ITAT Chennai Judgments — November 2025

The Tribunal, relying on a jurisdictional High Court decision, held that Section 200A, which enables the levy of fees under Section 234E while processing TDS statements, was introduced only from 01.06.2015. Since the relevant assessment years (2013-14 and 2014-15) pre-dated this effective date, there was no provision under Section 200A to impose late fees under Section 234E. Consequently, the impugned demand intimation letters were set aside.

The Tribunal held that the Ld.CIT(A) erred in refusing to admit the appeals solely on the ground of delay without providing the assessee an opportunity to explain and prove the reasons for the delay. The Tribunal also noted that the assessee did not get a proper opportunity before the AO during assessment proceedings, especially considering the notice was issued during the Covid-19 pandemic.

The Tribunal held that income recomputed solely based on the DVO's estimated cost of acquisition falls under clause (b) of sub-section (6) of Section 270A, which excludes estimated income from the definition of 'under-reported income'. Therefore, the penalty levied under Section 270A was cancelled.

The tribunal held that the Ld.CIT(A) erred in rejecting the appeals solely on the ground of delay without giving the assessee an opportunity to explain. The tribunal also noted that the AO did not provide proper opportunity to the assessee during assessment proceedings, especially considering the notice was issued during the Covid-19 pandemic.

The Tribunal held that the assessee, being a registered co-operative society, is entitled to deduction under Section 80P(2)(d) of the Act on interest income earned from investments with the Villupuram District Central Co-operative Bank, as the bank is also a co-operative society.

The tribunal ruled that the CIT(A) erred in dismissing appeals under Section 249(4)(b), clarifying that advance tax liability pertains to admitted income, not disputed additions. It condoned the 869-day delay, acknowledging the assessee's lack of education and awareness, subject to a payment of Rs. 70,000 to the Tamil Nadu State Legal Services Authority. The matter was remitted back to the Assessing Officer for a fresh examination of all issues with a reasonable opportunity of hearing to the assessee.

The Tribunal held that the CIT(A) erred in dismissing the appeals solely on the grounds of non-payment of advance tax and delay. Advance tax liability is based on admitted income. The delay was condoned upon payment of Rs. 70,000/- by the assessee.

The Tribunal condoned the delay of 300 days in filing the appeal by the assessee, holding that there was sufficient cause. The Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for a de novo assessment.

The Tribunal held that the CIT(A) erred in dismissing the appeal without awaiting the decision on the condonation petition. The matter requires fresh consideration.

The Tribunal held that the CIT(A)'s direction to consider only peak credit and not the entire cash deposits for taxation was correct. This was based on previous ITAT orders and a High Court judgment which established the 'Peak Credit' method as appropriate for such cases.

The Tribunal held that the CIT(A) was incorrect in dismissing the appeals for non-payment of advance tax based on assessed income, as advance tax is calculated on estimated or admitted income, not disputed additions. The Tribunal also condoned the delay in filing the appeals, considering the assessee's lack of education and understanding of tax matters, subject to a payment.

The Tribunal held that the CIT(A) was incorrect in dismissing the appeals for non-payment of advance tax based on assessed income, as advance tax liability arises on admitted income. The Tribunal also condoned the delay in filing the appeals.

The Tribunal held that the addition of gross cash deposits is incorrect and only the unexplained peak credit can be added to the total income. The CIT(A)'s direction to verify and tax only the peak credit was upheld.

The Tribunal held that the penalty under Section 271(1)(b) is for non-compliance with a notice and is independent of the quantum of the assessment order. Therefore, the penalty was confirmed to the extent of Rs. 10,000/- for one default.

The Tribunal found that the orders were passed ex-parte without sufficient opportunity for the assessee. While noting the assessee's negligence, the Tribunal, in the interest of natural justice, granted one more opportunity for denovo assessment.

The Tribunal held that the CIT(A) erred in dismissing the appeals for non-prosecution without considering the merits. One more opportunity was granted to the assessee to present her case.

The Tribunal noted that the CIT(A) dismissed the appeals without discussing the merits. Considering the assessee's explanation for non-compliance and assurance of cooperation, the Tribunal granted one more opportunity.

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

The Tribunal held that the assessee is entitled to deduction under Section 80P(2)(d) for interest income earned from its investments with VDCC, as VDCC is registered as a cooperative society. The FAA's order directing the AO to grant the deduction was upheld.

The Tribunal held that the interest income earned by a co-operative society from investments with another co-operative bank is eligible for deduction under Section 80P(2)(d) of the Act, provided the bank is registered as a co-operative society.

The Tribunal held that Section 200A of the Act, which empowers the levy of late fees, was introduced only with effect from 01.06.2015. Therefore, for the assessment years 2013-14 and 2014-15, the CPC could not have imposed late fees under Section 234E.

The Tribunal found that the CIT(A) had narrated facts of a different case and proceeded as if the assessment order was passed under Section 144 r.w.s. 147, indicating a non-application of mind. Therefore, the Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for de novo assessment.

The Tribunal held that the CIT(A) erred in dismissing the appeals on the grounds of non-payment of advance tax, as advance tax is payable on admitted or undisputed income, not on additions disputed by the assessee. The Tribunal also condoned the delay in filing the appeals, considering the assessee's lack of education and familiarity with tax matters.

The Tribunal held that the CIT(A) erred by not admitting the appeals solely on the ground of delay without properly considering the reasons provided and without giving the assessee an opportunity to explain. The assessment orders were set aside due to lack of proper opportunity for the assessee during the assessment proceedings.

The Tribunal held that the Ld.CIT(A) was duty-bound to decide the appeal on merits and not dismiss it ex-parte. The Tribunal also noted that the AO hurried the assessment order. Therefore, the Tribunal set aside the order of the Ld.CIT(A) and restored the issue back to the AO for de novo consideration, granting one more opportunity to the assessee.

The Tribunal noted that the AO and CIT(A) passed ex-parte orders due to the assessee's failure to provide evidence. However, considering the principles of natural justice, the Tribunal granted one more opportunity to the assessee to substantiate their case.

The Tribunal found that the assessee had indeed responded and provided acknowledgments as proof. It held that the ex-parte order violated natural justice.

The Tribunal held that the assessee is a co-operative society and has earned interest income from VDCC, which is also a co-operative society registered under the Tamil Nadu Co-operative Societies Act. Following various judicial precedents, including decisions of the Jurisdictional High Court and the Tribunal's own case, the interest income earned from VDCC is eligible for deduction under Section 80P(2)(d) of the Act.

The Tribunal held that the Ld.PCIT violated principles of natural justice by ignoring the assessee's request for adjournment and passing an ex-parte order without proper opportunity to respond. The revisional action was restored to the file of the Ld.PCIT.

The Tribunal held that the CIT(A) erred in dismissing the appeals for non-payment of advance tax on assessed income, as advance tax is only on admitted or undisputed income. The Tribunal also condoned the significant delay in filing the appeals due to the assessee's lack of education and understanding of tax matters, subject to a payment.

The Tribunal noted that the AO and CIT(A) passed ex-parte orders due to the assessee's failure to furnish evidence and negligence. However, in the interest of natural justice, one more opportunity was granted to the assessee.

The Tribunal followed the decision of the Hon'ble Jurisdictional High Court in TVS Credit Services Ltd. v. DCIT, which held that notices under Section 148 must be issued by the Faceless Assessing Officer (FAO) and not the JAO. Consequently, the notice and consequential assessment order were set aside.

The Tribunal held that the appeal deserved to be dismissed for want of prosecution and for non-compliance with the defects pointed out by the Registry. The appeal was accordingly dismissed.

Following the jurisdictional High Court's decision, the Tribunal held that the notice under Section 148 issued by the Jurisdictional Assessing Officer (JAO) was invalid, as it is mandatory for such notices to be issued by the Faceless Assessing Officer (FAO). Consequently, the reassessment notice and all consequential orders were set aside, with a liberty for the Revenue to seek revival if the Supreme Court reverses the precedent relied upon.

The Tribunal admitted additional evidence (consultancy contracts) filed by the assessee under Rule 29 of the Income Tax (Appellate Tribunal) Rules, 1963, citing difficulties in collating evidence post-Covid. Deeming the evidence crucial to the issue, the Tribunal restored the matter to the AO to examine the fresh evidence and decide on the allowability of the expenditure.

The Tribunal held that the reassessment notice issued by the JAO after March 29, 2022, was invalid as it should have been issued by the FAO, following the jurisdictional High Court's decision in Hexaware Technologies Ltd.

The Tribunal held that the assessee had not earned any exempt income. Relying on the decision of the Madras High Court, it was held that no disallowance is called for u/s 14A when there is no exempt income. The explanation added to Section 14A w.e.f 01.04.2022 was held to be prospective.

The Tribunal held that the sale deed for the property in question pertains to another assessee with a similar name, not the appellant. The Tribunal restored the matter to the AO to verify facts and delete the addition if the documents do not pertain to the assessee.

The Tribunal held that the CIT(A) correctly observed that the assessee should be given another opportunity to present their case before the AO and that the total income should be determined after a thorough examination of facts and evidence. The appeal was dismissed.

The Tribunal held that the receipts from the sale of MLFPS scripts are a capital receipt, not a revenue receipt, and therefore, not taxable. This decision followed previous rulings by the Tribunal and considered amendments to the Income Tax Act.

The Tribunal held that the notice issued by the JAO was invalid as it was not in accordance with the mandatory faceless procedure prescribed by the CBDT e-assessment scheme, 2022. Following the jurisdictional High Court's decision in Hexaware Technologies Ltd., the Tribunal set aside the impugned notice and consequential orders.