ITAT Chennai Judgments — December 2025

KRISHNAN NAGARAJAN,SALEM vs ITO, WARD-1(2), SALEM

ITA 2893/CHNY/2025[2018-19]Status: Disposed23 Dec 2025AY 2018-19Allowed

The Tribunal held that the notice issued by the JAO was invalid and bad in law because it contravened the provisions of Section 151A of the Act and the mandatory Faceless Scheme notified on 29.03.2022. Consequently, the reopening of assessment and the assessment order were vitiated.

B. ANAND BABU,COIMBATORE vs DCIT, CC-3,, COIMBATORE

ITA 2086/CHNY/2025[2017-18]Status: Disposed22 Dec 2025AY 2017-18Allowed

The Tribunal held that the penalty order was barred by limitation as it was passed after the expiry of the six-month period from the end of the month in which action for imposition of penalty was initiated. The Tribunal also noted that the AO was not the competent authority to levy the penalty.

SARAVANAN,TIRUPPUR vs ITO, WARD-1(1), TIRUPUR

ITA 2553/CHNY/2025[2014-15]Status: Disposed22 Dec 2025AY 2014-15Partly Allowed

The Tribunal held that the estimation of profit at 10% by the Assessing Officer was arbitrary. It deemed it appropriate to estimate the net profit at 4% of the contract receipts. The Tribunal also directed the Assessing Officer to allow credit for TDS as reflected in Form 26AS.

B. ANAND BABU,COIMBATORE vs DCIT, CENTRAL CIRCLE-3,, COIMBATORE

ITA 2085/CHNY/2025[2016-17]Status: Disposed22 Dec 2025AY 2016-17Allowed

The Tribunal held that the penalty orders were barred by limitation as per Section 275(1)(c) of the Act, considering the date of initiation of penalty proceedings. Consequently, the appeals were allowed on this legal ground.

MR. B. ANAND BABU,COIMBATORE vs DCIT, CC-3,, COIMBATORE

ITA 2087/CHNY/2025[2019-20]Status: Disposed22 Dec 2025AY 2019-20Allowed

The Tribunal held that the penalty orders were barred by limitation as per Section 275(1)(c) of the Act, considering the date of initiation of penalty proceedings. Consequently, the appeals were allowed on this legal ground.

AKSHAYA PVT. LTD.,CHENNAI vs ITO, CORPORATE WARD-1(1), CHENNAI

ITA 2605/CHNY/2025[2022-23]Status: Disposed22 Dec 2025AY 2022-23Partly Allowed

The Tribunal held that Rule 46A does not permit the CIT(A) to scrutinize the credibility of additional evidence before admitting it. The CIT(A) should have admitted the evidence and forwarded it for a remand report.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs JAYARAM JAYALALITHA, CHENNAI

ITA 3085/CHNY/2025[1997-98]Status: Disposed22 Dec 2025AY 1997-98Allowed

The Tribunal observed that the AO's order was based on the CIT's order which was annulled by the ITAT. Therefore, the additions/disallowances made by the AO in the set-aside assessment were treated as allowed.

VESTAS WIND TECHNOLOGY INDIA PVT. LTD.,CHENNAI vs JCI, CO. RANGE-III, CHENNAI

ITA 319/CHNY/2025[2008-09]Status: Disposed22 Dec 2025AY 2008-09Allowed

The Tribunal held that the AO lacked jurisdiction to substitute the actual sale consideration with a notional market value without a specific statutory provision. Relying on Supreme Court judgments, the Tribunal stated that only real income can be taxed and the Revenue has the burden to prove consideration beyond invoiced amounts.

SHRI SARTH KUMAR SEKKANOR MURUGESAN,CHENNAI vs ITO, NCW-22(4), CHENNAI

ITA 3067/CHNY/2025[2021-22]Status: Disposed22 Dec 2025AY 2021-22Allowed

The Tribunal noted that the issue of FTC is covered by the Madras High Court's decision in Duraiswamy Kumaraswamy, which held that filing Form 67 under Rule 128 is directory, not mandatory. Therefore, the AO was directed to grant the FTC.

KALYANI DISTRIBUTIONS SERVICERS,POLLACHI vs DEPUTY COMMISSIONER OF INCOME TAX, COIMBATORE

ITA 1821/CHNY/2025[2021-22]Status: Disposed22 Dec 2025AY 2021-22Allowed

The Tribunal held that the expenses incurred for repairs on rented premises were for day-to-day operations, recurring in nature, and related to normal wear and tear, not bringing about enduring benefit or new assets. The Tribunal found that the evidence demonstrated the assessee's responsibility for these repairs.

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE-1(1), CHENNAI, CHENNAI vs JOYSON ANAND ABHISHEK SAFETY SYSTEMS PVT LTD, KANCHEEPURAM

ITTPA 26/CHNY/2025[2016-17]Status: Disposed22 Dec 2025AY 2016-17Dismissed

The Tribunal held that the TPO order dated 01.11.2019 is barred by limitation and is void. The Tribunal reasoned that the word 'may' in section 92CA(3A) should be construed as 'shall', and the time period fixed therein must be scrupulously followed. The proviso to the sub-section clarifies the mandatory nature of the time schedule. The Tribunal noted that the date of the TPO order and the Assessment Year were the same as in the case of Saint Gobain India (P.) Ltd. (supra). Respectfully following the binding precedents of the jurisdictional High Court, the Tribunal concluded that the TPO order was barred by limitation and void. Consequently, the Cross Objection filed by the assessee became infructuous. The appeal of the revenue was dismissed.

SARAVANAN,TIRUPPUR vs ITO, WARD-1(1), TIRUPPUR

ITA 2556/CHNY/2025[2015-16]Status: Disposed22 Dec 2025AY 2015-16Partly Allowed

The Tribunal held that the estimation of profit at 10% by the Assessing Officer was arbitrary. It deemed it appropriate to estimate the net profit at 4% of the contract receipts. The Tribunal also directed the Assessing Officer to allow credit for TDS as reflected in Form 26AS.

GOPINATH PALANI,CHENNAI vs ITO, NCW08(2), CHENNAI

ITA 3023/CHNY/2025[2017-18]Status: Disposed22 Dec 2025AY 2017-18Allowed

The Tribunal held that the reason provided by the assessee for the delay in filing the audit report (due to a close relative's hospitalization and need for care) constituted a reasonable cause. Following jurisdictional High Court judgments, the Tribunal decided to delete the penalty.

TPMM AND CO.,TIRUNELVELI vs ITO, WARD-4, TIRUNELVELI

ITA 2711/CHNY/2025[2017-18]Status: Disposed19 Dec 2025AY 2017-18Partly Allowed

The Tribunal held that in the interest of justice, the assessee should be given a last opportunity to appear and file evidence before the AO for a denovo assessment. The impugned orders were set aside, and the appeals were restored back to the AO.

SIDHAMPOONDI PA CULTURAL COOP BANK LTD. S 1392,NAMAKKAL vs ITO, WARD-2,, NAMAKKAL

ITA 3070/CHNY/2025[2019-20]Status: Disposed19 Dec 2025AY 2019-20Allowed

The Tribunal held that the notice under Section 148 was not issued in accordance with the e-assessment scheme, 2022, as it was issued by the JAO and not the NFAC. This was found to be contrary to the scheme and various High Court judgments.

VIMALA,BANGALORE vs INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI , CHENNAI

ITA 3035/CHNY/2025[2016-17]Status: Disposed19 Dec 2025AY 2016-17Partly Allowed

The Tribunal noted that the assessee claimed non-receipt of hearing notices and requested a last opportunity. In the interest of justice, the Tribunal set aside the order and restored the appeal to the CIT(A) for a fresh hearing on merits, subject to a cost of Rs. 2,000/-.

ABAN OFFSHORE LIMIED,CHENNAI vs ACIT, NATIONAL E-CENTRE, DELHI

ITTPA 6/CHNY/2023[2015-16]Status: Disposed19 Dec 2025AY 2015-16Dismissed

The Tribunal held that the appeal could not be proceeded with during the continuance of the proceedings under the Insolvency and Bankruptcy Code, 2016 (IBC). Citing the Supreme Court's decision in Ghanashyam Mishra And Sons vs. Edelweiss Asset Reconstruction and the Jurisdictional Bombay High Court's decision in Murli Industries Limited vs. ACIT, the Tribunal reasoned that once a resolution plan is approved under Section 31 of the IBC, all claims not part of the plan stand extinguished, and no proceedings can be initiated or continued. The Tribunal noted that the present case did not involve a contention from the Department that the claims were part of the resolution plan. Therefore, the appeal was dismissed in limine as not maintainable. The Tribunal granted leave to the appellant to seek restoration of the appeal if necessitated by the orders in the CIRP. The Stay Petition (SA No.56/Chny/2024) was rendered infructuous.

S ALBERT & CO. PVT. LTD.,CHENNAI vs ITO, CORPORATE WAR-6(1), CHENNAI

ITA 2924/CHNY/2025[2011-12]Status: Disposed19 Dec 2025AY 2011-12Dismissed

During the hearing, the assessee's authorized representative submitted that the assessee wished to withdraw the appeals and had filed a petition to that effect. The Tribunal dismissed the appeals as withdrawn.

S ALBERT & CO. PVT. LTD.,CHENNAI vs ITO, CORPORATE WARD-6(1), CHENNAI

ITA 2923/CHNY/2025[2011-12]Status: Disposed19 Dec 2025AY 2011-12Dismissed

During the hearing, the assessee's authorized representative submitted that the assessee wished to withdraw the appeals and had filed a petition to that effect. The Tribunal dismissed the appeals as withdrawn.

TPMM AND CO.,TIRUNELVELI vs ITO, WARD-4,, TIRUNELVELI

ITA 2710/CHNY/2025[2017-18]Status: Disposed19 Dec 2025AY 2017-18Partly Allowed

The Tribunal held that in the interest of justice, the assessee should be given a last opportunity to appear and file evidence before the AO for a denovo assessment. The impugned orders were set aside, and the appeals were restored back to the AO.

R 249 KULITHALAI CO-OP PARD BANK LIMITED,KARUR vs INCOME TAX OFFICER, KARUR

ITA 2543/CHNY/2025[2022-23]Status: Disposed18 Dec 2025AY 2022-23Partly Allowed

The Tribunal held that the CIT(A) erred in upholding the CPC's action without awaiting the outcome of the condonation petition. The matter was restored to the AO to decide afresh after the decision on the condonation petition.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs JAYA PUBLICATIONS, CHENNAI

ITA 3083/CHNY/2025[2006-07]Status: Disposed18 Dec 2025AY 2006-07Dismissed

The Tribunal found that the appeal did not fall under any exceptions to the CBDT Circular and was not maintainable due to the low tax effect.

CEM BUSINESS SOLUTIONS PVT. LTD.,CHENNAI vs ITO, , CHENNAI

ITA 2614/CHNY/2025[2013-14]Status: Disposed18 Dec 2025AY 2013-14Partly Allowed

The Tribunal condoned the delay in filing the appeal before the CIT(A) and set aside the order of the CIT(A). The matter was remitted back to the CIT(A) for adjudication afresh, providing a reasonable opportunity to the assessee.

THE TRIPLICANE COOP CREDIT SOCIETY LTD.,CHENNAI vs ITO, WARD-9(1), CHENNAI

ITA 2672/CHNY/2025[2018-19]Status: Disposed18 Dec 2025AY 2018-19Allowed

The Tribunal held that since the delay in filing the ITR was condoned by the Competent Authority, and the assessee had submitted the necessary documents, the deduction under Section 80P should be allowed. The AO's denial was therefore set aside.

PRAKASHCHAND,CHENNAI vs ITO, TDS WARD-1, CHENNAI

ITA 3065/CHNY/2025[2014-15]Status: Disposed18 Dec 2025AY 2014-15Allowed

The Tribunal held that for assessment years prior to June 1, 2015, the levy of late fee under Section 234E while processing TDS returns under Section 200A was without authority and invalid. Consequently, the Assessing Officer was directed to delete such fees.

SAINT-GOBAIN INDIA PRIVATE LIMITED,CHENNAI vs DCIT NCC 8(1), CHENNAI

ITA 1505/CHNY/2024[2016-17]Status: Disposed18 Dec 2025AY 2016-17Allowed

The Tribunal held that since the Transfer Pricing Order was void ab initio due to being time-barred, the assessee ceased to be an eligible assessee for the purpose of Section 144C. Consequently, the final assessment order passed beyond the normal limitation period was also void.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8,, CHENNAI

ITA 2979/CHNY/2025[2018-19]Status: Disposed18 Dec 2025AY 2018-19Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8,, CHENNAI

ITA 2977/CHNY/2025[2015-16]Status: Disposed18 Dec 2025AY 2015-16Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8, CHENNAI

ITA 2976/CHNY/2025[2013-14]Status: Disposed18 Dec 2025AY 2013-14Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8,, CHENNAI

ITA 2980/CHNY/2025[2020-21]Status: Disposed18 Dec 2025AY 2020-21Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.

DEPUTY COMMISSIONER OF INCOMETAX, CHENNAI vs SAINT - GOBAIN INDIA PRIVATE LIMITED, CHENNAI

ITA 1672/CHNY/2024[2016-17]Status: Disposed18 Dec 2025AY 2016-17Allowed

The Tribunal held that since the Transfer Pricing Order was void ab initio due to being time-barred, the assessee ceased to be an eligible assessee for the purpose of Section 144C. Consequently, the final assessment order passed beyond the normal limitation period was also void.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8,, CHENNAI

ITA 2975/CHNY/2025[2007-08]Status: Disposed18 Dec 2025AY 2007-08Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8, CHENNAI

ITA 2978/CHNY/2025[2019-20]Status: Disposed18 Dec 2025AY 2019-20Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.

M/S. CITY UNION BANK LTD.,,KUMBAKONAM vs PCIT,, MADURAI

ITA 1126/CHNY/2024[2018-19]Status: Disposed18 Dec 2025AY 2018-19Allowed

The Tribunal held that the PCIT erred in invoking Section 263 as the AO had made necessary inquiries and adopted a plausible view. Furthermore, the issues in question had been decided in favor of the assessee in its own case by a coordinate bench of the Tribunal.

KALAVATHY NAGARAJAN,TIRUVARUR vs ACIT, CIRCLE-2(1), TRICHY

ITA 2832/CHNY/2025[2019-20]Status: Disposed18 Dec 2025AY 2019-20Remanded

The ITAT found the assessee's reasons for delay (health issues and consultant's lapse) to be reasonable and condoned the 261-day delay in filing the appeal before the FAA. Despite deprecating the assessee's non-response to the AO's notices, the ITAT remitted the matter back to the Assessing Officer for fresh adjudication, directing the AO to provide a reasonable opportunity of hearing and the assessee to cooperate.

YOOSUF RAHUMAN MOHAMED IBRAHIM,SIVAGANGA vs ITO, WARD-1,, PUDUKKOTTAI

ITA 2946/CHNY/2025[2018-19]Status: Disposed18 Dec 2025AY 2018-19Partly Allowed

The Tribunal held that the CIT(A) was not justified in dismissing the appeal on grounds of delay. The Tribunal found that the appeal was filed within the limitation period, considering the date of knowledge of the assessment order. The order of the CIT(A) was set aside and the matter was remanded for de novo adjudication on merits.

PRAKASHCHAND,CHENNAI vs ITO, TDS WARD 1,, CHENNAI

ITA 3064/CHNY/2025[2013-14]Status: Disposed18 Dec 2025AY 2013-14Allowed

The Tribunal held that for assessment years prior to June 1, 2015, the levy of late fee under Section 234E while processing TDS returns under Section 200A was without authority and invalid. Consequently, the Assessing Officer was directed to delete such fees.

PRAKASHCHAND,CHENNAI vs ITO, TDS WARD-1,, CHENNAI

ITA 3061/CHNY/2025[2014-15]Status: Disposed18 Dec 2025AY 2014-15Allowed

The Tribunal held that for assessment years prior to June 1, 2015, the levy of late fee under Section 234E while processing TDS returns under Section 200A was without authority and invalid. Consequently, the Assessing Officer was directed to delete such fees.

SULOCHANA COTTON SPINNING MILLS (P) LTD.,TIRUPPUR vs DCIT CIRCLE 1, TIRUPPUR

ITTPA 85/CHNY/2024[2021-22]Status: Disposed18 Dec 2025AY 2021-22Partly Allowed

The Tribunal rejected the assessee's grounds claiming deduction under Section 80-IA in respect of REC receipts. It followed the ratio decidendi from the decisions of the Hon'ble Andhra Pradesh High Court in CIT Vs My Home Power Ltd and the Madras High Court, which held that carbon credits (RECs) are not directly linked to power generation but are an offshoot of environmental concerns, not directly linked to the business. Regarding the alternate plea that REC receipts are capital in nature, the Tribunal noted that the legal position changed with the introduction of Section 115BBG w.e.f. 01.04.2018, which specifically taxes the sale of carbon credits (RECs) at 10%. The Tribunal found that the decision in Satia Industries Ltd. was rendered prior to this change and thus not applicable. Coordinate Benches have treated RECs as akin to carbon credits. Therefore, the Tribunal found no infirmity in the action of lower authorities treating the income from sale of RECs as ‘other income’ and taxing it under Section 115G of the Act. The ground regarding loss on sale of machinery was dismissed as not pressed. The ground relating to MAT Credit was disposed of with a direction to the AO to re-compute it.

MEENAKSHI ACHI TRUST,MADURAI vs CIT, EXMEPTIONS,, CHENNAI

ITA 3010/CHNY/2025[-]Status: Disposed18 Dec 2025Partly Allowed

The Tribunal noted that the hearing notice was not received by the assessee and granted one more opportunity. The impugned order was set aside, and the appeal was restored to the CIT(E) for a fresh hearing on merits.

BADMA BARIBOORANAM,TUTICORIN vs ITO, WARD-1, TUTICORIN

ITA 3498/CHNY/2025[2015-16]Status: Disposed18 Dec 2025AY 2015-16Allowed

The Tribunal held that the assessment order passed by the NFAC was bad in law, relying on the decision of the Hon'ble High Court of Madras in TVS Credit Services Ltd. v. DCIT. The Tribunal quashed the assessment order.

PRAKASHCHAND,CHENNAI vs ITO, TDS WARD-1,, CHENNAI

ITA 3063/CHNY/2025[2013-14]Status: Disposed18 Dec 2025AY 2013-14Allowed

The Tribunal held that for assessment years prior to June 1, 2015, the levy of late fee under Section 234E while processing TDS returns under Section 200A was without authority and invalid. Consequently, the Assessing Officer was directed to delete such fees.

ALLAVUDIN MUHAPADMA BEEVI,SALEM vs ITO, WARD-1(2), SALEM

ITA 2961/CHNY/2025[2016-17]Status: Disposed18 Dec 2025AY 2016-17Partly Allowed

The Tribunal held that the CIT(A) dismissed the appeal for non-prosecution without proper opportunity of hearing, breaching the principles of natural justice. The order passed by the CIT(A) was quashed and set aside.

CPT ELECY SYSTEM EMPLOYEES COOP T&C SOCIETY,KANCHEEPURAM vs ITO, WARD-1,, KANCHEEPURAM

ITA 3058/CHNY/2025[2020-21]Status: Disposed18 Dec 2025AY 2020-21Allowed

The Tribunal held that the notice under Section 148 was not issued in accordance with the CBDT's e-assessment scheme, which mandates automated allocation and faceless issuance. Relying on High Court judgments, the Tribunal set aside the notice.

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs SUBRAMANIAM KATHIRESAN, CHENNAI

ITA 899/CHNY/2025[2014-15]Status: Disposed18 Dec 2025AY 2014-15Dismissed

The Tribunal held that the 'Satisfaction Note' prepared by the AO did not satisfy the legal requirement of mentioning that income represented in the form of an asset worth Rs. 50 lakhs or more had escaped assessment for AY 2014-15. Therefore, the assumption of jurisdiction under Section 153C was bad in law.

YOOSUF RAHUMAN MOHAMED IBRAHIM,SIVAGANGA vs ITO, WARD-1,, PUDUKOTTAI

ITA 2947/CHNY/2025[2018-19]Status: Disposed18 Dec 2025AY 2018-19Partly Allowed

The Tribunal held that the CIT(A) was not justified in dismissing the appeal on grounds of delay. The Tribunal found that the appeal was filed within the limitation period, considering the date of knowledge of the assessment order. The order of the CIT(A) was set aside and the matter was remanded for de novo adjudication on merits.

SURESHKUMAR,CHENNAI vs ITO, NON CORP WARD 6(1), CHENNAI

ITA 2963/CHNY/2025[2019-20]Status: Disposed18 Dec 2025AY 2019-20Partly Allowed

The Tribunal held that the CIT(A) erred in dismissing the appeal solely for non-prosecution without considering the merits of the case. Citing legal precedent, the Tribunal emphasized that even an ex-parte disposal requires a decision on merits after affording a reasonable opportunity of hearing.

SWAMEDAS PANITHASAN,CHENNAI vs ITO, NON-CORPORATE WARD 17(2) , CHENNAI

ITA 3056/CHNY/2025[2015-16]Status: Disposed18 Dec 2025AY 2015-16Allowed

The Tribunal held that the notice under Section 148 was not issued in accordance with the e-assessment scheme, 2022, which mandates issuance through automated allocation in a faceless manner. Following jurisdictional High Court decisions, the Tribunal set aside the impugned notice.

PUDHUREDDIYUR RAJU KALAIMANI,HOSUR vs ITO, WARD-1,, HOSUR

ITA 1740/CHNY/2025[2017-18]Status: Disposed18 Dec 2025AY 2017-18Allowed

The Tribunal held that leave encashment received at the time of cessation of employment, even on resignation and subsequent re-employment, is eligible for exemption under Section 10(10AA) of the Act, as per judicial precedents. Denial based solely on Form 26AS mismatch during processing is not sustainable.

INDIAN OVERSEAS BANK,CHENNAI vs DCIT, NCC-8,, CHENNAI

ITA 2981/CHNY/2025[2021-22]Status: Disposed18 Dec 2025AY 2021-22Allowed

The Tribunal held that orders passed by the Assessing Officer (AO) while giving effect to appellate orders are made under Section 143 or 144 of the Act, making them appealable under Section 246(c). Therefore, the FAA's dismissal was set aside.