ITAT Chennai ruled that for captive power consumption, the market value for Section 80-IA deduction should be the rate at which electricity is supplied to industrial consumers, not the SEB purchase rate. AO’s downward adjustment was deleted.
ITAT held that most jewellery seized during a search could be accounted for from declared drawings and past income, reducing addition to ₹72.45 lakh. Ruling emphasizes that unexplained investment must be proven in relevant assessment year.
ITAT held that post-29.03.2022, notices must be issued faceless; issuance by JAO violated law, invalidating the reopening and assessment.
The Tribunal held that Section 87A contains no exclusion for long-term capital gains and allowed the rebate since total income remained below Rs.5 lakhs. The order of the lower authorities was set aside.
The assessee’s plea that delayed PF/ESI deduction was a debatable issue was rejected because Checkmate had settled the law retrospectively. The key takeaway is that once the Supreme Court clarifies the law, CPC may apply it through 143(1)(a) adjustments based on audit disclosures.
ITAT Chennai holds that Section 87A rebate is available even when total income includes capital gains taxed at special rates, reversing CIT(A)’s denial.
The Tribunal held that a 143(1)(a) adjustment denying ₹5.05 crore TDS credit was invalid because no mandatory show-cause intimation was issued. It ruled that a 139(9) defect notice cannot substitute the statutory opportunity required under 143(1), resulting in deletion of the entire ₹5.73 crore demand.
ITAT Chennai held that an appeal filed under the Black Money Act with a 5-day delay cannot be condoned without a notarised affidavit supporting the delay. The appeal was dismissed in limine, emphasizing strict adherence to procedural requirements.
ITAT ruled that invoking the Black Money Act for AY 2022–23 on income earned in FY 2015–16 was without jurisdiction, rendering the entire assessment invalid.
ITAT Chennai ruled that an assessment order issued without a Document Identification Number violates CBDT Circular No. 19/2019 and is invalid. Tribunal held that non-compliance with circular’s mandate cannot be cured by later communication of DIN. Orders lacking DIN are deemed never to have been issued.
