disposed28 Oct 2025AY 2010-11Remanded

The Tribunal held that the AO's failure to correctly give effect to the CIT(A)'s order constituted a patent error rectifiable under Section 154. The AO's inaction was seen as a disregard of judicial discipline and a misinterpretation of the appellate order.

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs ACIT, CIRCLE 3(1), TRICHY, TRICHY

ITA 1300/CHNY/2025[2008-09]Status: Disposed28 Oct 2025AY 2008-09Remanded

The Tribunal held that the AO's failure to correctly give effect to the CIT(A)'s order constituted a patent error rectifiable under Section 154. The AO's inaction was seen as a disregard of judicial discipline and a misinterpretation of the appellate order.

DAR E IMAAN WELFARE AND EDUCATIONAL TRUST,VELLORE vs ITO, EXEMPTION WARD,, CHENNAI

ITA 2259/CHNY/2025[2019-20]Status: Disposed28 Oct 2025AY 2019-20Allowed

The Tribunal held that the expenditure incurred for stationery and books, supported by vouchers acknowledged by the recipient, cannot be treated as unexplained expenditure. The order of the CIT(A) was found to be not justified.

RAJASEKAR DHANAPAL,KANCHEEPURAM vs ITO, NCW-22(1), TAMBARAM

ITA 2299/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Partly Allowed

The Tribunal held that the Revenue failed to provide evidence of service of notice or the impugned order. Consequently, it was held that there was no delay in filing the appeal. The Tribunal also noted additions made under Section 69A of the Act.

ARULMIGU THIRUMALAI KUMARASWAMY THIRUKOIL,TIRUNELVELI vs ITO, EXEMPTIONS WARD,, TIRUNELVELI

ITA 2210/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Partly Allowed

The Tribunal held that the CIT(A) ought to have condoned the delay, considering the facts and circumstances, and decided the appeal on merits. The impugned order was set aside, and the matter was remitted to the CIT(A).

IRUTHAYARAJ PRAKASH KUMAR ANTHONY,CHENNAI vs NON.CORP WARD 3(3) CHE, CHENNAI

ITA 2225/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Partly Allowed

The Tribunal condoned the delay in filing the appeal and noted the assessee's negligence. However, in the interest of natural justice, the Tribunal decided to grant one more opportunity to the assessee to substantiate their case.

GOKULDASS SRINIVASAN,UDUMALAIPETTAI vs ITO, WARD-2(4), TIRUPPUR

ITA 2230/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Allowed

The tribunal noted contradictions and inconsistencies in the AO's order, indicating a lack of due application of mind. The PCIT had also set aside the assessment order. The tribunal set aside the impugned orders and restored the assessment to the AO for a de novo assessment, granting the assessee an opportunity to present evidence.

LATE SITTHAGOUNDER RASU, REPL BY LEGAL HEIR R. KUMARESAN,BHAVANI vs ITO, WARD-1(4), ERODE

ITA 2311/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Allowed

The Tribunal held that the assessment proceedings initiated against a deceased person without impleading the legal heirs are bad in law. The AO ought to have dropped the proceedings or continued them in the name of the legal representative.

THE MARTHANDAM BEE KEEPERS CO OP SOCIETY LTD,MARTHANDAM, KANYAKUMARI DIST vs INCOME TAX OFFICER WARD 1, NAGERCOIL, NAGERCOIL

ITA 2816/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Partly Allowed

The Tribunal condoned the delay in filing the appeal before the CIT(A), noting that the assessee was not heard by the AO due to potential technical issues. The CIT(A)'s order was set aside, and the case was restored for de novo assessment.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1808/CHNY/2025[2019-20]Status: Disposed28 Oct 2025AY 2019-20Partly Allowed

The Tribunal held that the penalty notice was defective for not specifying the exact limb of Section 270A(9) under which the penalty was proposed. Regarding the quantum, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio for estimating income from unaccounted purchases.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1810/CHNY/2025[2021-22]Status: Disposed28 Oct 2025AY 2021-22Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

VENKATACHALAM RAMAKRISHNAN,TRICHY vs ACIT, CIRCLE-3(1), TRICHY

ITA 2038/CHNY/2025[2016-17]Status: Disposed28 Oct 2025AY 2016-17Remanded

The Tribunal found that the assessee failed to provide sufficient evidence linking the borrowings and interest received to establish the nexus with M/s. Veesens Energy Pvt. Ltd. for the purpose of deduction. Consequently, the issue was remanded to the Assessing Officer for fresh verification.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1803/CHNY/2025[2019-20]Status: Disposed28 Oct 2025AY 2019-20Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1801/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs ACIT, CIRCLE 3(1), TRICHY, TRICHY

ITA 1301/CHNY/2025[2009-10]Status: Disposed28 Oct 2025AY 2009-10Remanded

The Tribunal held that the AO's failure to correctly give effect to the CIT(A)'s order constituted a patent error rectifiable under Section 154. The AO's inaction was seen as a disregard of judicial discipline and a misinterpretation of the appellate order.

RANJITH KUMAR,CHENNAI vs ITO, NCW-19(6), , CHENNAI

ITA 2041/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Partly Allowed

The Tribunal found no basis for the Assessing Officer's estimation of profit at 3%, which was confirmed by the CIT(A). Considering the assessee's submissions, the Tribunal held that 1% of total credits in the current account is just and proper.

THOMAS VICTOR,CHENNAI vs INCOME TAX OFFICER, NON CORP WARD 19(6), CHENNAI, CHENNAI

ITA 2987/CHNY/2024[2015-16]Status: Disposed28 Oct 2025AY 2015-16Allowed

The Tribunal held that the notice issued by the JAO for reopening the assessment was invalid as it contravened the Faceless Assessment Scheme. Consequently, the assessment order and the subsequent penalty order were also deemed null and void.

INCOMETAX OFFICER, CHENNAI vs DOOSAN BOBCAT INDIA PVT LTD, CHENNAI

ITA 2137/CHNY/2025[2012-13]Status: Disposed28 Oct 2025AY 2012-13Dismissed

The Tribunal held that the assessee was entitled to claim depreciation on intangible assets such as dealer network, vendor relationship, customer database, and trained employee base, as they were part of a business transfer and taken into account in the books of accounts.

SHRI RAVICHANDRA MANNAR NIDU,CHENNAI vs ITO NON CORPORATE WARD 2 (3), CHENNAI

ITA 3101/CHNY/2017[2014-15]Status: Disposed28 Oct 2025AY 2014-15Withdrawn

The Tribunal noted the assessee's intention to withdraw the appeal for the purpose of the DTVSV scheme. The appeal was accordingly dismissed as withdrawn, with liberty granted for restoration if the DTVSV resolution fails.

GOKULDASS SRINIVASAN,UDUMALAIPETTAI vs PCIT, COIMBATORE

ITA 1061/CHNY/2025[2017-18]Status: Disposed28 Oct 2025AY 2017-18Allowed

The tribunal noted contradictions and inconsistencies in the AO's order, indicating a lack of due application of mind. The PCIT had also set aside the assessment order. The tribunal set aside the impugned orders and restored the assessment to the AO for a de novo assessment, granting the assessee an opportunity to present evidence.

INCOME TAX OFFICER , INCOME TAX DEPARTMENT vs TRUE VALUE HOMES (INDIA) PRIVATE LIMITED, CHENNAI

ITA 1213/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Dismissed

The Tribunal held that the Ld.CIT(A)'s approach of using the assessee's historical audited results to estimate profit was reasonable and judicious. The rejection of books of accounts solely for not filing a tax audit report u/s.44AB without assigning defects was not concurred with.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1802/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Partly Allowed

The Tribunal found the show-cause notice for penalty under Section 270A to be defective as it did not specify the exact limb of Section 270A(9) under which the penalty was proposed. The Tribunal also noted that the addition was based on an estimation of GP, making penalty unjustified.

IMMACULATE HEART OF MARY,MAYILADUTHURAI vs INCOME TAX OFFICER, EXEMPTIONS WARD, TRICHY, TRICHY

ITA 2222/CHNY/2025[2015-16]Status: Disposed28 Oct 2025AY 2015-16Partly Allowed

The Tribunal held that the assessee was not given sufficient opportunity for compliance, especially considering the short notice period. The Tribunal set aside the impugned order and remitted the matter back to the AO for a denovo assessment, emphasizing the principles of natural justice.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1805/CHNY/2025[2021-22]Status: Disposed28 Oct 2025AY 2021-22Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

KHATEEB OMAIR AHMED,CHENNAI vs ITO, NCC-4(1), CHENNAI

ITA 2211/CHNY/2025[2003-04]Status: Disposed28 Oct 2025AY 2003-04Partly Allowed

The Tribunal held that the CIT(A) had dismissed the appeal ex-parte without giving sufficient opportunity to the assessee. Therefore, the Tribunal set aside the order and remitted the matter back for fresh adjudication.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1804/CHNY/2025[2020-21]Status: Disposed28 Oct 2025AY 2020-21Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

PRIYADARSHINI KASIVISVANATHEN,CHENNAI vs ITO, NCW-7(3), CHENNAI

ITA 2224/CHNY/2025[2016-17]Status: Disposed28 Oct 2025AY 2016-17Partly Allowed

The Tribunal held that the CIT(A) should have condoned the delay and decided the case on merits. Therefore, the Tribunal set aside the order and remitted the matter back to the CIT(A) to decide the appeal on merits after condoning the delay.

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs ACIT, CIRCLE 3(1), TRICHY, TRICHY

ITA 1304/CHNY/2025[2013-14]Status: Disposed28 Oct 2025AY 2013-14Remanded

The Tribunal held that the AO's failure to correctly give effect to the CIT(A)'s order constituted a patent error rectifiable under Section 154. The AO's inaction was seen as a disregard of judicial discipline and a misinterpretation of the appellate order.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1809/CHNY/2025[2020-21]Status: Disposed28 Oct 2025AY 2020-21Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

CHUNGATH VARGHESE SUNNY,COIMBATORE vs DCIT, CC-3(3), CHENNAI

ITA 1807/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Partly Allowed

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

VENKATESHWARAN PAULCHAMY,CHENNAI vs ITO, INTL TAXATION, WARD-2(1), CHENNAI

ITA 524/CHNY/2025[2016-17]Status: Disposed28 Oct 2025AY 2016-17Allowed

The Tribunal noted that the Assessing Officer had recorded reasons for initiating reassessment proceedings. However, the Tribunal found that the reasons recorded by the Assessing Officer were not sufficient to establish that income chargeable to tax had escaped assessment for the assessment year 2016-17. The Tribunal observed that the Assessing Officer had not demonstrated how the information available to him indicated escapement of income. Consequently, the Tribunal held that the reassessment proceedings initiated under Section 147 of the Income Tax Act, 1961, were not sustainable. The appeal filed by the assessee was allowed on this ground. The Tribunal did not decide on any other issues as the primary ground of appeal led to the quashing of the reassessment.

V S K CHARITABLE AND EDUCATIONAL TRUST,PUDUKKOTTAI vs INCOME TAX OFFICER, PUDUKKOTTAI

ITA 1006/CHNY/2025[2024-2025]Status: Disposed28 Oct 2025AY 2024-2025Partly Allowed

The Tribunal held that the CIT(A) had incorrectly rejected the benefit of Section 10(23C)(iiid) based on flimsy reasons. The Tribunal directed the Assessing Officer to verify the duly signed and stamped audited income and expenditure account and, if found satisfactory, grant the benefit of application/expenditure to the assessee.

K 2078 AKKARAI SENGAPPALLI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY,AKKARAI SENGAPPALLI vs ASSESSING OFFICER, COIMBATORE

ITA 2162/CHNY/2025[2018-19]Status: Disposed28 Oct 2025AY 2018-19Partly Allowed

The tribunal acknowledged the delay and excused it. While agreeing with the respondent, the tribunal set aside the impugned order due to principles of natural justice and ex-parte orders.

AUROJEEVA TRUST,PUDUCHERRY vs INCOME TAX OFFICER, EXEMPTIONS WARD 1, CHENNAI, CHENNAI

ITA 2246/CHNY/2025[NA]Status: Disposed28 Oct 2025Partly Allowed

The Tribunal held that since a condonation petition was pending before the CBDT, the CIT(E) should decide the application after the outcome of the CBDT's decision on the condonation petition. The order of CIT(E) was set aside and the matter was remitted back.

GULF OF MANNER BIOSHPERE RESERVE TRUST,RAMANATHPURAM vs CIT EXEMPTION , CHENNAI

ITA 2154/CHNY/2025[2023-24 TO 2027-28]Status: Disposed27 Oct 2025Partly Allowed

The Tribunal found that the CIT(E) had rejected the application primarily due to non-compliance by the assessee. However, considering the explanation provided by the assessee and in the interest of justice, the Tribunal decided to grant one more opportunity.

SHANMUGAVEL SUDARARAJAN,DINDIGUL vs ITO, WARD-1, , DINDIGUL

ITA 2327/CHNY/2025[2018-19]Status: Disposed27 Oct 2025AY 2018-19Remanded

The Tribunal, in the interest of justice, set aside the appeal to the Ld. CIT(A) for de novo adjudication on merits, granting the assessee one last opportunity to present its case. It was explicitly warned that further non-compliance would lead to the impugned order of the Ld. CIT(A) prevailing without leniency.

BRITTO EXPORTS,,CHENNAI vs ACIT, NCC-4(1), CHENNAI

ITA 2341/CHNY/2025[2017-18]Status: Disposed27 Oct 2025AY 2017-18Partly Allowed

The Tribunal, considering the interest of justice, decided to set aside the appeals to the file of the CIT(A) for de novo adjudication, granting the assessee one more opportunity to present relevant evidence and arguments.

SUDHA,TIRUNELVELI vs ITO, WARD-4,, TIRUNELVELI

ITA 2360/CHNY/2025[2018-19]Status: Disposed27 Oct 2025AY 2018-19Allowed

The Tribunal held that the notice under Section 148 was not issued in accordance with the e-assessment scheme, as it was issued by the JAO and not the NFAC. Following jurisdictional High Court decisions, the Tribunal set aside the impugned notice and consequential orders.

PICHAIMANI GUNASUNDARI,KANCHEEPURAM vs ITO, NC-22(1), TAMBARAM

ITA 2333/CHNY/2025[2019-20 ]Status: Disposed27 Oct 2025Allowed

The Tribunal held that the notice under Section 148 was issued by the JAO, not the FAO, which is contrary to the e-assessment scheme and relevant High Court judgments. Consequently, the notice and consequential orders were set aside.

BRITTO EXPORTS,CHENNAI vs ACIT, NON-CORPORATE CIRCLE-4(1), CHENNAI

ITA 2338/CHNY/2025[2017-18]Status: Disposed27 Oct 2025AY 2017-18Partly Allowed

The Tribunal, considering the interest of justice, decided to set aside the appeals to the file of the CIT(A) for de novo adjudication, granting the assessee one more opportunity to present relevant evidence and arguments.

SB ENTERPRISES,NAGAPATTINAM vs ITO, NCW-15(1), CHENNAI

ITA 2344/CHNY/2025[2017-18]Status: Disposed27 Oct 2025AY 2017-18Partly Allowed

The Tribunal noted the delay and accepted the explanation. The Tribunal decided to give the assessee one more opportunity before the CIT(A) to present evidence, setting aside the appeal for de novo adjudication.

BRITTO EXPORTS,CHENNAI vs ACIT, NCC-4(1), CHENNAI

ITA 2339/CHNY/2025[2017-18]Status: Disposed27 Oct 2025AY 2017-18Partly Allowed

The Tribunal, considering the interest of justice, decided to set aside the appeals to the file of the CIT(A) for de novo adjudication, granting the assessee one more opportunity to present relevant evidence and arguments.

BRITTO EXPORTS,,CHENNAI vs ACIT, NCC-4(1), CHENNAI

ITA 2340/CHNY/2025[2017-18]Status: Disposed27 Oct 2025AY 2017-18Partly Allowed

The Tribunal, considering the interest of justice, decided to set aside the appeals to the file of the CIT(A) for de novo adjudication, granting the assessee one more opportunity to present relevant evidence and arguments.

SRI RAMALINGAM RADHA,NAMAKKAL vs ACIT, CIRCL-I,, ERODE

ITA 2342/CHNY/2025[2013-14]Status: Disposed27 Oct 2025AY 2013-14Allowed

The Tribunal held that the notice under Section 148 was not issued in accordance with the e-assessment Scheme, 2022, as it was not issued by the National Faceless Assessment Centre (NFAC) but by the Joint Assessing Officer (JAO). This rendered the notice invalid.

SELVARAJ GOKULNATH,CHENNAI vs THE INCOME TAX OFFICER, NON CORP WARD 17(6), CHENNAI

ITA 2329/CHNY/2025[2021-22]Status: Disposed27 Oct 2025AY 2021-22Partly Allowed

The Tribunal condoned the delay, set aside the impugned order, and restored the appeal to the AO for a de novo assessment. This was subject to the assessee paying Rs. 10,000 to the Tamil Nadu State Legal Services Authority and providing all necessary evidence.

GULF OF MANNAR BIOSHPHERE RESERVE TRUST,RAMANATHAPURAM vs CIT EXEMPETION, CHENNAI

ITA 2153/CHNY/2025[-]Status: Disposed27 Oct 2025Partly Allowed

The Tribunal found that the CIT(E) had rejected the application primarily due to non-compliance by the assessee. However, considering the explanation provided by the assessee and in the interest of justice, the Tribunal decided to grant one more opportunity.

RAMANI RAJESH,COIMBATORE vs ACIT, NON CORPORATE CIRCLE-2, COIMBATORE

ITA 2343/CHNY/2025[2010-11]Status: Disposed27 Oct 2025AY 2010-11Allowed

The ITAT set aside the impugned order and restored the appeal to the AO for de novo assessment. This was done to uphold the principles of natural justice, subject to a cost of Rs. 5,000 to be deposited by the assessee.