ITAT Chennai Judgments — October 2025

M/S. AM INTERNATIONAL HOLDINGS (INDIA) PVT. LTD.,CHENNAI vs ITO, CORPORATE CIRCLE-1(1), CHENNAI

ITA 2057/CHNY/2025[2014-15]Status: Disposed21 Oct 2025AY 2014-15Allowed

The Tribunal held that the software expenses were inextricably linked to the assessee's business and were incurred to discharge contractual obligations. Therefore, the expenditure was allowable as a deduction.

M/S. CHITTASWARUP AGRO FARMING PVT. LTD.,CHENNAI vs ACIT, CC-1(2), CHENNAI

ITA 1794/CHNY/2025[2018-19]Status: Disposed21 Oct 2025AY 2018-19Partly Allowed

The Tribunal held that for unabated assessments, additions cannot be made in the absence of incriminating material found during the search. Relying on the Supreme Court judgment in PCIT vs. Abhisar Buildwell (P) Ltd., the Tribunal deleted the additions made by the AO.

M/S. ANANTRAM ORCHARDS PVT. LTD.,BANGALORE vs ACIT, CC-1(2), CHENNAI

ITA 1791/CHNY/2025[2018-19]Status: Disposed21 Oct 2025AY 2018-19Partly Allowed

The Tribunal held that for unabated assessments, additions cannot be made in the absence of incriminating material found during the search. Relying on the Supreme Court judgment in PCIT vs. Abhisar Buildwell (P) Ltd., the Tribunal deleted the additions made by the AO.

M/S. BETELNUT ESTATES PVT. LTD.,HYDERABAD vs ACIT, CC-1(2), CHENNAI

ITA 1792/CHNY/2025[2014-15]Status: Disposed21 Oct 2025AY 2014-15Partly Allowed

The Tribunal held that for unabated assessments, additions cannot be made in the absence of incriminating material found during the search. Relying on the Supreme Court judgment in PCIT vs. Abhisar Buildwell (P) Ltd., the Tribunal deleted the additions made by the AO.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

ITA 1650/CHNY/2025[2015-16]Status: Disposed21 Oct 2025AY 2015-16Dismissed

The Tribunal held that the penalty order dated 22.09.2022 passed by the AO under Section 271AAB(1A) of the Act for AY 2021-22, imposing a penalty of Rs. 2,39,98,544/-, was legally unsustainable and vitiated due to a defective show-cause notice dated 27.03.2022. The AO failed to specify whether the penalty was proposed under clause (a) or clause (b) of Section 271AAB(1A), which is a mandatory requirement. This omission renders the penalty proceedings fundamentally defective, depriving the assessee of a fair opportunity to respond. The Tribunal relied on the judgment of the Madras High Court in PCIT v. Shri R. Elangovan and various co-ordinate bench decisions, which held that such a failure vitiates the penalty proceedings and renders the penalty order unsustainable. Consequently, the CIT(A) was correct in deleting the penalty, and the Tribunal upheld the CIT(A)'s order. The Tribunal also noted that the Revenue failed to raise specific grounds challenging the CIT(A)'s findings on legal grounds, making the appeal exercise futile. The appeals concerning penalties under Section 271(1)(c) and Section 270A were not explicitly discussed in the provided excerpt, but the overarching result indicates they were also dismissed.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

ITA 1654/CHNY/2025[2020-21]Status: Disposed21 Oct 2025AY 2020-21Dismissed

The Tribunal held that the penalty order dated 22.09.2022 passed by the AO under Section 271AAB(1A) of the Act for AY 2021-22, imposing a penalty of Rs. 2,39,98,544/-, was legally unsustainable and vitiated due to a defective show-cause notice dated 27.03.2022. The AO failed to specify whether the penalty was proposed under clause (a) or clause (b) of Section 271AAB(1A), which is a mandatory requirement. This omission renders the penalty proceedings fundamentally defective, depriving the assessee of a fair opportunity to respond. The Tribunal relied on the judgment of the Madras High Court in PCIT v. Shri R. Elangovan and various co-ordinate bench decisions, which held that such a failure vitiates the penalty proceedings and renders the penalty order unsustainable. Consequently, the CIT(A) was correct in deleting the penalty, and the Tribunal upheld the CIT(A)'s order. The Tribunal also noted that the Revenue failed to raise specific grounds challenging the CIT(A)'s findings on legal grounds, making the appeal exercise futile. The appeals concerning penalties under Section 271(1)(c) and Section 270A were not explicitly discussed in the provided excerpt, but the overarching result indicates they were also dismissed.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

ITA 1653/CHNY/2025[2019-20]Status: Disposed21 Oct 2025AY 2019-20Dismissed

The Tribunal held that the penalty order dated 22.09.2022 passed by the AO under Section 271AAB(1A) of the Act for AY 2021-22, imposing a penalty of Rs. 2,39,98,544/-, was legally unsustainable and vitiated due to a defective show-cause notice dated 27.03.2022. The AO failed to specify whether the penalty was proposed under clause (a) or clause (b) of Section 271AAB(1A), which is a mandatory requirement. This omission renders the penalty proceedings fundamentally defective, depriving the assessee of a fair opportunity to respond. The Tribunal relied on the judgment of the Madras High Court in PCIT v. Shri R. Elangovan and various co-ordinate bench decisions, which held that such a failure vitiates the penalty proceedings and renders the penalty order unsustainable. Consequently, the CIT(A) was correct in deleting the penalty, and the Tribunal upheld the CIT(A)'s order. The Tribunal also noted that the Revenue failed to raise specific grounds challenging the CIT(A)'s findings on legal grounds, making the appeal exercise futile. The appeals concerning penalties under Section 271(1)(c) and Section 270A were not explicitly discussed in the provided excerpt, but the overarching result indicates they were also dismissed.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

ITA 1652/CHNY/2025[2018-19]Status: Disposed21 Oct 2025AY 2018-19Dismissed

The Tribunal held that the penalty order dated 22.09.2022 passed by the AO under Section 271AAB(1A) of the Act for AY 2021-22, imposing a penalty of Rs. 2,39,98,544/-, was legally unsustainable and vitiated due to a defective show-cause notice dated 27.03.2022. The AO failed to specify whether the penalty was proposed under clause (a) or clause (b) of Section 271AAB(1A), which is a mandatory requirement. This omission renders the penalty proceedings fundamentally defective, depriving the assessee of a fair opportunity to respond. The Tribunal relied on the judgment of the Madras High Court in PCIT v. Shri R. Elangovan and various co-ordinate bench decisions, which held that such a failure vitiates the penalty proceedings and renders the penalty order unsustainable. Consequently, the CIT(A) was correct in deleting the penalty, and the Tribunal upheld the CIT(A)'s order. The Tribunal also noted that the Revenue failed to raise specific grounds challenging the CIT(A)'s findings on legal grounds, making the appeal exercise futile. The appeals concerning penalties under Section 271(1)(c) and Section 270A were not explicitly discussed in the provided excerpt, but the overarching result indicates they were also dismissed.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

ITA 1651/CHNY/2025[2017-18]Status: Disposed21 Oct 2025AY 2017-18Dismissed

The Tribunal held that the penalty order dated 22.09.2022 passed by the AO under Section 271AAB(1A) of the Act for AY 2021-22, imposing a penalty of Rs. 2,39,98,544/-, was legally unsustainable and vitiated due to a defective show-cause notice dated 27.03.2022. The AO failed to specify whether the penalty was proposed under clause (a) or clause (b) of Section 271AAB(1A), which is a mandatory requirement. This omission renders the penalty proceedings fundamentally defective, depriving the assessee of a fair opportunity to respond. The Tribunal relied on the judgment of the Madras High Court in PCIT v. Shri R. Elangovan and various co-ordinate bench decisions, which held that such a failure vitiates the penalty proceedings and renders the penalty order unsustainable. Consequently, the CIT(A) was correct in deleting the penalty, and the Tribunal upheld the CIT(A)'s order. The Tribunal also noted that the Revenue failed to raise specific grounds challenging the CIT(A)'s findings on legal grounds, making the appeal exercise futile. The appeals concerning penalties under Section 271(1)(c) and Section 270A were not explicitly discussed in the provided excerpt, but the overarching result indicates they were also dismissed.

THAVAM RESEARCH FOUNDATION,,PUDUKKOTTAI vs CIT, EXEMPTION,, CHENNAI

ITA 1159/CHNY/2025[-]Status: Disposed21 Oct 2025Allowed

The Tribunal held that the CIT(E)'s rejection of the registration application was premature. The question of whether the activities are commercial or charitable, and whether income derived is taxable or exempt, should be decided during assessment proceedings, not at the stage of registration.

MADRAS CHINMAYA SEVA TRUST,CHETPET, CHENNAI vs CIT (EXEMPTION), NUMGAMBAKKAM, CHENNAI

ITA 885/CHNY/2025[2025-26]Status: Disposed17 Oct 2025AY 2025-26Allowed

The Tribunal held that the assessee's application should be considered under the newly inserted clause (iv) of the first proviso to Section 80G(5), which became effective from 01.10.2024, allowing applications post-commencement of activities.

J.L. INFRASTRUCTURE PVT. LTD.,CHENNAI vs DCIT, CORPORATE CIRCLE-2(2), CHENNAI

ITA 1911/CHNY/2025[2017-18]Status: Disposed17 Oct 2025AY 2017-18Dismissed

The Tribunal dismissed the appeal as withdrawn, noting that the assessee had opted for the Vivad-se-Vishwas Scheme. The Assessing Officer was directed not to give effect to the CIT(A)'s order, as it would be deemed not passed in light of the settlement.

RAZAK ROWTHER MOHAMED SALEEM,DINDIGUL vs ITO, WARD-1,, DINDIGUL

ITA 1731/CHNY/2025[2016-17]Status: Disposed17 Oct 2025AY 2016-17Allowed

The Tribunal held that the assessee's activities in cultivating and selling eucalyptus trees satisfied the conditions for agricultural income under Section 2(1A) of the Income Tax Act. The tribunal found that the assessee was involved in basic and subsequent operations, and the sale of produce qualified as agricultural income. Therefore, the disallowance by the lower authorities was not justified.

COMMISSIONER OF POLICE COIMBATORE CITY TAMILNADU POLICE CANTEEN,COIMBATORE vs ITO, NCW-1(1), COIMBATORE

ITA 2069/CHNY/2025[2022-23]Status: Disposed16 Oct 2025AY 2022-23Allowed

The Tribunal held that Section 44AB applies only to 'business' or 'profession', and since the assessee operated under the principle of mutuality, it was not carrying on business. Therefore, the requirement of a tax audit report under Section 44AB was not applicable.

J vs EXPORTS,MADURAIVS.DCIT, NCC-2, , MADURAI

ITA 2059/CHNY/2025[2013-14]Status: Disposed16 Oct 2025AY 2013-14Allowed

The Tribunal held that the reassessment proceedings were initiated without any fresh tangible material and were based on a mere change of opinion, amounting to a review of the earlier assessment. Therefore, the assumption of jurisdiction was invalid.

MURUGAN DEEPAN,CHENNAI vs DCIT, NCC-10(1), CHENNAI

ITA 1988/CHNY/2025[2018-19]Status: Disposed16 Oct 2025AY 2018-19Partly Allowed

The tribunal condoned the delay in filing the appeal. Regarding the net profit estimation, the tribunal found that the AO's calculation errors led to an incorrect estimation. Considering the assessee's concession and the calculated net profit ratio, the tribunal decided to estimate the net profit at 6% of sales. The addition on account of increase in capital was deleted as it was covered by the returned income and estimated net profit. The disallowance of depreciation was also directed to be deleted as it was subsumed in the net profit.

RAMSAMY PONGIANNA GOUNDER DESAMANI,PALLIPALAYAM vs ITD, WARD 2, , TIRUCHENGODE

ITA 2438/CHNY/2024[2011-12]Status: Disposed16 Oct 2025AY 2011-12Remanded

The Tribunal noted that the company M/s. Best Cheran Spintex India Limited was previously assessed under Section 2(22)(e) but its appeal was allowed as it was not a registered shareholder of the lending company. The Tribunal is now examining if the deeming provision applies to the individual shareholder.

SRI KARPAGA VINAYAGAR EDUCATIONAL AND CHARITABLE TRUST,DINDIGUL vs ITO, EXEMPTIONS WARD,, MADURAI

ITA 2084/CHNY/2025[2016-17]Status: Disposed16 Oct 2025AY 2016-17Withdrawn

The Tribunal considered the submission made by the AR from the Bar. Consequently, the appeal filed by the assessee was dismissed as withdrawn.

RAMAMOORTHY SRINIVASAN CHANDILYA,BANGALORE vs ITO, WARD-12(1), HYDERABAD

ITA 2029/CHNY/2025[2015-16]Status: Disposed16 Oct 2025AY 2015-16Dismissed

The Tribunal held that the appeal was filed before the wrong bench (Chennai) as the jurisdiction lies with the Hyderabad Bench, based on the location of the Assessing Officer. Consequently, the appeal was dismissed for want of jurisdiction.

M.N. CHICKKANNA CHETTIAR TRUST,TIRUPPUR vs ACIT (EXEMPTIONS), COIMBATORE

ITA 1568/CHNY/2025[2020-21]Status: Disposed15 Oct 2025AY 2020-21Allowed

The Tribunal held that the filing of the audit report in Form 10B is a procedural-cum-directory requirement and not mandatory. Since the substantive conditions for exemption under Section 11 were fulfilled, the delay in filing the audit report should not lead to the denial of exemption.

AMEYA PLANTATIONS PRIVATE LIMITED,TRIUVALLUR vs ACIT, DC/AC CENTRAL CIRCLE1 (2) CHENNAI, TAMILNADU, CHENNAI

ITA 1460/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. AVANISH PLANTATIONS PVT. LTD.,BANGALORE vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1454/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. PARAMJEET ORCHARDES PVT. LTD.,TIRUVALLUR vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1449/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

RAMASAMY DINESH,GOBICHETTIPALAYAM vs ITO, WARD-2(1),, ERODE

ITA 2008/CHNY/2025[2017-18]Status: Disposed15 Oct 2025AY 2017-18Allowed

The Tribunal held that the assessee had discharged the onus to explain the source of cash deposits by furnishing sale bills and disclosing the capital gain in the return of income. The AO had not properly considered the evidence. The Addl. CIT(A) had not doubted the sales bills but confirmed the addition solely on the ground that the cash was deposited after a gap of three months and during the demonetization period. The Tribunal found no bar or restriction in law against keeping cash at home for three months. Therefore, the Addl. CIT(A) was not justified in confirming the addition. The Tribunal reversed the order of the Addl. CIT(A) and directed the AO to delete the addition of Rs. 13,10,000/-. The issue regarding the rate of tax under Section 115BBE was not expressly decided as the addition itself was deleted.

BHADRAK AGRO FARMING PVT. LTD.,TRIUVALLUR vs ACIT, CENTRAL CIRCLE 1(2) CHENNAI, CHENNAI

ITA 1459/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. CHETAN ORCHARDES PVT. LTD.,TIRUVALLUR vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1458/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. ANANTRAM AGRO FARMS PVT. LTD.,TIRUVALLUR vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1455/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. AJITABH AGRO FARMS PVT. LTD.,BANGALORE vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1453/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. AJITABH ORCHARDES PVT. LTD.,CHENNAI vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1452/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

M/S. ACHYUTA PLANATATIONS PVT. LTD.,BEGALURU vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1450/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

MASS READYMIX,KARUR vs ASSISTANT COMMISSIONER CENTRAL CIR 2 COIMBATORE, COIMBATORE

ITA 1424/CHNY/2025[2017-2018]Status: Disposed15 Oct 2025AY 2017-2018Partly Allowed

The Tribunal held that the purchase price of river sand could not be the Rs. 309/- claimed by the assessee, nor the Rs. 1,500/- adopted by the AO, but estimated it at Rs. 770/- per unit. The addition on account of sundry creditors was confirmed.

MASS READYMIX,KARUR vs ASSISTANT COMMISSIONER CENTRAL CIR 2 COIMBATORE, COIMBATORE

ITA 1423/CHNY/2025[2016-2017]Status: Disposed15 Oct 2025AY 2016-2017Partly Allowed

The Tribunal held that the purchase price of river sand could not be the Rs. 309/- claimed by the assessee, nor the Rs. 1,500/- adopted by the AO, but estimated it at Rs. 770/- per unit. The addition on account of sundry creditors was confirmed.

ACIT, NON-CORPORATE CIRCLE 7(1), CHENNAI, CHENNAI vs LATE SHRI MAHAVEER BHANDARI, LEGAL HEIR- SMT. LALITHA BHANDARI, CHENNAI

ITA 2785/CHNY/2024[2016]Status: Disposed15 Oct 2025Partly Allowed

The Tribunal noted that the CIT(A) had deleted the entire assessment order without discussing the merits of the case. The appeal was admitted for adjudication, indicating that the Tribunal would examine the grounds raised by the Revenue.

UCAL LIMITED,CHENNAI vs PCIT, CHENNAI-3,, CHENNAI

ITA 1018/CHNY/2025[2020-21]Status: Disposed15 Oct 2025AY 2020-21Allowed

The Tribunal held that the PCIT's action under Section 263 was without jurisdiction. The Assessing Officer had followed the jurisdictional High Court's decision at the time of assessment, and subsequent Supreme Court decisions reversing such views do not make the AO's order erroneous retrospectively.

MASS READYMIX,KARUR vs ASSISTANT COMMISSIONER CENTRAL CIR 2 COIMBATORE, COIMBATORE

ITA 1425/CHNY/2025[2018-2019]Status: Disposed15 Oct 2025AY 2018-2019Partly Allowed

The Tribunal held that the purchase price of river sand could not be the Rs. 309/- claimed by the assessee, nor the Rs. 1,500/- adopted by the AO, but estimated it at Rs. 770/- per unit. The addition on account of sundry creditors was confirmed.

M/S. ASHWAGANDHA HOMES PVT. LTD.,TELANGANA vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1457/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

MANIMOZHIAN VAIDEKI,SIVAGANGAI vs ACIT, INTERNATIONAL TAXATION CIRCLE,, MADURAI

ITA 2025/CHNY/2025[2016-17]Status: Disposed15 Oct 2025AY 2016-17Allowed

The Tribunal held that the reopening of assessment was barred by limitation as the escaped income was less than Rs. 50 lakhs and the notice was issued beyond 3 years from the end of the relevant assessment year. The assumption of jurisdiction by the AO was found to be flawed.

M/S, AVANINDRA AGRO FARMS PVT. LTD.,CHENNAI vs ACIT, CENTRAL CIRCLE-1(2), CHENNAI

ITA 1456/CHNY/2025[2018-19]Status: Disposed15 Oct 2025AY 2018-19Allowed

The Tribunal held that no addition can be made under Section 68 for an unabated assessment year without any incriminating material found during the search. The assessment year was considered unabated as no notice under Section 143(2) was issued within the prescribed time.

RAMALINGAM ELLALAN,ERODE vs ACIT, CENTRAL CIRCLE-2,, COIMBATORE

ITA 1129/CHNY/2025[2018-19]Status: Disposed14 Oct 2025AY 2018-19Partly Allowed

The Tribunal held that the Rs 19,00,000 pertains to AY 2017-18 and cannot be taxed in AY 2018-19. The remaining Rs 18,70,000, representing payments made in AY 2018-19, should be taxed as business receipts at 30%.

THANARAJ SUMATHI,MAYILADUTHURAI vs ITO, WARD-1,, KUMBAKONAM

ITA 2031/CHNY/2025[2019-20]Status: Disposed14 Oct 2025AY 2019-20Allowed

The Tribunal held that the notices issued by the JAO for reopening the assessment were invalid and bad in law, as they were issued contrary to the faceless scheme notified on March 29, 2022. Consequently, the reassessment proceedings were quashed.

ANTHONYMUTHU UDAYAR XAVIER,SIVAGANGA vs ITO, WARD-1,, KARAIKUDI

ITA 1943/CHNY/2024[2014-15]Status: Disposed14 Oct 2025AY 2014-15Allowed

The Tribunal held that the notice under Section 148 was issued on April 1, 2021, as per the ITBA portal, making the reopening invalid. The Tribunal found the revenue's claim of issuance on March 31, 2021, to be unsubstantiated and relied on ITBA portal records and judicial precedents.

SWAMINATHAN SUKUMAR,SALEM vs ITO, WARD-1(6), SALEM

ITA 1105/CHNY/2025[2020-21]Status: Disposed14 Oct 2025AY 2020-21Allowed

The Tribunal held that the additional income tax under Section 140B(3) should be restricted to 25%. While the updated return was filed on October 31, 2022, which is beyond 12 months from the end of AY 2020-21 (March 31, 2021), the provisions of Section 139(8A) and 140B came into effect only on April 1, 2022. Furthermore, the relevant ITR-3 form was enabled on July 9, 2022. The Tribunal found that penalizing the assessee for a procedural impossibility due to the non-availability of the form before July 9, 2022, would be inequitable and ultra vires the principle of administrative fairness. This view was supported by judicial precedents and CBDT FAQs. The Tribunal also held that interest under Section 234A is compensatory and should be computed only up to the date of tax payment, May 25, 2022, not the date of filing the return. This was supported by judicial pronouncements. The AO/CPC was directed to recompute the tax liability accordingly.

SHAMIMULLAH,RANIPET vs ITO, NCW-11(2), CHENNAI

ITA 1564/CHNY/2025[2017-18]Status: Disposed13 Oct 2025AY 2017-18Allowed

The Tribunal held that the penalty appeal should be set aside and restored to the file of the Ld.CIT(A) for de novo adjudication, to be decided after the quantum appeal is adjudicated.

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs ANBEZHIL SURYARAJ KUMAR, CHENNAI

ITA 1676/CHNY/2025[2016-17]Status: Disposed13 Oct 2025AY 2016-17Dismissed

The Tribunal held that the Assessing Officer erred in treating the 'on-money' as unaccounted income without proper justification, especially when the assessee had disclosed it in her return. The Tribunal also agreed with the CIT(A)'s allowance of deductions under Section 54 and 54F.

RAGHAVAN,KANCHIPURAM vs ITO, NCC-22(1), TAMBARAM

ITA 1776/CHNY/2025[2018-19]Status: Disposed13 Oct 2025AY 2018-19Allowed

The Tribunal held that the assessee had a bonafide belief that TDS was sufficient compliance, especially given their long tenure working abroad and lack of familiarity with Indian tax laws. Since the Assessing Officer accepted the returned income without adverse inference, the penalty under Section 270A was deleted.

KRISHNASAMY ILANGOVAN,NAMAKKAL vs ITO, WARD-2,, NAMAKKAL

ITA 2066/CHNY/2025[2017-18]Status: Disposed13 Oct 2025AY 2017-18Partly Allowed

The Tribunal condoned the delay in filing the appeal. It set aside the CIT(A) order and remitted the matter back to the AO for denovo assessment after providing an opportunity to the assessee.

PONNUCHAMY,COIMBATORE vs ITO, NCW-4(4), COIMBATORE

ITA 2068/CHNY/2025[2018-19]Status: Disposed13 Oct 2025AY 2018-19Partly Allowed

The tribunal held that the assessee was not given adequate opportunity to present their case before the CIT(A) and that the appeal was dismissed due to a delay in filing without proper consideration of the reasons. Therefore, the tribunal condoned the delay and remitted the matter back to the CIT(A) for fresh adjudication.

KAILASHKUMAR JAIN,CHENNAI vs ITO, NCW-5(1), CHENNAI

ITA 2070/CHNY/2025[2017-18]Status: Disposed13 Oct 2025AY 2017-18Allowed

The Tribunal condoned the delay in filing the appeal. It noted that the AO passed an order without considering the assessee's information and the CIT(A) dismissed the appeal due to the assessee's non-appearance. The Tribunal set aside the CIT(A) order and remitted the matter back to the AO for a denovo assessment.

SASTHA HOSPITALITY,CHENNAI vs ITO, NCW-19(3), CHENNAI

ITA 2077/CHNY/2025[2017-2018]Status: Disposed13 Oct 2025AY 2017-2018Partly Allowed

The Tribunal condoned the delay in filing the appeal and noted the assessee's failure to participate in proceedings before the lower authorities. The Tribunal set aside the order of the CIT(A) and remitted the matter back to the AO for denovo assessment, providing a reasonable opportunity to the assessee.

RISE ADVERTISING PVT. LTD.,MADURAI vs ITO, TDS , MADURAI

ITA 251/CHNY/2025[2016-17]Status: Disposed13 Oct 2025AY 2016-17Dismissed

The Tribunal held that Section 200A(1)(c) of the Income Tax Act, which allows charging of fees under Section 234E, was introduced effective June 1, 2015. Since the assessee's TDS statement was filed and processed after this date, the late fee was rightly levied.