ITAT Chennai Judgments — July 2026

The CIT(A) confirmed the addition but directed that it not be taxed under Section 115BBE. The Tribunal found that the CIT(A) erred in not admitting additional evidence and remanding the matter to the CIT(A) for fresh adjudication.

The Tribunal held that the expenses claimed were incurred wholly and exclusively for the purpose of earning interest income and were therefore allowable as a deduction. The addition made by the Assessing Officer was directed to be deleted.

The Tribunal found that the CIT(A) dismissed the appeal without a proper examination of the merits and restored the matter for fresh adjudication. Both appeals were allowed for statistical purposes.

The Tribunal held that the expenses claimed were incurred wholly and exclusively for the purpose of earning interest income and were therefore allowable as a deduction. The addition made by the Assessing Officer was directed to be deleted.

The Tribunal held that the expenses claimed were incurred wholly and exclusively for the purpose of earning interest income and were therefore allowable as a deduction. The addition made by the Assessing Officer was directed to be deleted.

The Tribunal found that the CIT(A) dismissed the appeal without a proper examination of the merits and restored the matter for fresh adjudication. Both appeals were allowed for statistical purposes.

The Tribunal held that the CIT(A) annulled the assessment order for non-quoting of the DIN Number. The Parliament inserted section 292BA by the Finance Act, 2026, with retrospective effect from 01.10.2019, to clarify that no assessment shall be invalid on account of any mistake, defect, or omission in respect of non-quoting of the DIN Number. In view of this legislative amendment, the Tribunal was of the considered opinion that the order of the CIT(A) needed to be reversed. The matter was remitted back to the file of the CIT(A) for de novo disposal of the issues in appeal in accordance with law, after affording an opportunity of being heard to the respondent assessee. The Tribunal noted that the assessment order was quashed by the CIT(A) for non-quoting of DIN, and the insertion of section 292BA with retrospective effect from 01.10.2019 validates such orders. The Tribunal did not decide the merits of the addition made by the AO.

The Tribunal reversed the CIT(A)'s finding, stating that since the escaped income exceeded Rs. 50 lakhs, the reassessment proceedings were initiated within the six-year limitation period. The matter was restored to the CIT(A) for adjudication on merits.

The Tribunal held that additions on account of differential purchases were not sustainable given the opening stock and the recycling of sale proceeds. For differential sales, the addition of 8% profit was deemed arbitrary and restored to the Assessing Officer for fresh assessment.

The Tribunal held that additions on account of differential purchases were not sustainable, especially considering the opening stock and the recycling of sale proceeds. For differential sales, the estimation of profit was arbitrary and required reconsideration.

The Tribunal held that Section 69 applies only to investments not recorded in books. Since the investment was duly recorded in the firm's books and reflected through partners' capital accounts, Section 69 was not applicable. The addition was unsustainable on facts and in law.

The Tribunal held that additions on account of differential purchases were not sustainable given the opening stock and the recycling of sale proceeds. For differential sales, the addition of 8% profit was deemed arbitrary and restored to the Assessing Officer for fresh assessment.

The Tribunal held that additions on account of differential purchases were not sustainable given the opening stock and the recycling of sale proceeds. For differential sales, the addition of 8% profit was deemed arbitrary and restored to the Assessing Officer for fresh assessment.

The Tribunal held that additions on account of differential purchases were not sustainable given the opening stock and the recycling of sale proceeds. For differential sales, the addition of 8% profit was deemed arbitrary and restored to the Assessing Officer for fresh assessment.

The Tribunal found that no substantial proceedings were held due to communication issues. Therefore, the matter was restored to the AO for a de novo assessment, allowing the assessee a proper opportunity to be heard.

The Tribunal found the facts to be similar to a previous case and decided to remand the matter back to the CIT(E). The CIT(E) was directed to reconsider the application, taking into account the amendment to Section 80G(5) and grant approval from the date of application.

The Tribunal found that the AO's addition of entire cash deposits without proper explanation was not justified. Since the assessee also failed to comply before the CIT(A), the matter was remanded for fresh consideration.

The Tribunal held that the statutory forms filed along with the return (Form 9A and Form 10B) are integral parts of the return and should not be considered in isolation. The Assessing Officer and the First Appellate Authority erred in rejecting the rectification petition based on a narrow interpretation of Section 154.

The Tribunal observed that the assessee lacked proper documentation to explain the cash deposits. Therefore, the matter was restored back to the Assessing Officer to provide a proper cash flow statement.

The Tribunal found that while the CIT(A) allowed exemption based on a screenshot of Section 12A approval and a prior year's acceptance, there was no detailed verification of the approval's validity and period. However, considering the prior year's acceptance by the Revenue, the CIT(A)'s order was upheld.

The Tribunal noted that crucial evidence, including a confirmation letter and details of cash withdrawals, was not available before the lower authorities. Therefore, the matter was remanded to the AO for fresh consideration of these additional evidences.

The Tribunal found that the AO's addition of entire cash deposits without proper explanation was not justified. Since the assessee also failed to comply before the CIT(A), the matter was remanded for fresh consideration.

The Tribunal found the assessee's explanations unconvincing and contradictory. Therefore, the matter was restored to the AO for reconsideration with proper opportunity for the assessee to present evidence.

The Tribunal held that the CIT(A) acted judicially and fairly by admitting additional evidence under Rule 46A due to sufficient cause and that the proviso to Section 251(1)(a) should be read harmoniously with Rule 46A and Section 251(1)(c). The grounds raised by the Revenue were found to be baseless.

The Tribunal allowed Ground No. 10, agreeing with the assessee's contention that turnover is a valid quantitative filter for determining comparability, especially in software development services. The Tribunal noted that entities with turnovers exceeding 10 times the assessee's turnover are not ideal comparables. It referenced a coordinate bench decision in the assessee's own case for AY 2021-22, which held that companies with turnovers exceeding 10 times the assessee's turnover should be excluded. The Tribunal also cited that coordinate benches consistently hold an upper turnover filter of Rs. 200 crore or 10 times the assessee's turnover as essential, as turnover reflects economies of scale impacting Functions, Assets, and Risks (FAR). The Tribunal followed the principle of consistency, as there was no material difference in the functional profile or international transaction for the current year. Accordingly, the Tribunal directed the AO/TPO to apply an upper turnover filter of ten times the assessee's turnover, excluding companies exceeding this limit, and to recompute the arm's length price after providing the assessee an opportunity of being heard. The transfer pricing adjustment was to be recomputed accordingly.

The Tribunal found that the notices were sent to an incorrect email ID, leading to non-receipt by the assessee. The matter was restored to the CIT(E) for fresh consideration after giving the assessee a proper opportunity of being heard.

The Tribunal found that the AO did not properly examine the assessee's residential status, the utilization of cash withdrawals, or the applicability of Section 69C in the context of presumptive taxation. The DRP also failed to consider the documentary evidence.

The Tribunal condoned the delay in filing the appeals. Considering the assessee's undertaking to provide evidence and the nature of additions made under Section 69A, the matters were remanded to the CIT(A) for fresh consideration.

The Tribunal noted that the Assessing Officer had made various additions. In the interest of justice, the Tribunal decided to condone the delay and remand the matter to the CIT(A) for adjudication on merits.

The Tribunal condoned the delay in filing the appeal after finding the assessee's reasons to be bonafide. The core issue of Section 80P deduction was then to be examined.

The Tribunal condoned the delay and restored the matters to the AO for fresh adjudication, subject to the assessee paying a cost of Rs. 5,000/- in each appeal. The AO was directed to provide a reasonable opportunity of hearing.

The Tribunal found the facts to be similar to a previous case and decided to remand the matter back to the CIT(E). The CIT(E) was directed to reconsider the application, taking into account the amendment to Section 80G(5) and to grant approval from the date of application.

The Tribunal noted the lack of compliance before the CIT(A) and that the additions made by the AO under Section 56(2)(viib) required the assessee's assistance. Therefore, the matter was remanded to the CIT(A) for fresh consideration.

The Tribunal held that while some reasons might be genuine, they did not constitute a sufficient cause for the inordinate delay. The Tribunal emphasized that the law of limitation should not be frustrated by a liberal approach without justification.

The Tribunal found that the CIT(E) did not consider all the evidence submitted by the assessee. Therefore, the matter was remanded back to the CIT(E) for a fresh adjudication.

The Tribunal noted that the withdrawal of the penalty appeal was made by mistake and no immunity from penalty proceedings was granted. Therefore, the matter was remanded to the CIT(A) for adjudication on merits.

The Tribunal held that the CIT(A) should not have refused to condone the delay solely based on its length. The focus should be on whether there was a sufficient and reasonable cause for the delay.

The Tribunal held that since the notice under Section 148 was issued beyond three years, the approval ought to have been obtained from the PCCIT as per Section 151(ii). Approval from the PCIT was insufficient, rendering the notice invalid.

The Tribunal set aside the ex-parte order of the CIT(Exemption) and restored the matter for fresh adjudication. The assessee was granted an opportunity to present its case and furnish necessary documents.

The tribunal held that the assessee bank was justified in not deducting TDS due to the binding interim directions of the Madras High Court. The bank cannot be treated as an assessee in default for complying with court orders.

The Tribunal noted the mistake in withdrawing the penalty appeal and the lack of immunity for penalty proceedings. The matter was remanded to the CIT(A) for adjudication on merits.

The Tribunal found the facts to be similar to a previous case and decided to remand the matter back to the CIT(E). The CIT(E) was directed to reconsider the application, taking into account the amendment to Section 80G(5), and grant approval from the date of application.

The Tribunal, while deprecating the assessee's non-compliance, granted a final opportunity in the interest of justice. The matter was restored to the AO for fresh adjudication subject to a cost payment.

The Tribunal condoned the delay and restored the matters to the AO for fresh adjudication, subject to the assessee paying a cost of Rs. 5,000/- in each appeal. The AO was directed to provide a reasonable opportunity of hearing.

The Tribunal held that the CIT(A) failed to verify the assessee's plea that deposits were made from earlier withdrawals. Therefore, the matter requires a remand for fresh consideration.

The Tribunal held that the explanation of not receiving mail and being unaware of proceedings is not a sufficient cause for the inordinate delay. The Tribunal upheld the CIT(A)'s rejection of the delay condonation petition.

The tribunal condoned the delay due to the assessee's genuine health reasons. The matter was remanded to the Assessing Officer for fresh consideration, allowing the assessee to present evidence.

The Tribunal noted that the issue of jurisdiction for issuing Section 148 notices was subject to ongoing litigation and recent Supreme Court pronouncements. Consequently, the matter was remitted back to the CIT(A) for fresh consideration.

The Tribunal condoned the delay in filing the appeals. Considering the assessee's undertaking to provide evidence and the nature of additions made under Section 69A, the matters were remanded to the CIT(A) for fresh consideration.

The Tribunal condoned the delay in filing the appeal. It noted that crucial documentary evidence was not presented before the AO and CIT(A). Therefore, the matter was remanded to the AO for fresh consideration of the additional evidence.