ITAT Chennai Judgments — March 2026

The Tribunal held that the service of notice through the ITBA portal by the CIT(A) was not valid as per Section 282(1) of the Income Tax Act and Rule 127(1). Since principles of natural justice were violated due to lack of proper notice, the matter was remitted back to the CIT(A) for de novo adjudication.

The Tribunal held that the notices issued by the CIT(A) through the ITBA portal were not valid service as per Section 282(1) of the Income Tax Act and Rule 127(1). Therefore, the principles of natural justice were violated.

The Tribunal condoned the delay in filing appeals before the CIT(A) and set aside the CIT(A)'s order. The matter was remitted back to the AO for a fresh assessment after providing the assessee with a reasonable opportunity.

The Tribunal condoned the delay in filing the appeals before the CIT(A), noting the assessee's plea of illness affecting the tax consultant's ability to monitor the portal. The Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for denovo assessment.

The Tribunal held that the assessee's explanation for the 851-day delay in filing the appeal was general and lacked specific details or material evidence, failing to establish a 'sufficient cause'.

The Tribunal noted that the assessee failed to appear before the AO and CIT(A), despite multiple opportunities. The Tribunal set aside the order of CIT(A) and remitted the matter back to the AO for a fresh assessment, providing the assessee an opportunity to be heard.

The Tribunal noted that the assessee had already received relief regarding the condonation of delay in filing the application. Therefore, the Tribunal decided to dismiss both appeals as withdrawn.

The Tribunal condoned the delay in filing the appeal due to the assessee's illness, noting that the Department did not controvert the affidavit. The Tribunal found that both the assessment order and the CIT(A)'s order were ex parte. Therefore, the matter was remanded to the Assessing Officer for a denovo assessment, allowing the appellant an opportunity of hearing.

The Tribunal observed that the incidence of melting loss cannot be ruled out but the onus is on the assessee to prove it. The Tribunal found that the CIT(A) erred in deleting the addition without properly examining the accounting treatment and industry standards, and also erred in holding that no disallowance can be made without rejecting the books of accounts.

The Tribunal noted that the assessee had already received relief by the condonation of delay in filing the applications. Therefore, the appeals were dismissed as withdrawn.

The Tribunal accepted the assessee's explanation for the 401-day delay, noting her NRI status and that she became aware of the penalty order only after receiving recovery notices during a visit to India. The Tribunal condoned the delay, set aside the CIT(A)'s order, and remitted the penalty appeal back to the CIT(A) for a fresh decision on merits, granting the assessee another opportunity.

The Tribunal noted that there was a delay in filing the appeals. However, the assessee explained that they were unaware of the CIT(A)'s orders. The Tribunal condoned the delay and admitted the appeals. Finding that the CIT(A) had dismissed the appeals due to non-participation, the Tribunal decided to grant one more opportunity.

The Tribunal noted that no one appeared for the assessee. Both appeals were found to have a tax effect less than the monetary limit of Rs. 60 lakhs, as per CBDT Circular No. 09 of 2024. Therefore, the appeals were dismissed as not maintainable.

The Tribunal observed that the tax effect in both appeals was below the monetary limit set by CBDT Circular No. 09 of 2024 for filing appeals before the ITAT. Therefore, the appeals were dismissed as withdrawn/not maintainable, with the liberty for the Revenue to apply for recalling the order if any exceptions applied.

The Tribunal held that the addition of Rs.8,04,450 related to cash deposits handled in connection with Business Correspondent (BC) activities and was not unexplained income, thus deleting this addition. Regarding the Rs.4,41,000 transferred from the spouse, the Tribunal found that while the source of the spouse's deposit wasn't fully substantiated, the banking trail was established, and therefore sustained 50% of the addition (Rs.2,20,500) and deleted the rest. The addition of Rs.41,746 for undisclosed interest income was confirmed.

The Tribunal held that the assessee had voluntarily surrendered the claim and made a full and true disclosure of all material facts at the time of filing the revised return, which was based on prevailing judicial pronouncements. Therefore, the penalty levied under Section 270A(8) r.w.s. 270A(9) was unwarranted.

The Commissioner of Income Tax (Appeal) set aside the AO's assessment order and remitted the case back to the AO for fresh assessment. The Tribunal noted that the AO's order was based on available information and partial submissions, estimating income and rejecting books of accounts. The Tribunal found no infirmity in the CIT(A)'s order.

The Tribunal held that Section 56(2)(vii)(b) is not applicable as there was no difference between the sale consideration and the stamp duty value, and the full consideration was paid via banking channels. The Tribunal further held that Section 69 is also not applicable as the investment was recorded and the consideration was explained through banking channels.

The Tribunal set aside the CIT(A)'s order and directed the AO to assess the assessee's income following the approach adopted for A.Y. 2012-13. It estimated income from 4 lorries at Rs. 2,40,000/- under section 44AE and estimated business income from lorry booking at 8% of the remaining credits (Rs. 8,23,119/-), totaling Rs. 65,850/-.

The Tribunal noted that there was a delay in filing the appeals, which was condoned due to sufficient cause shown by the assessee. The assessee claimed ignorance of the CIT(A)'s notices due to not checking the income tax portal. The Tribunal found that the CIT(A) had provided opportunities for hearing but the assessee did not respond.

The Tribunal found merit in the assessee's explanation, stating that the delay in uploading the report was procedural and technical glitches are a reasonable cause in the digital environment. The Tribunal noted that the audit report was filed before the assessment was completed, causing no prejudice to the revenue.

The Tribunal condoned the delay in filing the appeals, subject to the assessee paying a consolidated amount to the State Legal Aid Authority. The quantum assessments were set aside and restored to the AO for fresh assessment, and the penalty appeals were rendered infructuous.

The Tribunal condoned the delay in filing the appeals, subject to the assessee depositing Rs. 20,000/- with the State Legal Aid Authority. The Tribunal set aside the ex-parte orders of the AO and the impugned orders of the CIT(A), restoring the cases for fresh assessment.

The Tribunal condoned the delay in filing the appeals, subject to the assessee paying ₹20,000 to the State Legal Aid Authority. The ex-parte assessment orders were set aside, and the cases were restored to the AO for fresh assessment after hearing the assessee. Penalty appeals were rendered infructuous.

The Tribunal set aside the impugned order of the CIT(A) and remitted the matter back for fresh adjudication. The CIT(A) is directed to provide adequate opportunity to the assessee to file written submissions and documentary evidences and decide the issue in accordance with law. A legal ground challenging the validity of a notice under Section 143(2) for being unsigned was not pressed by the assessee.

The CIT(A) quashed the notices issued u/s 148, holding that the jurisdiction to issue such notices vests with the Faceless Assessing Officer (FAO) as per the relevant notifications and amendments. The Tribunal, considering a proposed amendment to the Finance Bill and Supreme Court orders, decided to remand the matter for fresh consideration.

The Tribunal set aside the ex-parte order of the CIT(A) and remitted the matter back for fresh adjudication, directing the FAA to provide a reasonable opportunity of hearing to the assessee.

The CIT(A) found that the assessee, a small businessman with limited education, was engaged in milk trading and had provided sufficient evidence to explain the nature and source of cash deposits and withdrawals from his business. The CIT(A) deleted the additions made by the AO.

The Tribunal held that the payments made to Mutual Fund Distributors were not in the nature of technical services, following its own earlier orders. It also found no infirmity in the CIT(A)'s deletion of disallowance under Section 14A, deeming it a double disallowance.

The Tribunal condoned the delay in filing appeals, noting the assessee's genuine lack of awareness due to technological limitations and remote location. The Tribunal set aside the Ld.CIT(A)'s orders and restored the assessments to the AO for fresh consideration after hearing the assessee.

The Tribunal held that for the first two remittances of PF contribution, there was no infirmity in the CIT(A)'s order. However, for the third remittance falling on a Sunday, the assessee's payment on the next working day was considered sufficient compliance. For TDS, the matter was remanded for fresh adjudication due to evidence of deposit appearing on record.

The Tribunal held that a fresh return is not required if the assessee informs the AO to treat the earlier return as filed in response to the Section 148 notice. The Tribunal found that no notice under Section 143(2) was issued, rendering the reassessment invalid.

The Tribunal dismissed the Revenue's appeal, affirming the CIT(A)'s decision. It held that the assessee had already offered the difference in stock valuation as business income in their return. The difference arose from adopting a GP ratio to the total valuation, and there was no finding of actual 'excess stock' by the Assessing Officer. Therefore, the addition under Section 69B was not justified.

The Tribunal noted that the assessee was issued only one notice by the FAA and had responded to it, requesting more time. However, no further opportunity was granted. The Tribunal found it appropriate to remit the matter back to the FAA for a fresh examination.

The Tribunal found the assessee's reasons for delay genuine, noting electronic notices were not responded to due to lack of digital literacy and remote location. It condoned the delay in filing appeals, provided the assessee remits ₹20,000 to the State Legal Aid Authority. Citing the principle of natural justice, the Tribunal set aside the CIT(A)'s orders and remanded the quantum assessments back to the AO for fresh de-novo assessment after hearing the assessee. The penalty appeals were deemed infructuous, with the AO to decide on penalty initiation after fresh assessments.

The Tribunal condoned the delay in filing the appeal and admitted it for adjudication. While noting the assessee's non-participation, the Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for fresh adjudication after providing a reasonable opportunity to the assessee.

The Tribunal condoned the delay in filing the appeals, finding the assessee's reasons for delay to be genuine and not fabricated. The Tribunal directed the assessee to pay a consolidated amount to the State Legal Aid Authority and set aside the orders of the Ld.CIT(A), restoring the assessments to the AO for fresh assessment.

The Tribunal, relying on decisions of the Hon'ble Madras High Court, held that interest income earned by a Co-operative Society from investments made with another Co-operative Society, including a District Central Co-operative Bank, is eligible for deduction under Section 80P(2)(a)(i) and Section 80P(2)(d) of the Income Tax Act. The High Court had clarified that a Cooperative Bank does not cease to be a Cooperative Society for the purpose of these deductions, despite engaging in banking activities with the general public.

The Tribunal held that the order of the CIT(A) dismissing the appeal was not infirm, as the assessee was not entitled to the deduction for non-filing the return within the prescribed time. Consequently, the grounds raised by the assessee were dismissed.

The Tribunal noted that the jurisdictional Assessing Officer (JAO) lacked the jurisdiction to issue the notice under Section 148, as this power vested with the Faceless Assessing Officer (FAO) as per relevant notifications. Citing High Court decisions, the Tribunal found the notice issued by the JAO to be ultra vires.

The Tribunal held that interest income earned by a cooperative society from its investments with another cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income Tax Act. The Tribunal relied on the decisions of the Hon'ble Madras High Court in similar cases, which clarified that a cooperative bank, if registered under the relevant act, is still considered a cooperative society for the purpose of this deduction.

The Tribunal condoned the delay in filing the appeals, directing the assessee to pay ₹20,000/- to the State Legal Aid Authority. The appeals were restored to the AO for fresh assessment, and the penalty appeals were rendered infructuous pending fresh assessment.

The Tribunal held that the assessee's explanation for the SBN deposit as sale proceeds from genuine business sales was supported by records. The AO's addition u/s 68 was considered untenable as it amounted to double addition, and the Ld.CIT(A)'s deletion of the addition was upheld.

The Tribunal held that the delay in filing Form 68 was bonafide and should be condoned, following the precedent set by the Hon'ble High Court in Natarajan Anandh Kumar v. DCIT. The impugned order rejecting the application for immunity was quashed.

The Tribunal held that the assessee's explanation regarding the cash balance of ₹26,75,440/- as being from withdrawals was acceptable, explaining its source. However, the remaining ₹22,40,560/- was claimed as sales realization and recorded in the audited books, which were not rejected by the AO. Therefore, confirming the addition would be a double addition.

The Tribunal found the assessee's reason for delay to be genuine, considering the circumstances of remote location and lack of digital literacy. The Tribunal condoned the delay on the condition of a ₹20,000 payment to the State Legal Aid Authority.

The Tribunal held that interest earned by a cooperative society from its investments in a cooperative bank is eligible for deduction under Section 80P(2)(a)(i) and 80P(2)(d) of the Income Tax Act. The Tribunal relied on decisions of the Madras High Court, which had addressed similar issues.

The Tribunal held that payments to mutual fund distributors were not in the nature of technical services or royalty, and that the deletion of disallowance under Section 14A by the CIT(A) was justified. The delay in filing the appeals by the Revenue was condoned.

The Tribunal held that the comparable company 'Bizsense Solutions Pvt Ltd' was functionally dissimilar to the assessee, as Bizsense was engaged in software design and development while the assessee provided routine ITeS services. Therefore, Bizsense should be excluded from the list of comparables for determining the Arm's Length Price (ALP).