ITAT Chennai Judgments — September 2026

The Tribunal condoned the delay of 584 days in filing the appeal, finding sufficient cause due to the assessee's prolonged illness. The appeal was admitted for adjudication on merits.

The Tribunal noted that the assessee was abroad for employment for a decade and was unaware of the assessment order. To meet the ends of justice, the Tribunal set aside the CIT(A)'s order and remitted the matter back to the AO for de novo assessment.

The Tribunal held that teaching Vedas is not exclusively a religious activity but rather a charitable one, aligning with established judicial precedents. Therefore, the rejection of the 80G approval by the CIT(E) was incorrect.

The Tribunal held that the disallowance of deduction was due to a difference in interpretation of statutory conditions and not due to concealment or furnishing of inaccurate particulars. Therefore, the penalty under Section 271(1)(c) was unsustainable.

The Tribunal held that merely depositing Specified Bank Notes (SBN) during demonetization, without any adverse findings on the source or genuineness, cannot by itself justify treating accounted business receipts as unexplained investment. The revenue did not establish that unaccounted cash was introduced.

The Tribunal held that the assessee had a bona fide belief that TDS was sufficient and provided a plausible explanation for the delay in filing the return. The Revenue failed to establish that the failure was without reasonable cause.

The Tribunal held that a mere violation of demonetisation notifications regarding SBN acceptance does not automatically render business receipts as unexplained income under Section 69A. The crucial factor is whether the nature and source of the money are explained.

The Tribunal found that the First Appellate Authority (FAA) had not properly examined the documentary evidence submitted by the assessee regarding his wife's income disclosure. Therefore, the issue was restored to the Assessing Officer (AO) for fresh examination.

The Tribunal, in the interest of natural justice, decided to give the assessee one more opportunity to present necessary details. The appeal was remitted back to the CIT(A) for a fresh decision.

The Tribunal held that the PCIT was not justified in exercising revisionary jurisdiction to direct the initiation of penalty proceedings under Section 271(1)(c) when the Assessing Officer had consciously chosen not to invoke it and had instead invoked other penalty provisions. The Tribunal also noted that for one assessment year, the addition itself was deleted by the CIT(A), making the penalty direction infructuous.

The Tribunal held that the PCIT was not justified in exercising revisionary jurisdiction to direct the initiation of penalty proceedings under Section 271(1)(c) when the Assessing Officer had consciously chosen not to invoke it and had instead invoked other penalty provisions. The Tribunal also noted that for one assessment year, the addition itself was deleted by the CIT(A), making the penalty direction infructuous.

The Tribunal held that the failure to specify the set-off was an inadvertent clerical error, not a fresh claim. Therefore, the assessee's claim for set-off of business loss should be allowed.

The Tribunal condoned the delay in filing the appeal. It further held that the issue of cash deposits, which was initially treated as unexplained by the AO and sustained by the CIT(A), should also be remitted back to the AO for fresh consideration.

The Tribunal condoned the substantial delay in filing the appeals before the CIT(A), citing the assessee's advanced age, health issues, personal tragedy, and lack of digital literacy as sufficient cause. The matter was remanded to the CIT(A) for adjudication on merits.

The Tribunal found merit in the assessee's submission that winnings deposited in the bank account were the source for subsequent cash deposits into the gaming platform. It noted that lower authorities did not properly examine the deposits and withdrawals from the gaming platform reconciling with bank statements.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal held that the AO's action of making a fresh disallowance under Section 14A through a Section 154 rectification order was beyond the scope of the provision. It reasoned that this constituted a fresh adjudication rather than correcting a mistake apparent from the record.

The Tribunal held that the application was rejected without a detailed examination of its merits. The matter was restored to the CIT(E) for fresh consideration, providing the assessee an opportunity to furnish documents.

The Tribunal condoned the delay in filing the appeals before the CIT(A), citing sufficient cause. The orders of the CIT(A) were set aside, and the matter was restored to the Assessing Officer for de novo assessment.

The Tribunal condoned the delay in filing the appeal, finding sufficient cause. The appeal was admitted for adjudication against the order confirming the reassessment.

The Tribunal held that both the assessment order and the appellate order were passed ex parte, violating the principles of natural justice. The assessee was not given a proper opportunity to be heard.

The Tribunal held that the lower appellate authority passed an ex-parte order without affording the assessee a proper opportunity to be heard, violating principles of natural justice.

The Tribunal condoned the delay in filing the appeal before the CIT(A) and restored the matter to the CIT(A) for adjudication on merits. The CIT(A) was directed to provide an opportunity of hearing and consider the assessee's explanations and evidence.

The Tribunal found that the issues raised by the assessee required proper factual verification and reasoned adjudication. The matter was restored to the CIT(A) for de novo adjudication after examining evidence related to business income and cash seizure.

The tribunal held that penalty proceedings are consequential to the assessment. Since the original assessment leading to the penalty had no surviving additions or tax adjustments, the penalty could not be sustained.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal condoned the delay in filing the appeals before the CIT(A), citing sufficient cause. The orders of the CIT(A) were set aside, and the matter was restored to the Assessing Officer for de novo assessment.

The Tribunal condoned the substantial delay in filing the appeals before the CIT(A), citing the assessee's advanced age, health issues, personal tragedy, and lack of digital literacy as sufficient cause. The matter was remanded to the CIT(A) for adjudication on merits.

The Tribunal held that the PCIT was not justified in exercising revisionary jurisdiction to direct the initiation of penalty proceedings under Section 271(1)(c) when the Assessing Officer had consciously chosen not to invoke it and had instead invoked other penalty provisions. The Tribunal also noted that for one assessment year, the addition itself was deleted by the CIT(A), making the penalty direction infructuous.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal admitted additional evidence of a bank acknowledgement for the amended partnership deed. The matter was restored to the AO for limited verification of this third-party evidence to determine if the amended deed was acted upon contemporaneously.

The Tribunal held that since the assessment was completed under Section 147 and not Section 144, the earlier non-compliance was condoned. Therefore, the penalty levied under Section 272A(1)(d) for not responding to notices was not sustainable.

The Tribunal held that the CIT(A) erred in making an ad-hoc addition of Rs. 10,00,000/- when the sources of cash, such as debtor collections, were accepted and the books of account were not rejected. The Tribunal directed the deletion of the disallowance.

The Tribunal, noting the failure of the assessee to respond and in the interest of natural justice, decided to grant one more opportunity. The appeal was remitted back to the CIT(E) to reconsider the application after calling for relevant details.

The Tribunal held that the AO had conducted a proper inquiry and accepted the assessee's suo-moto disallowance after due consideration. The mere absence of a detailed discussion in the assessment order does not amount to a lack of inquiry or an erroneous order. Therefore, the PCIT's assumption of jurisdiction under Section 263 was unsustainable.

The Tribunal found merit in the assessee's submissions regarding the disallowance of interest expenditure, stating it was not warranted as the interest paid was for car loans and not related to exempt income. The Tribunal also directed the AO to recompute the disallowance under Rule 8D(2)(iii) considering only investments yielding exempt income.

The Tribunal held that technical difficulties in electronic filing should not deny substantive benefits to an existing registered entity. The applications were directed to be treated as filed under the correct provisions, and the matters were restored for fresh adjudication.

The Tribunal held that Section 68 of the Income Tax Act can only be invoked for sums credited in the books of account of the assessee during the relevant previous year. Since the lease advances pertained to earlier years, the PCIT's invocation of Section 263 was based on a mistaken assumption of fact and was without jurisdiction.

The Tribunal held that technical difficulties in electronic filing should not deny substantive benefits to an existing registered entity. The applications were directed to be treated as filed under the correct provisions, and the matters were restored for fresh adjudication.

The Tribunal held that technical difficulties in electronic filing should not deny substantive benefits to an existing registered entity. The applications were directed to be treated as filed under the correct provisions, and the matters were restored for fresh adjudication.

The Tribunal held that the explanation for the delay in filing appeals before the CIT(A) was not substantiated. The company's active status on the MCA portal and substantial financial transactions indicated it was not dysfunctional. The Tribunal found no sufficient cause for condoning the delay.

The Tribunal held that since the notice under Section 148 was issued beyond three years, the approval should have been obtained from the Principal Chief Commissioner of Income Tax (PCCIT) as per Section 151(ii), not the Principal Commissioner of Income Tax (PCIT). Therefore, the notice was invalid.

The Tribunal held that the assessment orders passed by the Assessing Officer to give effect to the Tribunal's order were indeed time-barred as they were passed beyond the period prescribed under Section 153(3) of the Act. Consequently, these orders were deemed invalid.

The Tribunal dismissed the first appeal due to the unexplained and excessive delay, refusing to condone it. For the second appeal, the Tribunal set aside the CIT(A)'s order and remanded the matter back for fresh adjudication, allowing the assessee an opportunity to present its case.

The Tribunal noted that no one appeared for the hearing, and the delay was not explained. Consequently, the Tribunal held that it was not inclined to condone the delay and dismissed the appeal.

The Tribunal held that the addition was unsustainable as the Revenue failed to establish by independent and cogent evidence that the assessee actually incurred the alleged cash expenditure. The essential nexus between third-party entries and the actual incurrence of expenditure by the assessee remained unproved.

The Tribunal noted that the CIT(E) had not recorded any adverse findings and that the discrepancy in the assessment years for 12AB and 80G approvals appeared to be an inadvertent clerical error. The Tribunal directed the CIT(E) to verify and rectify the assessment year for the 12AB registration.