Wavoo Real Estate Corporation Vs DCIT/ACIT (ITAT Chennai)
Income Tax Appellate Tribunal (ITAT), Chennai bench, has set aside the orders of the Commissioner of Income Tax (Appeals) / National Faceless Appeal Centre (CIT(A)/NFAC) and remanded the tax appeals of Wavoo Real Estate Corporation back to the Assessing Officer (AO) for fresh adjudication. The decision, pronounced on June 25, 2025, covers Assessment Years 2013-14, 2014-15, and 2016-17, and highlights the Tribunal’s emphasis on ensuring a fair opportunity for taxpayers and proper verification of facts by the tax authorities. The remand comes with a condition for the assessee to pay a specified amount to the State Legal Aid Authority.
Background of the Assessment and Appeals
The case originated from assessment orders passed by the AO under Section 147 read with Section 144 and Section 144B of the Income Tax Act, 1961. For Assessment Year 2013-14, the AO noted that Wavoo Real Estate Corporation had received significant rent (₹.1,61,77,496/-) under Section 194I and contract receipts (₹.2,60,000/-) but failed to offer these incomes for taxation. Although the assessee uploaded a return of income in response to a Section 148 notice, it was treated as invalid by the AO due to pending e-verification. Furthermore, the assessee reportedly did not respond to notices issued under Section 142(1) or a show-cause notice under Section 144.
