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ITAT Chennai

Faceless Reassessment Is Mandatory: Chennai ITAT Sets Aside 69A Addition Despite Cash Deposits

December 26, 2025 2724 Views 0 comment Print

The Tribunal held that reassessment initiated by a jurisdictional officer after the faceless scheme became mandatory was invalid. The key takeaway is that failure to follow the faceless mechanism nullifies the entire reopening, regardless of merits.

JAO-Issued Section 148 Notice Held Void Under Faceless Scheme

December 26, 2025 666 Views 0 comment Print

The Tribunal ruled that non-compliance with the faceless reassessment scheme strikes at jurisdiction itself. JAO-issued notices post-notification were held legally unsustainable.

Comparable Excluded Due to Functional Dissimilarity in Software Development Transfer Pricing

December 25, 2025 792 Views 0 comment Print

Tribunal held that a company engaged in diversified IT consultancy and transformation services cannot be compared with a routine software development service provider

Revised Form 10 Filed During Assessment Held Valid for Accumulation Claim of Trust

December 25, 2025 756 Views 0 comment Print

The Tribunal ruled that revising Form 10 during assessment does not invalidate a trust’s accumulation claim when the original form was filed on time. The key takeaway is that revised filings before assessment completion are permissible.

Section 271D Penalty Quashed as Time-Barred in Absence of Assessment: ITAT Chennai

December 25, 2025 1350 Views 0 comment Print

The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).

Buyback through High Court approved scheme needs verification of NAV valuation u/r 11UA: Matter remitted

December 23, 2025 492 Views 0 comment Print

ITAT Chennai held that the matter of buyback through High Court approved scheme of arrangment remitted back for verification of NAV valuation under rule 11UA and also to analyize applicability of section 115QA. Accordingly, appeal restored back.

Appeal Cannot Be Dismissed for Non-Appearance Without Merits Review: ITAT Chennai

December 22, 2025 327 Views 0 comment Print

The Tribunal ruled that appellate authorities must decide appeals on merits, even if the taxpayer does not appear, reinforcing the mandate of Section 250(6).

Limitation Runs from Date of Knowledge; Cash Deposit Appeal restored

December 22, 2025 543 Views 0 comment Print

The ITAT ruled that appeal limitation must be counted from the date the taxpayer gains knowledge of the order, setting aside dismissal wrongly made on delay grounds.

Consultant Lapse & Health Issues Sufficient Cause: Chennai ITAT Condoned 261-Day Delay

December 22, 2025 381 Views 0 comment Print

The ITAT held that professional negligence and continuous medical problems constitute sufficient cause, condoning a 261-day delay and reviving the appeal.

Final Assessment Set Aside Due to Limitation Breach After Invalid TP Order

December 21, 2025 393 Views 0 comment Print

The Tribunal held that a transfer pricing order passed beyond statutory limitation is non est in law. As a result, the assessee ceased to be an eligible assessee under section 144C, making the final assessment beyond limitation and void.

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