Archive · 21 Sep 2026
Chennai ITAT Revives ₹3.79 Crore TDS Dispute After Delay
A taxpayer had reported large payments on which tax had not been deducted.
The payments totaled about ₹3.79 crore across two financial years.
The tax officer sent notices asking for information, but the taxpayer did not answer them.
The officer then made decisions without hearing the taxpayer’s explanation.
The taxpayer appealed, but the appeals were filed 60 days late.
The first appeals authority rejected them because they were late.
The tribunal accepted the taxpayer’s reason for the delay and gave another chance.
The tribunal did not cancel the tax issue and sent it back for a fresh decision after hearing the taxpayer.
Payments totaling about ₹3.79 crore were reported without TDS for assessment years 2021-22 and 2022-23.
The assessing officer issued ex-parte orders after the taxpayer did not respond to statutory notices.
The orders imposed TDS demands totaling ₹22.02 lakh, plus interest of ₹7.22 lakh.
The taxpayer’s appeals were filed 60 days late and dismissed by the Commissioner of Income Tax (Appeals).
The Chennai ITAT condoned the delay and ordered a fresh examination without deciding the underlying TDS liability.
- Who
- Jayagopal Rathish, an individual engaged in transport and logistics, and the Income Tax Department.
- What
- The Chennai ITAT condoned a 60-day appeal delay and restored a TDS dispute for fresh examination.
- When
- The tribunal passed its order on 8 September 2026 for assessment years 2021-22 and 2022-23.
- Where
- Before the Chennai bench of the Income Tax Appellate Tribunal.
- Why
- The tribunal found sufficient cause for the delay and determined that the substantive TDS issue had not been examined after hearing the taxpayer on merits.
- Payments reported without TDS
- ₹98.09 lakh for assessment year 2021-22 and ₹2.81 crore for assessment year 2022-23
- Total payments
- Approximately ₹3.79 crore
- TDS demand
- ₹5.06 lakh for assessment year 2021-22 and ₹16.96 lakh for assessment year 2022-23
- Interest demand
- ₹2.13 lakh for assessment year 2021-22 and ₹5.09 lakh for assessment year 2022-23
- Appeal delay
- 60 days
- Original orders
- Ex-parte orders under Sections 201(1) and 201(1A), passed on 19 September 2024
- Tribunal outcome
- Delay condoned and matters restored to the assessing officer for fresh adjudication