ITAT Chennai Judgments — August 2026

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal found that the Ld.CIT(A) passed the order without issuing notice to the assessee, violating principles of natural justice. The impugned orders were set aside.

The Tribunal held that the AO's satisfaction for invoking Rule 8D was not valid as it was based on an incorrect assumption that borrowed funds were used for investments. The Tribunal found that the assessee had sufficient own funds for investments, thus the disallowance under Rule 8D was deleted.

The Tribunal held that unrealized MTM gains on forward contracts, as per ICDS VI and Section 43AA of the Income Tax Act, are recognized only at the time of settlement and not merely because they are accounted for in the books as per AS-11. Therefore, the addition made by the AO was incorrect.

The Tribunal held that depreciation disallowance was incorrect as the assessee had not received any subsidy. The issue of cash deposits was remitted back to the AO for fresh examination.

The Tribunal noted the assessee's inadvertent action and the fact that a response was filed for one application. Considering the interest of natural justice, the Tribunal decided to give the assessee another opportunity to present their case.

The Tribunal held that the enhanced threshold of Rs. 3 crores for cooperative societies should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal held that the enhanced threshold of Rs. 3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal condoned the delay in filing the appeals before the CIT(A) due to sufficient cause and set aside the CIT(A)'s order. The quantum assessments and penalties were restored to the Assessing Officer for de novo assessment, as the assessee was not given a proper opportunity to be heard.

The Tribunal condoned the delay in filing the appeal and set aside the ex parte order of the CIT(A). The appeal was restored to the CIT(A) for adjudication on merits after granting the assessee an opportunity to present submissions and documents.

The Tribunal held that the omission to file Form 10E electronically was inadvertent and procedural, especially since the employer had already obtained the form and granted relief. Since the Revenue accepted the assessee's entitlement after verification, the dismissal of the appeal on a technicality was unsustainable.

The Tribunal held that the enhanced threshold of Rs.3 crores for cooperative societies, introduced by Finance Act, 2023, should be applied retrospectively. It also noted that withdrawals related to government schemes and by business correspondents should not attract TDS under Section 194N.

The Tribunal set aside the CIT(E)'s order and restored the matter for fresh consideration. The CIT(E) was directed to provide the assessee with a reasonable opportunity of hearing and dispose of the application on merits.

The Tribunal held that a trust can be both religious and charitable, and a narrow interpretation excluding such trusts from Section 80G is not warranted. The CIT(E) erred in rejecting the application solely on the basis of the trust's description without examining its predominant charitable objects and activities.

The tribunal noted that the dispute had been settled under the Direct Tax Vivad se Vishwas Act, 2024, as confirmed by the settlement order. Therefore, the appeal was no longer maintainable.

The Tribunal held that the discrepancy in the date of the assessment order was a curable procedural defect and should not lead to the dismissal of the appeal. The appellate authority should have provided an opportunity to rectify the mistake.

The Tribunal held that both the assessment and appellate orders were passed ex parte without affording the assessee an effective opportunity of being heard. The impugned appellate order was set aside due to violation of principles of natural justice.

The Tribunal noted that the Supreme Court had set aside the High Court judgments relied upon by the CIT(A) and allowed taxpayers to challenge retrospective amendments. Consequently, the Tribunal set aside the CIT(A)'s order and restored the appeals to the CIT(A) to await the Supreme Court's decision on the validity of the notice.

The Tribunal condoned the delay in filing the appeal before the CIT(A) upon payment of costs. It set aside the CIT(A)'s order and restored the appeals to the file of the AO for de novo assessment, directing the assessee to provide substantiation for cash deposits.

The Tribunal held that the assessee is entitled to the benefit of the enhanced exemption limit of Rs. 25 lakhs under Section 10(10AA)(ii) for leave encashment. Since the amount received was within this limit, it is eligible for exemption.

The Tribunal condoned the delay in filing the appeal before the CIT(A) upon payment of costs. It set aside the CIT(A)'s order and restored the appeals to the file of the AO for de novo assessment, directing the assessee to provide substantiation for cash deposits.

The tribunal set aside the ex parte order of the Ld.CIT(A) and restored the appeal to the file of the Ld.CIT(A). The assessee was directed to file submissions and documents, and the Ld.CIT(A) was to adjudicate the grounds of appeal after hearing the assessee.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to the assessee's circumstances. The Tribunal also noted that the Assessing Officer passed an ex-parte order without proper opportunity.

The Tribunal held that the initiation of penalty proceedings was invalid as the notices under Section 274 were issued after the assessment orders were finalized. The lack of recorded satisfaction in the assessment orders and the delayed issuance of notices rendered the penalty orders legally unsustainable.

The Tribunal held that the initiation of penalty proceedings was invalid as the notices under Section 274 were issued after the assessment orders were finalized. The lack of recorded satisfaction in the assessment orders and the delayed issuance of notices rendered the penalty orders legally unsustainable.

The Tribunal held that the initiation of penalty proceedings was invalid as the notices under Section 274 were issued after the assessment orders were finalized. The lack of recorded satisfaction in the assessment orders and the delayed issuance of notices rendered the penalty orders legally unsustainable.

The Tribunal condoned the delay in filing the appeal. However, it held that the appeal was not maintainable as the tax effect was below the monetary limit prescribed by CBDT Circular No.05/2024, and no exceptions applied.

The Tribunal condoned the delay in filing the appeals before the CIT(A) due to sufficient cause and set aside the CIT(A)'s order. The quantum assessments and penalties were restored to the Assessing Officer for de novo assessment, as the assessee was not given a proper opportunity to be heard.

The Tribunal held that the disallowance was made in undue haste and without proper verification of documents already submitted by the assessee. The Tribunal found that the documents were legible and the assessee had complied with all notices, thus upholding the deletion of the disallowance.

The Tribunal found that the AO had made the addition without proper application of mind, considering details for the wrong assessment year and not giving the assessee a proper opportunity to explain the deposit. The assessee's health condition was also noted as a factor.

The Tribunal held that disallowance under Rule 8D(2)(ii) was not warranted as the assessee's own funds exceeded its investments, following established legal precedents. The disallowance under Rule 8D(2)(iii) was confirmed as per a Special Bench decision.

The Tribunal condoned the delay in filing the appeals due to the legal heir's lack of familiarity with tax matters and communication gaps. The Tribunal remitted the appeals back to the Assessing Officer to provide the assessee with an opportunity to present necessary details.

The Tribunal held that the CIT(E) should have provided a more effective opportunity to the assessee before rejecting the applications. The rejection was based solely on non-compliance, without examining the merits.

The Tribunal, considering the assessee's personal circumstances and lack of proper representation, decided to grant another opportunity for the assessee to present her case. The appeals were remitted back to the CIT(A) for fresh consideration.

The Tribunal held that the assessee had provided sufficient explanation supported by books of account, including an opening cash balance of Rs. 18,28,789/-. The Revenue failed to bring any material to contradict the genuineness of the cash balance.

The Tribunal held that the assessee had discharged its onus by providing documentation for purchases and payments. The mere failure of suppliers to respond to notices does not automatically make the purchases bogus, especially when the assessee has provided evidence.

The Tribunal, considering the assessee's personal circumstances and lack of proper representation, decided to grant another opportunity for the assessee to present her case. The appeals were remitted back to the CIT(A) for fresh consideration.

The Tribunal held that the enhanced exemption limit of Rs. 25,00,000/- under Section 10(10AA)(ii) is applicable retrospectively to the assessee's case. Since the leave encashment received was within this enhanced limit, the entire amount is eligible for exemption.

The Tribunal held that the AO's re-computation of agricultural income was based on unsubstantiated assumptions regarding yield. The Tribunal found that the assessee's declared yield was reasonably substantiated by a report from the National Agriculture Development Programme.

The Tribunal held that the delay in filing Form-67 is a technical or venial breach and not a mandatory requirement. Denying FTC solely on this ground would amount to unjust enrichment.

The Tribunal condoned the delay in filing the appeal before the CIT(A) considering the bonafide reasons and the assessee's lack of expertise. The case was remitted back to the AO to decide the issue on merits after calling for necessary details.