ITAT Chennai Judgments — September 2026

The Tribunal accepted the assessee's request and remanded the matter back to the CIT(E) for fresh consideration. The assessee was given liberty to file supporting evidence.

The Tribunal held that the assessee failed to provide sufficient cause for the inordinate delay and that a day-to-day explanation was required. The affidavit seeking condonation of delay was dismissed.

The Tribunal held that the assessee had discharged the initial burden under Section 68 by providing donor confirmations, gift deeds, and income tax returns. The Revenue failed to provide independent material to disprove the genuineness of the gifts or establish that the amounts belonged to the assessee.

The Tribunal held that the assessee mistakenly omitted to disclose income from other sources in the relevant columns of the return, but had discharged the tax liability. Therefore, the addition made by the AO and confirmed by the CIT(A) was not justified.

The Tribunal held that the penalty notices were defective as the Assessing Officer failed to strike down the relevant charge (concealment or inaccurate particulars). Following the Madras High Court's decision in Babuji Jacob v. ITO, the penalty notices were quashed.

The tribunal set aside the order of the Ld. CIT(A) and remanded the matter for fresh consideration. The assessee was directed to represent its case and file evidence before the Ld. CIT(A).

The Tribunal held that the reassessment notice was issued beyond the four-year period without any failure on the part of the assessee to disclose material facts. Therefore, the reassessment order was quashed as bad in law.

The Tribunal noted the consistent non-compliance by the assessee at all levels of assessment and appeal. Consequently, the Tribunal confirmed the order of the CIT(A).

The Tribunal dismissed the appeal filed by the assessee. The Tribunal noted that despite multiple hearing notices, the assessee or their representative did not appear on most occasions, except for two when the bench was not working. On the final hearing date, no one appeared on behalf of the assessee. The Tribunal, having gone through the orders of the authorities below and the directions of the DRP, found them to be tenable. Since the assessee did not appear to differentiate the DRP's order, the same was confirmed. Consequently, the grounds raised by the assessee were dismissed, and the orders of the authorities below were confirmed. No issue was expressly left undecided.

The Tribunal held that the penalty notices were defective as the Assessing Officer failed to strike down the relevant charge (concealment or inaccurate particulars). Following the Madras High Court's decision in Babuji Jacob v. ITO, the penalty notices were quashed.

The Tribunal held that while some doubt remained regarding the genuineness of expenses due to ambiguous diary entries and lack of corroboration, a complete disallowance was not justified. A 5% disallowance was sustained.

The Tribunal held that while some doubt remained regarding the genuineness of expenses due to ambiguous diary entries and lack of corroboration, a complete disallowance was not justified. A 5% disallowance was sustained.

The Tribunal condoned the delay in filing the appeal before the CIT(A) due to sufficient cause and remitted the issues back to the AO for fresh adjudication on merits. The assessee was directed to provide necessary details and cooperate with the proceedings.

The Tribunal held that the surviving addition for unaccounted stock should be treated as business income, not unexplained investment. However, additions for unexplained cash and unexplained creditors were rightly assessed under Section 115BBE.

The Tribunal held that the surviving addition for unaccounted stock should be treated as business income, not unexplained investment. However, additions for unexplained cash and unexplained creditors were rightly assessed under Section 115BBE.

The Tribunal held that the Assessing Officer was not justified in denying the entire deduction. However, the cost of the land purchased in the wife's name prior to the sale of the original property is not eligible for deduction under Section 54.

The Tribunal held that the assessee failed to provide any evidence to support its claim that the land was agricultural. The AO had obtained details from the Sub-Registrar indicating the land was classified as 'dry' and not fit for cultivation. Therefore, the gains on sale were liable for capital gains tax. Regarding the guideline value, the Tribunal found no reason to interfere with the CIT(A)'s finding upholding the adoption of Rs. 180 per sq. ft., as the competent stamp valuation authority had determined this value, and the consideration disclosed was lower. The Tribunal rejected the contention that the AO was mandatorily required to refer the property to the DVO, noting that the assessee had not raised the requisite objection before the AO disputing the stamp valuation and seeking such a reference. The Tribunal upheld the CIT(A)'s direction to the AO to verify the correct extent of the property (1.72 acres vs. 1.92 acres) and restrict the computation under Section 50C to the determined correct extent, considering this as adequate relief. The Tribunal also dismissed the grounds related to violation of natural justice and exceeding the scope of limited scrutiny due to lack of supporting material.

The Tribunal condoned the delay in filing the appeal and, in the interest of justice, restored the issue of unexplained cash deposits to the Assessing Officer (AO). The assessee was directed to provide necessary evidence to explain the source of the deposits.

The Tribunal held that the reopening of the assessment was bad in law as the Assessing Officer failed to satisfy the conditions precedent under the first proviso to Section 147. Consequently, the reassessment order was quashed.

The Tribunal restored the issue of Rs. 55,00,000/- (recoveries from debtors) to the AO for fresh examination. The addition of Rs. 50,00,000/- (redeposit of withdrawn cash) was deleted, accepting the assessee's explanation based on bank records.

The Tribunal held that the surviving addition for unaccounted stock should be treated as business income, not unexplained investment. However, additions for unexplained cash and unexplained creditors were rightly assessed under Section 115BBE.

The Tribunal held that the surviving addition for unaccounted stock should be treated as business income, not unexplained investment. However, additions for unexplained cash and unexplained creditors were rightly assessed under Section 115BBE.

The Tribunal admitted additional evidence, including an allotment letter and proof of part payment made prior to registration. It held that these documents are crucial for determining the applicability of Section 56(2)(x) and restored the issue to the AO for fresh examination.

The Tribunal held that the assessee had provided sufficient primary evidence for unsecured loans and partners' capital, including confirmations, PAN, bank statements, and ledger accounts. The Revenue failed to produce independent material to disprove the assessee's explanation or establish that the funds represented the assessee's undisclosed income.

The Tribunal held that the Assessing Officer (AO) failed to establish that the impugned cash deposits comprised demonetized currency. The bank statements merely showed aggregate cash deposits without denomination-wise details, and no independent material was presented to prove the exact quantum of Specified Bank Notes (SBNs) within the deposits. The Tribunal noted that a regulatory infraction, if any, in accepting demonetized notes cannot convert an otherwise explained business receipt into unexplained money under Section 69A. The Tribunal found that the assessee had provided substantial documentary evidence, including cash books, subscriber-wise details, bank statements, and auditor's certificates, maintained in the ordinary course of business. The Revenue did not provide cogent material to prove the books were fabricated or that the deposits represented unaccounted money. Therefore, the essential conditions for invoking Section 69A were not satisfied. The addition of Rs. 41,52,672/- was directed to be deleted.

The Tribunal held that commission receipts, even if in cash, cannot be treated as unexplained cash credit under Section 68 if their business nature is accepted. Similarly, cash introduced into a proprietary concern's account from disclosed business cash cannot be treated as unexplained.

The Tribunal condoned the delay in filing the appeal. While deprecating the assessee's non-compliance, the Tribunal restored the matter to the AO to provide one more opportunity for proper representation, allowing the assessee to raise all contentions.

The Tribunal noted that the appeal was filed late, with no condonation petition, and the assessee was absent and unrepresented. The appeal was also found to be defective for not being signed and for not curing the defects.

The Tribunal noted that after the FAA's remand, the AO verified Form-3 and Form-4 and accepted the assessee's claim, deleting the addition. Therefore, the issue before the Tribunal no longer survived.

The Tribunal noted that the quantum addition forming the basis of the penalty is pending adjudication before the FAA. Therefore, the penalty order was also restored to the FAA to be adjudicated after the decision on the quantum appeal.

The Tribunal condoned the delay in filing the appeal before it. It held that the FAA should have considered the detailed reasons provided by the assessee for the delay in filing the appeal before the FAA. The matter was restored to the FAA for fresh consideration.

The Tribunal permitted the assessee to withdraw the appeals as the registrations sought were subsequently granted. Therefore, the appeals were dismissed as withdrawn.

The Tribunal, considering the lack of knowledge of the assessee's management and the accountant's oversight, decided to grant one more opportunity. The appeals were remitted back to the CIT(E) for fresh consideration.

The Tribunal found that the CIT(E) had rejected the application in ignorance of the fact that the assessee had filed the requisite information. Therefore, the matter was remanded to the CIT(E) for de novo disposal.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal, considering the lack of knowledge of the assessee's management and the accountant's oversight, decided to grant one more opportunity. The appeals were remitted back to the CIT(E) for fresh consideration.

The Tribunal held that the penalty order was passed beyond the statutory limitation period prescribed under Section 275(1)(c) of the Act. Therefore, the penalty order is liable to be quashed.

The Tribunal condoned the delay in filing the appeal. It held that the CIT(A) erred in remanding the matter without deciding the legal grounds concerning the validity of the assessment order passed in the name of a deceased person and the nature of the property sold.

The Tribunal found that the CIT(E) had rejected the application in ignorance of the fact that the assessee had filed the requisite information. Therefore, the matter was remanded to the CIT(E) for de novo disposal.

The Tribunal set aside the FAA's order as the basis for it (High Court decisions) was overruled by the Supreme Court due to a retrospective amendment. The matter was restored to the FAA to await the High Court's decision on the retrospective amendment.

The Tribunal held that the objects of the trust were purely charitable and not religious. Therefore, the classification as 'religious cum charitable' was incorrect, and the denial of 80G approval based on this classification was also untenable.

The Tribunal held that the trust's objects were purely charitable and not religious. Therefore, the classification as 'religious cum charitable' was incorrect, and the approval under Section 80G, which was denied based on this classification, should be granted.

The Tribunal permitted the assessee to withdraw the appeals as the registrations sought were subsequently granted. Therefore, the appeals were dismissed as withdrawn.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal, while deprecating the assessee's non-compliance, decided to grant one more opportunity in the interest of justice and fair play. This opportunity is conditional upon the assessee paying a cost of Rs. 1,00,000/- for each assessment year.

The Tribunal found that the CIT(E) likely granted registration from AY 2027-28 inadvertently, as there were no adverse findings against the assessee. The matter was remanded to the CIT(E) to amend the registration certificate.