ITAT Chennai Judgments — June 2026

The Tribunal held that the CIT(A) erred in dismissing the appeal for non-appearance without adjudicating on merits. The Tribunal set aside the orders of the lower authorities and remitted the matter back to the CIT(A) for a decision on merits.

The Tribunal held that the assessee was not afforded an effective adjudication on merits and that substantial justice should prevail over technicalities. Therefore, the matter was restored to the CIT(A) for fresh adjudication.

The Tribunal granted the assessee one more opportunity to produce necessary details regarding the creditworthiness and genuineness of the parties from whom the funds were received. The appeal was remitted back to the CIT(A) for fresh adjudication.

The tribunal held that the requirement of filing Form 10IE is directory, not mandatory. Since the form was available before the return was processed, the benefit of the new tax regime should have been granted.

The Tribunal found that the assessee had a reasonable cause for non-compliance due to medical hardship for three instances. Therefore, penalty for these three instances was deleted, but penalty for one instance was sustained.

The Tribunal held that the reassessment notice was issued beyond the period of limitation prescribed under the unamended provisions of Section 149 of the Income Tax Act. Consequently, the assumption of jurisdiction by the AO was without authority of law.

The Tribunal condoned the delay in filing the appeal and set aside the CIT(A)'s order, restoring the matter to the AO for fresh assessment. The assessee was directed to participate diligently and provide necessary documents.

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

The Tribunal condoned the delay in filing the appeal before the CIT(A) after noting that the appeal was filed within 30 days of the order's communication. The Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for de novo assessment.

The Tribunal noted that the delay in filing the return was subsequently condoned by the CCIT under Section 119(2)(b). Therefore, the basis for denying the Section 80P deduction no longer existed.

The Tribunal considered the assessee's request for withdrawal and the absence of objection from the Revenue. Permission was granted to the assessee to withdraw the appeals.

The Tribunal considered the assessee's request for withdrawal and the absence of objection from the Revenue. Permission was granted to the assessee to withdraw the appeals.

The Tribunal condoned the delay in filing the appeal and set aside the CIT(A)'s order. The matter was remitted back to the CIT(A) for fresh adjudication on merits, providing the assessee with another opportunity.

The Tribunal allowed the assessee's appeal. The core issue was whether the assessee had discharged its onus of proving the identity of the contractors, the genuineness of the transactions, and the actual rendering of services. The Tribunal noted that while the payee entities were non-functional as per ROC master data, this fact alone should not be the sole basis for disallowing the expenses. The assessee had provided substantial documentary evidence, including bills, bank remittances, GST details, and ledger accounts, which demonstrated that entries were made in the books, payments were routed through banking channels, and bills were issued. The Tribunal found that the vendors' default in ROC compliances did not necessarily impact the assessee's affairs. It was observed that the AO had the power to verify the information submitted by the assessee. The Tribunal distinguished the relied-upon judgments (Roshan Di Hatti and Nemi Chand Kothari) as pertaining to loan creditors, whereas this case involved expense creditors supported by extensive documentary evidence. Therefore, the Tribunal held that the assessee had sufficiently discharged its burden under Section 37(1) and set aside the orders of the authorities below, directing deletion of the additions.

The Tribunal found that the AO had erroneously checked AY 2016-17 instead of AY 2017-18, from which the loss was actually carried forward. The Tribunal directed the AO to allow the set off of the brought forward loss from AY 2017-18.

The Tribunal found the estimation of 35% of deposits as unexplained investment to be excessive and unreasonable. It directed the AO to estimate the income at 8% of the total deposits to balance equities and end litigation.

The Tribunal held that the requirement to file Form 10IE is directory, not mandatory. Since the form was filed before the processing of the return, the benefit of the new tax regime should be allowed.

The Tribunal held that the assessee satisfied the conditions for exemption under Section 54F, as the transfer of land was a long-term capital asset and the consideration was invested in constructing one residential flat. The Tribunal relied on previous judgments allowing such claims in JDA scenarios.

The Tribunal held that the reassessment proceedings are invalid and void ab initio. The Tribunal noted that the assessment year involved is 2015-16 and the notice under Section 148 was issued on 07.04.2022, which is after the expiry of the limitation period on 31.03.2022 as prescribed under the erstwhile provisions of Section 149 of the Act. The Tribunal relied on the authoritative decisions of the Hon'ble Supreme Court in The Income Tax Officer & Anr. vs. Sri Sai Kumar Mateti & Ors. (Civil Appeal No. ___ of 2026 arising out of SLP (Civil) No. 8682 of 2024, order dated 04.05.2026) and Union of India & Ors. vs. Rajeev Bansal (2024 SCC OnLine SC 2693). The Supreme Court had conceded that notices for AY 2015-16 would be barred by limitation and observed that such notices are liable to be struck down as time-barred. Consequently, the Tribunal held that the notice dated 07.04.2022 is invalid in law and void ab initio, and all proceedings initiated pursuant to this notice, including the reassessment order, are vitiated and quashed. Adjudication on the merits of the additions was rendered academic.

The Tribunal held that the assessee failed to demonstrate a sufficient cause for the extraordinary delay of 1,992 days. Failure to verify emails for an extended period, especially over five years, is not considered a sufficient cause.

The Tribunal found that the CIT(A) dismissed the appeal in limine due to the delay and lack of a condonation petition. To meet the ends of justice, the Tribunal set aside the CIT(A)'s order and remitted the matter back to the CIT(A) for deciding the condonation application and disposing of the appeal.

The Tribunal considered the assessee's request for withdrawal and the absence of objection from the Revenue. Permission was granted to the assessee to withdraw the appeals.

The Tribunal held that the 'J-Pack' data, relied upon by the AO, contained significant infirmities and inconsistencies, such as impossible purity figures and miniscule transaction quantities. The Tribunal found that the assessee had denied unaccounted transactions and provided supporting documents like invoices and bank statements for its recorded purchases. Therefore, the addition based solely on the 'J-Pack' ledger was not sustainable.

The Tribunal held that the entries in the third-party software (J-Pack) cannot be used as conclusive proof against the assessee without corroborative material. The lack of opportunity for the assessee to cross-examine the key witness and the AO's failure to conduct further inquiry vitiated the addition.

The Tribunal held that the assessee had discharged his onus by providing evidence that the funds were transferred from the company for business purposes and that the company had owned up these transactions. The AO failed to rebut this evidence.

The Tribunal found that transactions outside the books of accounts were akin to wholesale dealing in gold bullion, which has a lower profit earning capacity. The Tribunal directed the AO to re-estimate the profit at 2% instead of the previously computed 5.84%.

The Tribunal found that the AO erred in taxing transactions from a period before the assessee firm's incorporation. The matter was restored to the AO for a fresh assessment, directing the assessee to provide records to substantiate its claims regarding the proprietary concern's transactions.

The Tribunal held that while cash payments are common in the C&F industry, self-vouchers alone are insufficient proof. However, complete disallowance is also not justified as the Revenue did not prove the expenses were fictitious. Therefore, a reasonable disallowance was made.

The Tribunal upheld the CIT(A)'s decision, following the Supreme Court ruling in Jasjit Singh. It confirmed that the assessment under Section 153C could only be initiated for the year of receipt of documents and the preceding six years.

The Tribunal held that the CIT(A)'s decision was correct and confirmed it, stating that the Revenue's arguments did not override the relied-upon precedents. The Tribunal dismissed the Revenue's appeal.

The Tribunal directed the AO to re-estimate the profit on unaccounted transactions at 2% instead of the previously computed rate. The legal issue regarding the jurisdiction under Section 153C was left open due to a stay order by the High Court.

The Tribunal held that the notice issued under Section 148 on April 1, 2022, for AY 2015-16 was barred by limitation. Consequently, all subsequent actions were deemed non-est in the eyes of the law and the notice was quashed.

The Tribunal held that the notice under Section 148 was invalid because the approval was obtained from the Principal Commissioner (PCIT) instead of the Principal Chief Commissioner (PCCIT), as required for reopening beyond three years. Consequently, the assessment proceedings were quashed.

The Tribunal held that the notice issued under Section 148 of the Income Tax Act on 09.04.2022 for AY 2015-16 was barred by limitation. Consequently, all subsequent actions were deemed non-est in the eyes of the law.

The Tribunal held that the 'J-Pack' data, relied upon by the AO, contained significant infirmities and inconsistencies, such as impossible purity figures and miniscule transaction quantities. The Tribunal found that the assessee had denied unaccounted transactions and provided supporting documents like invoices and bank statements for its recorded purchases. Therefore, the addition based solely on the 'J-Pack' ledger was not sustainable.

The Tribunal held that the entries in the third-party software (J-Pack) cannot be used as conclusive proof against the assessee without corroborative material. The lack of opportunity for the assessee to cross-examine the key witness and the AO's failure to conduct further inquiry vitiated the addition.

The Tribunal held that the reassessment proceedings were invalid due to the improper approval for the notice under Section 148. Consequently, the penalty levied under Section 271E, which was based on the invalid reassessment order, was also quashed.

The Tribunal held that while the assessee's explanation for the entire cash balance was not fully substantiated, the AO's addition of the entire deposit was not justified. The Tribunal directed that only 50% of the addition be sustained.

The Tribunal held that the contents of the J-Pack software, unilaterally maintained by MJPL, cannot be used adversely against the assessee without corroborative evidence. The Tribunal also noted the lack of opportunity for the assessee to cross-examine the key witness from MJPL.

The Tribunal held that the entries in the third-party software (J-Pack) cannot be used as conclusive proof against the assessee without corroborative material. The lack of opportunity for the assessee to cross-examine the key witness and the AO's failure to conduct further inquiry vitiated the addition.

The Tribunal held that the entries in the third-party software (J-Pack) cannot be used as conclusive proof against the assessee without corroborative material. The lack of opportunity for the assessee to cross-examine the key witness and the AO's failure to conduct further inquiry vitiated the addition.

The Tribunal noted that for previous assessment years, the AO had estimated the profit from vegetable trading at 8%, which was later restricted by the Tribunal. For the current year, since the assessee did not participate in assessment proceedings, the matter was restored to the AO for de-novo assessment.

The Tribunal directed the AO to re-estimate the profit on unaccounted transactions at 2% instead of the previously computed rate. The legal issue regarding the jurisdiction under Section 153C was left open due to a stay order by the High Court.

The Tribunal held that for Ground No. 1 (Downward adjustment on account of Global IT services), the additional evidence submitted by the assessee, including third-party invoices, went to the root of the issue and were crucial for proper adjudication. Since this evidence was not presented before the lower authorities, the Tribunal admitted it and remitted the issue back to the AO/TPO for fresh consideration. The AO/TPO was directed to examine the evidence, considering the nature of services, and allow the claim in accordance with law. Ground No. 1 was allowed for statistical purposes. For Ground No. 6 (Deduction u/s. 80JJAA), the Tribunal directed the AO to verify and give full effect to the DRP's directions to allow the deduction as per law. For Ground No. 7 (TDS credit), the AO was directed to grant credit after verification. For Ground No. 8 (fee u/s. 234F) and Ground No. 10 (interest u/s. 244A), the issues were remitted back to the AO to verify the assessee's claims and allow them in accordance with law. Grounds No. 9 (interest u/s. 234B) and 11 (penalty u/s. 270A) were considered consequential and did not require separate adjudication. The appeal was partly allowed for statistical purposes.

The Tribunal held that the assessee had discharged his onus by providing evidence that the funds were transferred from the company for business purposes and that the company had owned up these transactions. The AO failed to rebut this evidence.

The Tribunal directed the AO to re-estimate the profit on unaccounted transactions at 2% instead of the previously computed rate. The legal issue regarding the jurisdiction under Section 153C was left open due to a stay order by the High Court.

The Tribunal directed the AO to re-estimate the profit on unaccounted transactions at 2% instead of the previously computed rate. The legal issue regarding the jurisdiction under Section 153C was left open due to a stay order by the High Court.

The Tribunal held that the 'J-Pack' data, relied upon by the AO, contained significant infirmities and inconsistencies, such as impossible purity figures and miniscule transaction quantities. The Tribunal found that the assessee had denied unaccounted transactions and provided supporting documents like invoices and bank statements for its recorded purchases. Therefore, the addition based solely on the 'J-Pack' ledger was not sustainable.

The Tribunal held that the 'J-Pack' data, relied upon by the AO, contained significant infirmities and inconsistencies, such as impossible purity figures and miniscule transaction quantities. The Tribunal found that the assessee had denied unaccounted transactions and provided supporting documents like invoices and bank statements for its recorded purchases. Therefore, the addition based solely on the 'J-Pack' ledger was not sustainable.

The Tribunal held that the 'J-Pack' data, relied upon by the AO, contained significant infirmities and inconsistencies, such as impossible purity figures and miniscule transaction quantities. The Tribunal found that the assessee had denied unaccounted transactions and provided supporting documents like invoices and bank statements for its recorded purchases. Therefore, the addition based solely on the 'J-Pack' ledger was not sustainable.