ITAT Chennai Judgments — July 2026

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 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 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.

The Tribunal held that in the absence of any representation from the assessee and any evidence to challenge the action of the CIT(A) in confirming the penalty imposed by the AO under section 270A of the Income-tax Act, 1961, it had no option but to confirm the order of the CIT(A). The Tribunal found the order of the CIT(A) to be justified in confirming the AO's view on imposing the penalty. Consequently, the grounds raised by the assessee were dismissed. The operative direction was to dismiss the appeal filed by the assessee. No issue was expressly left undecided.

The tribunal found no infirmity in the CIT(E)'s order as the assessee failed to furnish complete details and rebut the findings. In the absence of any representation or documentary evidence from the assessee, the appeal was dismissed.

The Tribunal held that the CIT(A) erred in rejecting the claim solely on the ground of a non-filed revised return, especially in light of the CBDT's circular advising officers not to take advantage of an assessee's ignorance. The Tribunal noted that the appellate authority's powers are co-terminus with the AO and directed the AO to allow the claim.

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 late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that the interest income earned by a co-operative society from deposits with co-operative banks is eligible for deduction under Section 80P(2)(d). The Supreme Court's decision in Totagars was distinguished as it pertained to Section 80P(2)(a)(i) and not Section 80P(2)(d).

The Tribunal held that the CIT(A) erred in rejecting the claim solely on the ground of a non-filed revised return, especially in light of the CBDT's circular advising officers not to take advantage of an assessee's ignorance. The Tribunal noted that the appellate authority's powers are co-terminus with the AO and directed the AO to allow the claim.

The Tribunal held that the First Appellate Authority erred in rejecting the assessee's claim solely on the ground of not filing a revised return. Citing CBDT Circular No. 14(XL-35) of 1955, the Tribunal emphasized that departmental officers should assist taxpayers and not take advantage of their ignorance.

The Tribunal held that the principles of natural justice require the assessee to be given an effective opportunity to present their case, especially since the rectification order resulted in a substantial enhancement of tax liability and the assessee claimed unawareness of the notices.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal found no infirmity in the order of the CIT(A) who confirmed the AO's action of adopting a GP ratio of 4.18% on turnover. Ample opportunities were given to the assessee, but no submissions were made.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that the First Appellate Authority erred in rejecting the assessee's claim solely on the ground of not filing a revised return. Citing CBDT Circular No. 14(XL-35) of 1955, the Tribunal emphasized that departmental officers should assist taxpayers and not take advantage of their ignorance.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal noted that crucial documentary evidence was not placed before the AO and CIT(A). Therefore, the matter was remanded to the AO for fresh consideration with liberty to the assessee to submit evidence.

The Tribunal held that no penalty under Section 271B is leviable if the audit report is on record before the completion of assessment proceedings. It also held that no penalty under Section 270A is justified when the Revenue accepts the return of income without any additions.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal upheld the order of the CIT(A) due to the assessee's absence and lack of evidence. The grounds raised by the assessee were dismissed for failing to provide any justification.

The Tribunal found that the assessee had produced additional documents before it, which were not available to the lower authorities. These documents were crucial for adjudicating the claim for exemption and computation of capital gains.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that no penalty under Section 271B is leviable if the audit report is on record before the completion of assessment proceedings. It also held that no penalty under Section 270A is justified when the Revenue accepts the return of income without any additions.

The Tribunal, in the interest of substantial justice, granted the assessee one more opportunity to present their case. The matter was restored to the Assessing Officer for fresh adjudication, subject to the assessee paying a cost of Rs. 25,000/-.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that late filing fees under Section 234E and consequential interest under Section 220(2) cannot be levied for belated filing of TDS returns for the period prior to June 1, 2015. This decision was based on the jurisdictional High Court's ruling.

The Tribunal held that the First Appellate Authority has co-terminus powers with the Assessing Officer and can entertain fresh claims. The Tribunal also emphasized the CBDT circular directing departmental officers not to take advantage of an assessee's ignorance, allowing the assessee's claim for exemptions.

The Tribunal held that the First Appellate Authority has co-terminus powers with the Assessing Officer and can entertain fresh claims. The Tribunal also emphasized the CBDT circular directing departmental officers not to take advantage of an assessee's ignorance, allowing the assessee's claim for exemptions.

The Tribunal held that the CIT(A) did not provide a proper opportunity of hearing to the appellant and that the sale of shares was not adequately considered. Therefore, the matter was remanded for denovo assessment.

The Tribunal condoned the delay in filing the appeal before the CIT(A) after considering the death of the assessee's relative who handled his tax affairs. The matter was restored to the AO for de-novo consideration with a cost of Rs. 15,000.

The Tribunal held that the AO was empowered under Section 154 to rectify mistakes apparent from the record, including the charging of mandatory interest. The Tribunal found that the AO had followed the due legal process and confirmed the orders of the lower authorities.

The Tribunal held that the amendment regarding the validity of returns filed under Section 148 was effective from 01.04.2022, which was after the assessment year in question. It also noted that the CIT(A) failed to appreciate that the sale deed indicated agricultural land, which is exempt, and that the income offered was after considering capital gains and deductions.

The Tribunal condoned the delay in filing the appeal before both the lower authorities, considering the substantial demand and the reasons provided by the assessee. The matter was restored to the CIT(A) for reconsideration after giving the assessee a proper opportunity to be heard.

The Tribunal held that the AO had taken a plausible view and the assessee's treatment of bad debts recovered and interest accrued was consistent. Therefore, the PCIT's order under Section 263 was erroneous and prejudicial to the assessee's interest.

The Tribunal dismissed the assessee's appeal, confirming the addition of ₹ 8,60,000. The assessee failed to substantiate the source and genuineness of the increased borrowings despite multiple opportunities.

The Tribunal held that the addition based on the IDS declaration was unsustainable as Form No. 2 was not served on the assessee, making the invocation of Section 197(b) of the Finance Act, 2016 invalid. The addition based on the survey statement was also deleted for lack of corroborative material.

The Tribunal partially deleted the penalty, giving the benefit of doubt to the assessee for one notice due to system glitches. However, the penalty for non-response to the other notice was sustained as no evidence was provided to show non-receipt.

The Tribunal held that the reopening of assessment was based solely on AIR information without independent verification or a bona fide 'reason to believe' that income had escaped assessment. Therefore, the reassessment proceedings were vitiated.

The Tribunal noted that the assessee had filed an application to condone the delay in filing the return. Therefore, the matter was restored to the Assessing Officer to await the decision on the condonation application.

The Tribunal condoned the delay in filing the appeal before the CIT(A) and set aside the CIT(A)'s order. The assessment order was restored to the AO for a fresh assessment after hearing the assessee.

The Tribunal noted that the Supreme Court had set aside the High Court judgments relied upon by the CIT(A) due to a retrospective amendment by the Finance Act, 2026, which validated notices issued by the JAO. Consequently, the CIT(A)'s order was set aside.