ITAT Chennai Judgments — April 2026

The Tribunal held that the reassessment proceedings were initiated based on information already available with the AO at the time of the original assessment, thus making the reopening bad in law. Consequently, the reassessment proceedings were quashed.

The Tribunal found that the appeal was a duplication and therefore non-maintainable. Consequently, the appeal was dismissed as infructuous.

The Tribunal held that the additions were not sustainable as they were based on loose sheets and statements without sufficient corroborative evidence. The reassessment for AY 2009-10 was also vitiated due to jurisdictional grounds of limitation.

The Tribunal held that the additions were not sustainable as they were based on loose sheets and statements without sufficient corroborative evidence. The reassessment for AY 2009-10 was also vitiated due to jurisdictional grounds of limitation.

The Tribunal condoned the delay in one appeal and, in the interest of justice, remitted the matters back to the FAA. The assessee was directed to furnish supporting evidence and an affidavit to substantiate the reasons for the delay.

For AY 2018-19, the Tribunal held that the TPO was not justified in determining the ALP of management and testing & validation services at Nil. The TPO rejected the assessee's benchmarking analysis without demonstrating the applicability of Section 92C(3) of the Act and determined the ALP at Nil using the 'Other Method' without any comparable uncontrolled transaction, which is not sustainable. The assessee had adequately demonstrated the nature of services and their benefits. The Tribunal found that the assessee's aggregated approach under TNMM, reporting a margin of 20.57% (higher than comparables), was acceptable, and the TPO's rejection was unsubstantiated. The disallowance was deleted. For AY 2020-21, regarding notional interest on outstanding receivables, the Tribunal respectfully followed the Coordinate Bench's decision in the assessee's own case for AY 2021-22. It was held that where receivables are closely linked to the main transaction and working capital adjustments are granted under TNMM, no separate TP adjustment for notional interest is warranted, especially when the assessee is debt-free. The addition was directed to be deleted. Regarding the disallowance of Rs. 43,09,815 under Section 43B, the Tribunal noted that this issue was not adjudicated in the draft or final assessment orders, nor was it raised before the AO or DRP. The disallowance was made by the CPC in an intimation under Section 143(1). As the cause of action did not arise in the present proceedings, this ground was rejected. Stay applications were dismissed as infructuous.

The Tribunal held that the final assessment order dated 19.12.2025 was passed in defiance of the binding directions of the DRP, constituting a gross violation of Section 144C(13) of the Act. The AO was duty-bound to complete the assessment in conformity with the DRP's directions. The fact that the TPO passed an order giving effect to the DRP's directions on 29.12.2025, which reduced the TP adjustment, clearly indicated that the AO's final assessment order did not incorporate these directions. This omission vitiates the final assessment order, rendering it void in the eyes of law. The Tribunal relied on the decisions of the Hon'ble Delhi High Court in *ESPN Star Sports Mauritius S.N.C. ET Compagnie v. UoI* and the Hon'ble Madras High Court in *CIT v. Sanmina SCI India (P.) Ltd.*. Consequently, the final assessment order was quashed. Since the legal issue was decided in favor of the assessee, other grounds were considered academic and not adjudicated. The appeal filed by the assessee was allowed, and the Stay Petition was dismissed as infructuous.

The Tribunal held that no addition can be made solely based on a third-party statement without corroborative evidence or an opportunity for cross-examination. The addition was therefore unsustainable.

For AY 2018-19, the Tribunal held that the TPO was not justified in determining the ALP of management and testing & validation services at Nil. The TPO rejected the assessee's benchmarking analysis without demonstrating the applicability of Section 92C(3) of the Act and determined the ALP at Nil using the 'Other Method' without any comparable uncontrolled transaction, which is not sustainable. The assessee had adequately demonstrated the nature of services and their benefits. The Tribunal found that the assessee's aggregated approach under TNMM, reporting a margin of 20.57% (higher than comparables), was acceptable, and the TPO's rejection was unsubstantiated. The disallowance was deleted. For AY 2020-21, regarding notional interest on outstanding receivables, the Tribunal respectfully followed the Coordinate Bench's decision in the assessee's own case for AY 2021-22. It was held that where receivables are closely linked to the main transaction and working capital adjustments are granted under TNMM, no separate TP adjustment for notional interest is warranted, especially when the assessee is debt-free. The addition was directed to be deleted. Regarding the disallowance of Rs. 43,09,815 under Section 43B, the Tribunal noted that this issue was not adjudicated in the draft or final assessment orders, nor was it raised before the AO or DRP. The disallowance was made by the CPC in an intimation under Section 143(1). As the cause of action did not arise in the present proceedings, this ground was rejected. Stay applications were dismissed as infructuous.

The Tribunal noted that the Supreme Court had set aside the High Court judgments and allowed taxpayers to challenge retrospective amendments. Therefore, the CIT(A)'s order, based on those now-overturned decisions, could not survive.

The Tribunal held that the notice for reassessment was issued by the Jurisdictional AO, who lacked jurisdiction as per Section 151A. Due to a Supreme Court order setting aside High Court judgments on similar issues, the matter requires remand for fresh consideration.

The Tribunal condoned the delay in filing the appeals before the FAA, finding the reason provided to be reasonable. The matter was remitted back to the FAA for adjudication on merits.

The Tribunal condoned the delay in filing the appeals before the FAA, finding the reason provided to be reasonable. The matter was remitted back to the FAA for adjudication on merits.

The Tribunal condoned the delay in filing the appeals before the FAA, finding the reason provided to be reasonable. The matter was remitted back to the FAA for adjudication on merits.

The Tribunal held that 'B' class members are considered members under the Tamil Nadu Co-operative Societies Act, 1983. Therefore, extending credit facilities to them does not violate the principle of mutuality, and the society is eligible for deduction under Section 80P.

The Tribunal condoned the delay due to sufficient cause. While deprecating the assessee's attitude, the Tribunal restored the matter to the AO for fresh adjudication in the interest of justice.

The Tribunal held that the assessee could deposit demonetized currency within the permitted window and needed to explain the source. It also ruled that accepting deposits from 'B' class members, who are considered members under the TNCS Act, does not violate the principle of mutuality, allowing the deduction under Section 80P(2)(a)(i).

The Tribunal condoned the delay in one appeal and, in the interest of justice, remitted the matters back to the FAA to allow the assessee an opportunity to substantiate the reasons for delay with supporting evidence.

The Tribunal condoned the delay in one appeal and, in the interest of justice, remitted the matters back to the FAA to allow the assessee an opportunity to substantiate the reasons for delay with supporting evidence.

The Tribunal condoned the delay in one appeal and, for the others, found that the FAA had dismissed the appeals without proper adjudication. The matter was remitted back to the FAA to provide the assessee an opportunity to furnish supporting evidence for the delay.

The Tribunal condoned the delay in filing appeals before the CIT(A) and remitted the matters back to the AO. The AO is directed to consider the deduction u/s. 80P based on the outcome of the pending petition u/s. 119(2).

The Tribunal condoned the delay in filing appeals before the CIT(A) and remitted the matters back to the AO. The AO is directed to consider the deduction u/s. 80P based on the outcome of the pending petition u/s. 119(2).

The Tribunal condoned the delay in filing the appeal before the CIT(A) and admitted the appeal. The Tribunal remitted the appeal back to the AO to provide the assessee with another opportunity to substantiate their claim by producing necessary details.

The Tribunal set aside the impugned order and restored the matter to the Assessing Officer for a de novo assessment. This was done considering the assessment proceedings were conducted during the Covid-19 pandemic, leading to inadequate opportunity for the assessee.

The Tribunal held that no transfer pricing adjustment was warranted for the corporate guarantee obligation, as the transaction arose from invoking a guarantee for an insolvent AE, and imputing interest would be contrary to commercial reality and the real income theory. The addition was deleted. For loans to Siva Skylink Global Ltd., the Tribunal deleted the adjustment, stating that transfer pricing provisions cannot tax non-existent income when recovery is uncertain and the AE has ceased to exist. Regarding foreign exchange fluctuation loss, the issue was restored to the AO for verification, as the assessee claimed it was on revenue account but factual verification was needed. The addition to the closing stock valuation was deleted, as the revenue did not conclusively disprove the assessee's NRV basis and consistent valuation method. The difference between Form 26AS and P&L was restored to the AO for verification and relief if income was already offered. The depreciation claim was restored to the AO for proper verification. For capital losses, the disallowance was deleted, as Section 50CA was not applicable to AY 2015-16, and substitution of FMV was impermissible prior to its insertion. The TDS credit issue was restored to the AO for verification and allowance in accordance with Section 199 read with Rule 37BA to avoid double taxation. The revenue's appeal regarding corporate guarantee commission was dismissed, upholding the CIT(A)'s restriction to 0.5%. The revenue's grounds concerning OFCD adjustments were dismissed as infructuous in view of the deletion of the entire adjustment in the assessee's appeal.

The Tribunal held that no transfer pricing adjustment was warranted for the corporate guarantee obligation, as the transaction arose from invoking a guarantee for an insolvent AE, and imputing interest would be contrary to commercial reality and the real income theory. The addition was deleted. For loans to Siva Skylink Global Ltd., the Tribunal deleted the adjustment, stating that transfer pricing provisions cannot tax non-existent income when recovery is uncertain and the AE has ceased to exist. Regarding foreign exchange fluctuation loss, the issue was restored to the AO for verification, as the assessee claimed it was on revenue account but factual verification was needed. The addition to the closing stock valuation was deleted, as the revenue did not conclusively disprove the assessee's NRV basis and consistent valuation method. The difference between Form 26AS and P&L was restored to the AO for verification and relief if income was already offered. The depreciation claim was restored to the AO for proper verification. For capital losses, the disallowance was deleted, as Section 50CA was not applicable to AY 2015-16, and substitution of FMV was impermissible prior to its insertion. The TDS credit issue was restored to the AO for verification and allowance in accordance with Section 199 read with Rule 37BA to avoid double taxation. The revenue's appeal regarding corporate guarantee commission was dismissed, upholding the CIT(A)'s restriction to 0.5%. The revenue's grounds concerning OFCD adjustments were dismissed as infructuous in view of the deletion of the entire adjustment in the assessee's appeal.

The Tribunal granted the assessee one more opportunity due to their senior citizen status and reliance on a tax consultant. The appeal was remitted back to the AO for fresh consideration of the addition.

The Tribunal found that the CIT(A) passed a cryptic order without considering the assessee's detailed submissions. Therefore, the matter was remitted back to the Assessing Officer for a fresh assessment.

The Tribunal held that for the purpose of Section 80IA, the rate at which TNEB supplies power to consumers in the open market should be considered, not the rate at which TNEB procures power. This is based on the Supreme Court's decision in CIT vs. Jindal Steel and Power Ltd., which held that the State Electricity Board's rate when supplying power to industrial consumers constitutes the market value for computing deduction under Section 80IA. The Tribunal found that the assessee's rate was less than the TNEB supply rate, making the disallowance incorrect. The Tribunal directed the AO to delete the disallowance and allow the deduction as claimed. Regarding the contention that the Jindal Steel & Power Ltd. judgment is not applicable due to amendments to Section 80A(6) and Explanation to Section 80IA(8), the Tribunal noted that the Calcutta High Court in Rungta Mines Limited and Star Paper Mills Ltd. considered these amendments and still followed the Supreme Court's decision. The DRP had also decided this issue in favour of the assessee for AY 2020-21. Therefore, the Tribunal found the revenue's contention unsustainable. Concerning the belated remittance of employee contribution, the Tribunal upheld the disallowance made by the AO, citing the Supreme Court's decision in Checkmate Services Pvt. Ltd. The decision for AY 2018-19 was applied mutatis mutandis to AY 2022-23, directing the TPO to delete the TP adjustment. The appeal for AY 2018-19 was partly allowed, and the appeal for AY 2022-23 was allowed.

The Tribunal held that for the purpose of Section 80IA, the rate at which TNEB supplies power to consumers in the open market should be considered, not the rate at which TNEB procures power. This is based on the Supreme Court's decision in CIT vs. Jindal Steel and Power Ltd., which held that the State Electricity Board's rate when supplying power to industrial consumers constitutes the market value for computing deduction under Section 80IA. The Tribunal found that the assessee's rate was less than the TNEB supply rate, making the disallowance incorrect. The Tribunal directed the AO to delete the disallowance and allow the deduction as claimed. Regarding the contention that the Jindal Steel & Power Ltd. judgment is not applicable due to amendments to Section 80A(6) and Explanation to Section 80IA(8), the Tribunal noted that the Calcutta High Court in Rungta Mines Limited and Star Paper Mills Ltd. considered these amendments and still followed the Supreme Court's decision. The DRP had also decided this issue in favour of the assessee for AY 2020-21. Therefore, the Tribunal found the revenue's contention unsustainable. Concerning the belated remittance of employee contribution, the Tribunal upheld the disallowance made by the AO, citing the Supreme Court's decision in Checkmate Services Pvt. Ltd. The decision for AY 2018-19 was applied mutatis mutandis to AY 2022-23, directing the TPO to delete the TP adjustment. The appeal for AY 2018-19 was partly allowed, and the appeal for AY 2022-23 was allowed.

The Tribunal held that the penalty under section 270A was premature as the AO had accepted the disclosed income as bona fide and the additions were nominal or set aside for verification. The penalty issue was remitted back to the AO.

The Tribunal held that the sale of old rubber trees, which were part of a cultivated plantation and removed in the course of replantation, constitutes agricultural income. This income is exempt from tax.

The Tribunal held that the CIT(A) is duty-bound to decide appeals on merits, even if ex-parte, and cannot dismiss them solely for non-prosecution. The matter was therefore remanded to the CIT(A) for de novo disposal.

The Tribunal condoned the delay in filing the appeal before the CIT(A) by prioritizing substantial justice over technicalities, citing the assessee's bonafide belief and prior tax payment. The penalty levied under Section 271(1)(c) was deleted as the assessee had suo motu paid the excess tax before reassessment proceedings.

The Tribunal condoned the delay, acknowledging the assessee's lack of familiarity with e-proceedings as a sufficient cause. The matter was remitted to the Assessing Officer for fresh adjudication, granting the assessee a last opportunity to present her case.

The tribunal held that the CIT(A) is obligated to decide appeals on merits, even if dismissed for non-prosecution, and must provide a speaking order after affording a reasonable opportunity to the assessee.

The tribunal held that the CIT(A) is obligated to decide appeals on merits, even if dismissed for non-prosecution, and must provide a speaking order after affording a reasonable opportunity to the assessee.

The Tribunal held that the reasons provided for the delay in filing the appeal before the CIT(A) were not sufficient or reasonable. The COVID-19 illness occurred much earlier than the appeal filing date, and the rectification petition was also filed late.

The tribunal held that the CIT(A) erred in dismissing the appeal without condoning the 17-day delay, which was supported by an uncontroverted medical reason. The matter was remanded for denovo assessment.

The Tribunal held that the CIT(A) erred in dismissing the appeal based on the date of the assessment order rather than the date of its receipt by the assessee. The matter was restored to the CIT(A) for de novo disposal.

The Tribunal held that the reassessment proceedings were bad in law as the notice under Section 148 was issued beyond the prescribed limitation period. The allegation of income escaping assessment of more than Rs. 50 lakhs was found to be incorrect.

The Tribunal held that the CIT(A) should have condoned the delay in filing the appeal, as the reasons provided by the assessee were uncontroverted. Given the ex-parte nature of the assessment order, the matter was remanded for de novo assessment.

The Tribunal held that the CIT(A) should have condoned the delay as the assessee's averments in the affidavit remained uncontroverted. The matter was remitted back to the CIT(A) for adjudication on merits.

The Tribunal held that the CIT(A) should have condoned the delay as the assessee's averments in the affidavit remained uncontroverted. The matter was remitted back to the CIT(A) for adjudication on merits.

The Tribunal held that the CIT(A) should have condoned the delay as the assessee's averments in the affidavit remained uncontroverted. The matter was remitted back to the CIT(A) for adjudication on merits.

The Tribunal, while deprecating the assessee's non-compliance, restored the matter to the Assessing Officer for fresh adjudication in the interest of justice. The Assessing Officer was directed to provide a reasonable opportunity of hearing.

The Tribunal, while deprecating the assessee's lack of response, restored the matter to the FAA for fresh adjudication in the interest of justice and fair play. The FAA was directed to provide a reasonable opportunity of hearing to the assessee.

The Tribunal, while deprecating the assessee's non-compliance, restored the matter to the Assessing Officer (AO) as a last opportunity in the interest of justice. This was conditional on the assessee paying a cost of Rs. 10,000/-.

The Tribunal observed that the assessee claimed to have filed responses online which were not considered. In the interest of natural justice, the Tribunal set aside the impugned order and restored the matter to the AO for de novo adjudication.

The Tribunal condoned the delay in filing the appeal before the CIT(A) by prioritizing substantial justice over technicalities, citing the assessee's bonafide belief and prior tax payment. The penalty levied under Section 271(1)(c) was deleted as the assessee had suo motu paid the excess tax before reassessment proceedings.