ITAT Chennai Judgments — January 2026

The Tribunal noted that as per section 80AC of the Act, deductions under Chapter VI-A are allowable only if the return of income is filed within the time prescribed under section 139(1). Since the assessee failed to do so, the Assessing Officer rightly denied the deduction, and the CIT(A) confirmation was justified.

The Tribunal noted that a Co-ordinate Bench had previously held the order under section 263 of the Act to be invalid. The CIT(A) had dismissed the assessee's appeal as infructuous based on this finding. The DR conceded that if the order under section 263 is invalid, the order under section 147 read with section 263 cannot stand.

The Tribunal held that the assessee had shown sufficient cause for the delay in filing the appeal before the CIT(A) due to illness, oversight, and lack of awareness. Procedural delays should not impede substantial justice. The CIT(A) had dismissed the appeal without adjudicating on merits.

The Tribunal noted that the CIT(A) had not discussed the merits of the case. Therefore, the Tribunal decided to remand the matter back to the CIT(A) to decide the issues on merits after providing an opportunity to the assessee.

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. Citing various High Court judgments and the Supreme Court's dismissal of an SLP, the Tribunal found the notice to be invalid.

The Tribunal held that the return was filed within the due date as the assessee had discharged its statutory obligation by dispatching the verified ITR-V within the prescribed time, and any delay in transit should not penalize the appellant. Section 27 of the General Clauses Act was invoked to presume service.

The Tribunal found the reasons for the delay to be reasonable and directed the CIT(A) to condone the delay and decide the issues on merits. The penalty appeals were also remanded for fresh adjudication.

The Tribunal noted that as per section 80AC of the Act, deductions under Chapter VI-A are allowable only if the return of income is filed within the time prescribed under section 139(1). Since the assessee failed to do so, the Assessing Officer rightly denied the deduction, and the CIT(A) confirmation was justified.

The Tribunal condoned the delay in filing the appeals before the CIT(A), stating that a party should not suffer for the default of their representative. The matter was restored to the CIT(A) for adjudication on merits after granting an opportunity to the assessee.

The Tribunal held that the assessee should be afforded one final opportunity to prosecute the appeal before the CIT(A). The impugned order was set aside and the matter was restored to the CIT(A) for de novo adjudication.

The Tribunal noted that the CIT(A) dismissed the appeal for non-prosecution without considering the merits. The CIT(A) is legally obligated to dispose of appeals on merits, even if ex-parte. Therefore, the matter needs to be remanded.

The assessee's appeal before the Ld. CIT(A) was dismissed in limine due to a delay of 203 days. The assessee explained the delay was due to family and health issues, which were supported by medical reports. The Tribunal condoned the delay and set aside the orders of the lower authorities.

The Tribunal noted that the CIT(A) dismissed the appeal for non-prosecution without considering the merits. The CIT(A) is legally obligated to dispose of appeals on merits, even if ex-parte. Therefore, the matter needs to be remanded.

The Tribunal held that the assessee was not afforded adequate opportunity to explain and justify the delay in filing the appeal. The CIT(A) issued only one notice for hearing and proceeded to pass the order without providing a reasonable opportunity.

The Tribunal condoned the delay in filing the appeals before the CIT(A), stating that a party should not suffer for the default of their representative. The matter was restored to the CIT(A) for adjudication on merits after granting an opportunity to the assessee.

The Tribunal condoned the delay in filing the appeals before the CIT(A), stating that a party should not suffer for the default of their representative. The matter was restored to the CIT(A) for adjudication on merits after granting an opportunity to the assessee.

The Tribunal condoned the delay in filing the appeals before the CIT(A), stating that a party should not suffer for the default of their representative. The matter was restored to the CIT(A) for adjudication on merits after granting an opportunity to the assessee.

The Tribunal condoned the delay in filing the appeals before the CIT(A), stating that a party should not suffer for the default of their representative. The matter was restored to the CIT(A) for adjudication on merits after granting an opportunity to the assessee.

The Tribunal held that the levy of penalty under section 271(1)(C) is automatic when income is assessed under section 148, as it is linked to the original return. The argument that no penalty is leviable for income assessed on an estimate basis was deemed inapplicable in cases assessed under section 148.

The Tribunal held that issuing a notice and passing an assessment order in the name of a deceased person is void ab initio and a nullity in the eyes of law. Such a fundamental jurisdictional defect is not curable under Section 292B.

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 NFAC. This rendered the subsequent proceedings and assessment order vitiated.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) of the Income Tax Act was defective and vague because the Assessing Officer failed to strike off the inappropriate words, thus not clearly specifying whether the penalty was for concealment of income or furnishing inaccurate particulars. This violated the principles of natural justice. The delay in filing the appeals was condoned based on sufficient cause.

The Tribunal held that the levy of penalty under section 271(1)(C) is automatic when income is assessed under section 148, as it is linked to the original return. The argument that no penalty is leviable for income assessed on an estimate basis was deemed inapplicable in cases assessed under section 148.

The Tribunal held that the levy of penalty under section 271(1)(C) is automatic when income is assessed under section 148, as it is linked to the original return. The argument that no penalty is leviable for income assessed on an estimate basis was deemed inapplicable in cases assessed under section 148.

The Tribunal held that the levy of penalty under section 271(1)(C) is automatic when income is assessed under section 148, as it is linked to the original return. The argument that no penalty is leviable for income assessed on an estimate basis was deemed inapplicable in cases assessed under section 148.

The Tribunal held that the incorrect mention of the clause was an inadvertent and curable defect, not an illegality. They found reasonable cause for the delay in the second application due to the rejection of the first.

The Tribunal held that the levy of penalty under section 271(1)(C) is automatic when income is assessed under section 148, as it is linked to the original return. The argument that no penalty is leviable for income assessed on an estimate basis was deemed inapplicable in cases assessed under section 148.

The Tribunal found the reasons for the delay to be reasonable and directed the CIT(A) to condone the delay and decide the issues on merits. The penalty appeals were also remanded for fresh adjudication.

The Tribunal held that the penalty notice issued under Section 274 read with Section 271(1)(c) of the Income Tax Act was defective and vague because the Assessing Officer failed to strike off the inappropriate words, thus not clearly specifying whether the penalty was for concealment of income or furnishing inaccurate particulars. This violated the principles of natural justice. The delay in filing the appeals was condoned based on sufficient cause.

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 jurisdictional assessing officer (JAO) and not the National Faceless Assessment Centre (NFAC). This violated the mandatory faceless procedure.

The Tribunal found the reasons for the delay to be reasonable and directed the CIT(A) to condone the delay and decide the issues on merits. The penalty appeals were also remanded for fresh adjudication.

The Tribunal found the reasons for the delay to be reasonable and directed the CIT(A) to condone the delay and decide the issues on merits. The penalty appeals were also remanded for fresh adjudication.

The Tribunal noted that the CIT(A) dismissed the appeal for non-prosecution without considering the merits. The CIT(A) is legally obligated to dispose of appeals on merits, even if ex-parte. Therefore, the matter needs to be remanded.

The Tribunal found the reasons for the delay to be reasonable and directed the CIT(A) to condone the delay and decide the issues on merits. The penalty appeals were also remanded for fresh adjudication.

The Tribunal noted that the appeal was dismissed by the CIT(A) due to non-compliance by the assessee. Therefore, the Tribunal decided to remand the matter back to the CIT(A) to consider all issues, including legal grounds.

The Tribunal held that the notice issued under Section 148 was not in accordance with the e-assessment scheme, which mandates faceless issuance. Therefore, the notice and subsequent proceedings were vitiated.

The Tribunal, considering the substantial additions and the peculiar facts, found it in the interest of justice to grant the assessee one final opportunity to present their case. The impugned order was set aside, and the matter was restored to the Assessing Officer for a de novo assessment.

The Tribunal held that since the amalgamation was effective prior to the declaration of the dividend, the dividend payment lost its character as a dividend and became a payment to self, thus not taxable as income. Relying on the Gujarat High Court's decision in Torrent (P.) Ltd. vs CIT, the Tribunal found merit in the assessee's argument.

The assessee's appeal before the Ld. CIT(A) was dismissed in limine due to a delay of 203 days. The assessee explained the delay was due to family and health issues, which were supported by medical reports. The Tribunal condoned the delay and set aside the orders of the lower authorities.

The Tribunal considered the submissions and decided that in the interest of justice, the assessee should be given a last opportunity to appear and file evidence before the CIT(A). The impugned order was set aside, and the appeal was restored to the CIT(A) for a fresh hearing on merits.

The Tribunal noted that a CBDT Notification dated 29.03.2022 formulated the e-assessment scheme, which mandates automated allocation and issuance of notices under Section 148 in a faceless manner. Multiple High Court judgments have affirmed that only the FAO has the jurisdiction to issue such notices. The Tribunal followed the jurisdictional High Court's decision in TVS Credit Services Ltd. v. DCIT, which held that notices issued by JAO are invalid.

The Tribunal held that the notice issued under Section 148 on April 1, 2022, was barred by limitation as it was issued beyond the six-year period from the end of AY 2015-16. Consequently, the reassessment proceedings and the addition were quashed.

The Tribunal, considering the submissions and the interest of justice, decided to remand the matters back to the CIT(E). The assessee was granted one more opportunity to furnish the required details.

The Tribunal noted that the CIT(A) dismissed the appeal for non-prosecution without considering the merits. The CIT(A) is legally obligated to dispose of appeals on merits, even if ex-parte. Therefore, the matter needs to be remanded.

The Tribunal, considering the submissions and the interest of justice, decided to remand the matters back to the CIT(E). The assessee was granted one more opportunity to furnish the required details.

The Tribunal held that the assessee should not be precluded from opting for the new tax regime in the current year, even if the option was not validly exercised in a prior year due to belated filing. The AO/CPC was directed to allow the assessee to opt for the new tax regime.

The Tribunal noted that the quantum appeal related to the same assessment year had been set aside by a co-ordinate bench. Consequently, since the penalty was consequential to the additions made in the quantum appeal, the penalty itself does not survive.

The Tribunal applied the principle of telescoping, allowing the assessee to offset unaccounted income offered to tax against seized cash. The Tribunal confirmed the deletion of the impugned addition by the CIT(A).

The Tribunal applied the principle of telescoping, allowing the assessee to offset unaccounted income offered to tax against seized cash. The Tribunal confirmed the deletion of the impugned addition by the CIT(A).

The Tribunal applied the principle of telescoping, allowing the assessee to offset unaccounted income offered to tax against seized cash. The Tribunal confirmed the deletion of the impugned addition by the CIT(A).