ITAT Chennai Judgments — June 2026

The Tribunal upheld the CIT(A)'s order, finding that the cash deposits and property purchases were related to the assessee's directorship in a real estate company and were duly accounted for in the company's books. The standard deduction was also allowed based on submitted documentation.

The ITAT found that the CIT(A) had dismissed the appeal summarily without properly considering the assessee's submissions and evidence. Therefore, the ITAT set aside the CIT(A)'s order and remitted the issues back for fresh adjudication.

The Tribunal found merit in the assessee's submissions, particularly regarding the cash withdrawals and the lack of proper verification by the lower authorities. It noted that the assessee also failed to provide comprehensive evidence.

The Tribunal condoned the delay in filing appeals and set aside the CIT(A)'s orders. The matters were remitted back to the Assessing Officer for fresh assessment, providing the assessee with another opportunity.

The Tribunal condoned the delay in filing appeals and set aside the CIT(A)'s orders. The matters were remitted back to the Assessing Officer for fresh assessment, providing the assessee with another opportunity.

The Tribunal condoned the delay in filing appeals and set aside the CIT(A)'s orders. The matters were remitted back to the Assessing Officer for fresh assessment, providing the assessee with another opportunity.

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

The Tribunal found that the CIT(A) order was passed without providing the assessee an adequate opportunity of being heard, violating principles of natural justice. Therefore, the order was set aside for fresh adjudication.

The Tribunal held that the AO's allegation of procuring bogus invoices was only with reference to M/s. LKR Enterprises. Therefore, it was fair and just to adopt a profit rate of 12.5% on the specific amount involving M/s. LKR Enterprises, not on the entire purchases.

The Tribunal held that the notice issued under Section 148 on 01.04.2022 was barred by limitation as the six-year period would have expired on 31.03.2022. Consequently, the reassessment proceedings were quashed.

The Tribunal held that the lower authorities erred in insisting on the filing of Form No. 9A or Form No. 10, as these were not mandatory for the assessment year in question. The assessee had validly exercised the option under Explanation 2(ii)(b) to Section 11(1) by providing the claim in writing before the due date.

The Tribunal allowed the assessee's claim for depreciation on goodwill arising from amalgamation. It held that the goodwill in question was not self-generated but arose from the amalgamation scheme, making the AO's reliance on Explanation 7 to Section 43(1) and Explanation 2(b) to Section 43(6) irrelevant. The Tribunal respectfully followed its own decision in FL Smidth India Private Limited (supra) and the binding ratio of the Hon'ble Supreme Court, concluding that depreciation on goodwill arising from amalgamation is allowable. The Tribunal also allowed the assessee's ground regarding the Transfer Pricing adjustment on notional interest on overdue receivables. It held that since the assessee is a debt-free company, does not incur significant interest cost, and did not charge interest on receivables from the AE, the TP adjustment for notional interest is unwarranted, following its decision in Newgen Digital Works Pvt Ltd. The grounds related to limitation under Section 153 and consequential grounds for penalty under Section 270A and interest under Sections 234B and 234C were dismissed as not pressed or not adjudicated.

The Tribunal allowed the assessee's claim for depreciation on goodwill arising from amalgamation. It held that the goodwill in question was not self-generated but arose from the amalgamation scheme, making the AO's reliance on Explanation 7 to Section 43(1) and Explanation 2(b) to Section 43(6) irrelevant. The Tribunal respectfully followed its own decision in FL Smidth India Private Limited (supra) and the binding ratio of the Hon'ble Supreme Court, concluding that depreciation on goodwill arising from amalgamation is allowable. The Tribunal also allowed the assessee's ground regarding the Transfer Pricing adjustment on notional interest on overdue receivables. It held that since the assessee is a debt-free company, does not incur significant interest cost, and did not charge interest on receivables from the AE, the TP adjustment for notional interest is unwarranted, following its decision in Newgen Digital Works Pvt Ltd. The grounds related to limitation under Section 153 and consequential grounds for penalty under Section 270A and interest under Sections 234B and 234C were dismissed as not pressed or not adjudicated.

The Tribunal held that the CIT(TP) was not justified in setting aside the TPO's order under Section 263. The Tribunal noted that the TPO had applied his mind while re-computing the PLI and made a conscious decision to allow the treatment of forex loss as non-operating. The Tribunal found that the CIT(TP) had not brought any material on record to establish that the forex loss had a direct bearing on the pricing or PLI of the assessee, which would demonstrate an error prejudicial to the revenue. Furthermore, the Tribunal observed that while the CIT(TP) relied on the fact that a major portion of the assessee's purchases were from imports, no factual finding was recorded to establish an error in the TPO's acceptance of the forex loss treatment. The Tribunal also noted that the revenue had allowed the treatment of forex loss as non-operating in other assessment years for the assessee without dispute. Citing Supreme Court decisions in Malabar Industrial Co. Ltd. and CIT v. Max India Ltd., the Tribunal stated that if the Assessing Officer has adopted a permissible course of action or taken one of two possible views, it cannot be treated as erroneous unless unsustainable in law. The Tribunal concluded that the CIT(TP)'s order was without jurisdiction and liable to be quashed. The TPO's order was set aside for a fresh order to be passed, considering the loss on account of foreign exchange fluctuation as operating expense, which would be suggested to the Assessment Unit.

The Tribunal held that the Assessing Officer exceeded the scope of remand by introducing a new ground (Section 80AC) for disallowance, which was not part of the original dispute. The AO had already found that other conditions for deduction were satisfied.

The Tribunal found that the CIT(A) did not provide proper opportunities to the assessee and violated principles of natural justice. Therefore, the appeals were remitted back to the AO for fresh consideration after allowing the assessee to present necessary details.

The Tribunal held that the Assessing Officer erred in recharacterizing the AIF's income as business income without proper inquiry or applying settled judicial tests. The processing fee was intrinsically linked to investments and not business income.

The Tribunal found that the lower authorities did not adequately examine the assessee's claim that the bank accounts belonged to a partnership firm, M/s IYYA Agencies, and that the assessee's PAN was erroneously updated. The matter requires fresh factual examination.

The Tribunal condoned the delay in filing the appeal and set aside the CIT(A)'s order. It granted the assessee one final opportunity to substantiate their claims with documentary evidence before the appellate authority.

The Tribunal held that web hosting services provided by the assessee do not confer any right to use equipment or intellectual property on the recipient. Therefore, the receipts are not taxable as royalty under the Income Tax Act or the India-USA DTAA.

The Tribunal held that web hosting services provided by the assessee do not confer any right to use equipment or intellectual property to the recipient. Therefore, the receipts are not taxable as royalty under the Income Tax Act or the India-USA DTAA.

The Tribunal held that web hosting services provided by the assessee do not confer any right to use equipment or intellectual property on the recipient. Therefore, the receipts are not taxable as royalty under the Income Tax Act or the India-USA DTAA.

The Tribunal found that the lower authorities had not conducted sufficient factual verification regarding the PAN-Aadhaar linkage status of deductees, subsequent regularisation, or the applicability of relevant circulars and judicial precedents. Therefore, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal held that the re-characterization of the loss was arbitrary and inconsistent, as the long-term capital loss from the same activity was accepted. It also found the CIT(A)'s reliance on a Google search to be a breach of natural justice.

The Tribunal set aside the orders of the lower authorities and restored the matter to the Assessing Officer for de novo assessment. The assessee was granted one final opportunity to explain the source of cash deposits and substantiate claims with evidence.

The Tribunal noted that the CIT(A) dismissed the appeal without adjudicating on merits and that the addition required verification of primary facts. Therefore, the matter was restored to the Assessing Officer for de novo adjudication.

The Tribunal condoned the delay in filing the appeal and restored the matter to the CIT(A) for fresh adjudication. The assessee was granted one final opportunity to substantiate the source of cash deposits with supporting documents.

The Tribunal noted that the CIT(A) did not consider a coordinate bench's decision in the assessee's own case for a prior assessment year. The Tribunal restored the matter to the CIT(A) for fresh adjudication, directing consideration of the previous order and evidence.

The Tribunal set aside the CIT(A)'s order and restored the matter to the Assessing Officer for de novo assessment, granting the assessee one final opportunity to substantiate its claims due to practical difficulties faced during the Covid-19 pandemic.

The Tribunal held that procedural delays should not ordinarily prevent adjudication on merits, especially when substantial additions are made. The delay in filing the appeal before the CIT(A) was condoned to allow the assessee an effective opportunity to contest the assessment.

The Tribunal held that the Assessing Officer erred in recharacterizing the AIF's income as business income without proper inquiry or applying settled judicial tests. The processing fee was intrinsically linked to investments and not business income.

The Tribunal condoned the delay in filing the appeal before it. It then remitted the matter back to the CIT(A) to consider the Section 80P deduction claim, directing the CIT(A) to decide based on the outcome of the assessee's petition for condoning the delay in filing the original return.

The Tribunal condoned the significant delay in filing the appeal due to the assessee's illness and lack of knowledge. It then remitted the matter back to the AO to provide the assessee with an opportunity to present necessary details and decide the issue afresh.

The Tribunal, considering the assessee's plea for a lack of proper communication and professional support, decided to grant one more opportunity in the interest of natural justice.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to the assessee's medical complications. The appeal was remitted back to the CIT(A) for a fresh decision after calling for necessary details.

The ITAT held that the CIT(A) was incorrect in dismissing the appeal as infructuous. The matter was remitted back to the CIT(A) for adjudication on merits after calling for necessary details.

The Tribunal held that the notice issued under Section 148 of the Income Tax Act for Assessment Year 2015-16 on April 1, 2022, was barred by limitation. Consequently, the reassessment proceedings and order were quashed.

The Tribunal found that the assessee did not receive the notices from the CIT(A) due to an incorrect email ID being used. To ensure natural justice, the Tribunal decided to give the assessee another opportunity to present their case.

The Tribunal found that the lower authorities had not conducted sufficient factual verification regarding the PAN-Aadhaar linkage status of deductees, subsequent regularisation, or the applicability of relevant circulars and judicial precedents. Therefore, the matter was restored to the Assessing Officer for fresh adjudication.

The Tribunal found that the CIT(A) did not provide proper opportunities to the assessee and violated principles of natural justice. Therefore, the appeals were remitted back to the AO for fresh consideration after allowing the assessee to present necessary details.

The Tribunal found that the CIT(A) did not provide proper opportunities to the assessee and violated principles of natural justice. Therefore, the appeals were remitted back to the AO for fresh consideration after allowing the assessee to present necessary details.

The Tribunal condoned the delay in filing the appeal before the CIT(A) in the interest of natural justice, citing the partner's medical issues. The case was remanded to the CIT(A) for fresh consideration of the delay petition and, if condoned, for adjudication on merits.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to reasonable cause and allowed the appeal for statistical purposes. The case was remitted back to the AO for fresh consideration.

The Tribunal held that the notice issued under Section 148 on 04.04.2022 for AY 2015-16 was barred by limitation, following Supreme Court decisions. Consequently, the reassessment proceedings and order were quashed.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to medical complications faced by the assessee. The appeal was remitted back to the CIT(A) for a fresh decision after calling for necessary details.

The Tribunal condoned the delay in filing the appeal before the CIT(A) and remitted the matter back to the Assessing Officer. The AO was directed to call for necessary details and decide the issue afresh in accordance with the law.

The Tribunal held that while unaccounted transactions were established, the gross profit rate applied by the AO was too high. It directed the AO to re-estimate the profit at 2% on unaccounted cash payments for gold purchases, considering it as wholesale bullion dealing.

The Tribunal condoned the delay in filing the appeal before the CIT(A) and set aside the CIT(A)'s order. The matter was restored to the CIT(A) for adjudication on merits after providing an opportunity to the assessee.

The Tribunal condoned the delay in filing the appeal before the CIT(A) and set aside the CIT(A)'s order. The matter was restored to the CIT(A) to adjudicate the appeal on merits after providing an opportunity of hearing to the assessee.

The Tribunal held that since the quantum addition, which formed the basis for the penalty, was deleted in the quantum proceedings, the penalty cannot survive independently. Following Supreme Court and High Court precedents, the penalty is liable to be cancelled.