ITAT Chennai Judgments — October 2025

The Tribunal heard both sides and perused the CBDT Circular. It was found that the appeal did not fall under any exceptions mentioned in the Circular and was not maintainable due to low tax effect.

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.

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.

The Tribunal found that the CIT(A) did not properly grant an opportunity of hearing and the order was cryptic. Therefore, the Tribunal set aside the appeal to the CIT(A) for de novo adjudication after providing a proper opportunity of hearing.

The Tribunal held that while Section 44AE might not be strictly applicable, it serves as a good guideline for estimating income in transport business cases, especially when books of accounts are unavailable. The Assessing Officer was directed to compute the profit by applying the provisions of Section 44AE.

The Tribunal held that the disallowance under Section 14A cannot exceed the actual exempt income, as per the Supreme Court's decision in Maxopp Investment. Therefore, the order of the CIT(A), which restricted the disallowance to the extent of actual exempt income, was upheld.

The Tribunal held that the High Court of Madras had quashed the original assessment order. Therefore, the CIT(A) order confirming a non-existent assessment order was also bad in law and consequently quashed.

The Tribunal found that the lower authorities did not properly examine the assessee's claim of availing a housing loan of Rs. 1 crore, which was used for the property purchase. Since both lower authorities passed ex parte orders, the issue was restored to the AO for fresh adjudication.

The Tribunal condoned the delay in filing the appeals and remanded the matter back to the CIT(E) for a fresh consideration. The assessee was granted one more opportunity to furnish the required details, subject to payment of costs.

The Tribunal held that the assessment order passed by the Faceless mechanism (NFAC) was bad in law. This was based on the decision of the Madras High Court in the case of Mark Studio India (P.) Ltd. v. ITO, as the notice under Section 148A(d)/148 was issued by the Jurisdictional Assessing Officer.

The Tribunal found that notices were sent to a wrong email ID, which was a violation of natural justice. Therefore, the ex parte orders were set aside, and the appeals were restored to the Ld.CIT(A) for fresh adjudication after issuing proper notice.

The Tribunal condoned the delay and remanded the matter back to the CIT(E). The CIT(E) is directed to provide one more opportunity to the assessee to furnish the required details for verification and then decide the application afresh.

The Tribunal directed the Ld.CIT(E) to treat the provisional registration granted for three years as if it were granted for five years, considering the assessee's status as an old trust and the circumstances of the inadvertent error.

The Tribunal found the reasons for the delay to be bonafide and directed the CIT(A) to condone the delay, adjudicate the issues on merits, and afford the assessee a reasonable opportunity to be heard, subject to a payment of ₹.10,000/- to the State Legal Aid Authority.

The Tribunal held that the Ld.CIT(A)'s orders were vitiated due to a violation of natural justice because notices were sent to an incorrect email ID, and the assessment orders were also ex parte. Therefore, the appeals were allowed for statistical purposes.

The Tribunal condoned the delay in filing the appeals and remanded the matter back to the CIT(E) for a fresh consideration. The assessee was granted one more opportunity to furnish the required details, subject to payment of costs.

The Tribunal held that the show-cause notices issued by the AO were vague and did not specify the exact clause of Section 270A(9) under which the penalty was proposed. Therefore, the penalty proceedings were illegal.

The Tribunal held that the assessment order passed by the NFAC assessment unit is bad in law, referencing the decision of the Hon'ble High Court of Madras in the case of Mark Studio India (P.) Ltd. V. ITO. The assessment order dated 29.02.2024 was quashed.

The Tribunal held that penalty proceedings are independent of assessment proceedings and the assessee can challenge the basis of penalty. It found that the penalty was unsustainable as it was based on loose sheets and sworn statements without corroborative evidence and without providing an effective opportunity for cross-examination.

The Tribunal held that penalty proceedings are independent of assessment proceedings and the assessee can challenge the basis of penalty. It found that the penalty was unsustainable as it was based on loose sheets and sworn statements without corroborative evidence and without providing an effective opportunity for cross-examination.

The Tribunal held that penalty proceedings are independent of assessment proceedings and the assessee can challenge the basis of penalty. It found that the penalty was unsustainable as it was based on loose sheets and sworn statements without corroborative evidence and without providing an effective opportunity for cross-examination.

The Tribunal held that while Section 44AE might not be strictly applicable, it serves as a good guideline for estimating income in transport business cases, especially when books of accounts are unavailable. The Assessing Officer was directed to compute the profit by applying the provisions of Section 44AE.

The Tribunal held that the issue of suppressed stock had reached finality for AY 2022-23, as the assessee had accepted the addition made by the AO and withdrawn their appeal. Therefore, the appeal for AY 2023-24 was dismissed as infructuous.

The Tribunal held that the assessee is eligible for the rebate under Section 87A of the Act, even with income that includes short-term capital gains taxable under Section 111A and long-term capital gains under Section 112A, as there is no statutory exclusion for these incomes.

The Tribunal held that penalty proceedings are independent of assessment proceedings and the assessee can challenge the basis of penalty. It found that the penalty was unsustainable as it was based on loose sheets and sworn statements without corroborative evidence and without providing an effective opportunity for cross-examination.

The Tribunal found that the assessee had sufficient cause for the delay and directed the Ld.CIT(A) to condone the delay and admit the appeals for adjudication on merits. The grounds raised in ITA No.2261 of 2025 were allowed for statistical purposes.

The Tribunal condoned the delay in filing the appeals, subject to payment of costs, and set aside the ex-parte orders passed by the Ld.CIT(A). The matters were remitted back to the Ld.CIT(A) for adjudication on merits after hearing the assessee.

The Tribunal found that the assessee had sufficient cause for the delay and directed the Ld.CIT(A) to condone the delay and admit the appeals for adjudication on merits. The grounds raised in ITA No.2261 of 2025 were allowed for statistical purposes.

The Tribunal held that a legal ground challenging jurisdiction can be raised at any stage, relying on a Supreme Court decision. The assessment order was found to be bad in law.

The Tribunal held that the market value of electricity supplied for captive consumption should be considered at the rate at which the State Electricity Board supplies power to its end consumers. This principle applies even after amendments to Section 80IA(8).

The Tribunal held that the CIT(A) erred in enhancing the cash deposit addition without issuing a show-cause notice to the assessee, violating Section 251(2) of the Act. The Tribunal also found that the cash deposits were out of withdrawals from the firm's bank account used for labour wages.

The Tribunal upheld the CIT(A)'s decision, confirming that disallowance under Section 14A is not warranted when no exempt income has been earned by the assessee. The Revenue failed to provide evidence contradicting this premise.

The Tribunal condoned the delay in filing the appeals and observed that the reasons for non-furnishing details were bonafide. The matter was remanded to the CIT(E) for one more opportunity to the assessee to furnish the details.

The Tribunal set aside the CIT(A)'s order and restored the appeal to the CIT(A)'s file, directing adjudication of grounds of appeal after hearing the assessee, granting one more opportunity.

The Tribunal held that interest income derived by a cooperative society from its investments in another cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income Tax Act. The Tribunal relied on decisions of the Jurisdictional High Court and its own previous judgments.

The Tribunal condoned the delay in filing the appeals and observed that the reasons for non-furnishing details were bonafide. The matter was remanded to the CIT(E) for one more opportunity to the assessee to furnish the details.

The Tribunal held that the Ld.CIT(A)'s orders were vitiated due to a violation of natural justice because notices were sent to an incorrect email ID, and the assessment orders were also ex parte. Therefore, the appeals were allowed for statistical purposes.

The Tribunal held that the deduction under section 80P of the Income Tax Act, 1961, is admissible only if the return of income is filed within the due date specified under section 139(1). Since the assessee filed the returns belatedly, they are not entitled to the deduction.

The Tribunal condoned the delay in filing the appeals, subject to payment of costs, and set aside the ex-parte orders passed by the Ld.CIT(A). The matters were remitted back to the Ld.CIT(A) for adjudication on merits after hearing the assessee.

The Tribunal found that the CITA violated Rule 46A of the Income Tax Rules by not giving the AO an opportunity to examine the additional evidence. Therefore, the issue was restored to the AO for fresh consideration.

The Tribunal held that the assessment was framed in the name of CNC CAC Charities, which is the assessee with a valid registration. The mere mention of 'CAC Charities' in the return does not change the entity. Therefore, the addition made by the AO was deleted.

The Tribunal held that the CIT(A) was justified in deleting the penalty under Section 271AAB because the show cause notice did not specify the exact charge. The Tribunal also upheld the deletion of the penalty under Section 271AAD, agreeing with the CIT(A) that the issue was a timing difference and not a deliberate omission.

The Tribunal found that the reasons for the delay constituted sufficient cause and directed the Ld.CIT(A) to condone the delay and admit the appeal for adjudication.

The Tribunal found that notices were sent to a wrong email ID, which was a violation of natural justice. Therefore, the ex parte orders were set aside, and the appeals were restored to the Ld.CIT(A) for fresh adjudication after issuing proper notice.

The Tribunal held that the addition made by the Assessing Officer and confirmed by the CIT(A) was not justified. Evidence, including the son's salary earnings and bank statements, indicated that the son had sufficient sources to deposit into his account, and the assessee was authorized to withdraw funds.

The Tribunal held that the condition of filing Form 67 before the due date is directory and not mandatory. Since the assessee filed Form 67 before the completion of assessment proceedings and before the intimation under section 143(1), the FTC claim should be allowed.

The Tribunal upheld the CIT(A)'s decision, confirming that disallowance under Section 14A is not warranted when no exempt income has been earned by the assessee. The Revenue failed to provide evidence contradicting this premise.

The Tribunal held that the disallowance under Section 14A cannot exceed the actual exempt income, as per the Supreme Court's decision in Maxopp Investment. Therefore, the order of the CIT(A), which restricted the disallowance to the extent of actual exempt income, was upheld.

The Tribunal held that the deduction under section 80P of the Income Tax Act, 1961, is admissible only if the return of income is filed within the due date specified under section 139(1). Since the assessee filed the returns belatedly, they are not entitled to the deduction.

Following a decision of the Madras High Court, the Tribunal held that the notice issued by the JAO was invalid as it was in defiance of the CBDT Notification dated 29.03.2022, which required such notices to be issued by the FAO. Consequently, the impugned notice under Section 148 and all consequential orders were set aside, with liberty for the Revenue to seek revival if the Supreme Court reverses the High Court's judgment.