CHRYSALIS PLAY SCHOOL PVT. LTD.,CHENNAI V. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

ITA 3586/CHNY/2025

AI Insights

The case involves Chrysalis Play School Private Ltd., which appealed against the order of the Addl./JCIT(A), Faridabad, for the assessment year 2022-23. The appeal was initially filed with a delay of 273 days, which was condoned by the Tribunal. The primary issue in the appeal was the denial of TDS credit of 3,30,000/- related to one of the amalgamated entities, M/s. Amaryllis Properties Pvt. Ltd. The Tribunal found it appropriate to remand the matter back to the Assessing Officer for verification of the TDS credit and to allow the assessee to present supporting documentary evidence.

• Counselvise Citation: [2026] 140 COUNSELVISE.COM (IT) 834178 (ITAT-CHENNAI)
• Duration Of Justice: 2 month(s) 4 day(s)
• Appeal Type: Income Tax Appeal
• Pronouncement Date: 02-02-2026
• Appeal Filed By: Assessee
• Order Result: Partly Allowed
• Bench Allotted: D
• Assessment Year: 2022-2023
• Appeal Filed On: 28-11-2025
• Laws Referred To: Income Tax Act, 1961
• Result in Favour of: Partly Allowed
• Court: TRIBUNAL
• Department Lawyers: Y. SUDARSHAN
• Assessee Lawyers: GIRISH KUMAR
• Keywords: Condonation of delay; TDS

Judgement Text

"आयकर अपीलीय अिधकरण, ’डी’ Ɋायपीठ, चेɄई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI ŵी इंट ूरी रामाराव, लेखा सद˟ एवं ŵी एस.एस. िवʷनेũ रिव, Ɋाियक सद˟ क े समƗ । Before Shri Inturi Rama Rao, Accountant Member & Shri S.S. Viswanethra Ravi, Judicial Member आयकर अपील सं./I.T.A. No.3586/Chny/2025 िनधाŊरण वषŊ/Assessment Year: 2022-23 Chrysalis Play School Private Ltd., 12, South Mada Street, Srinagar Colony, Saidapet, Chennai 600 015. [PAN: AAICC2959D] Vs. The Deputy Commissioner of Income Tax, Corporate Circle 1(1), Chennai. (अपीलाथŎ/Appellant) (ŮȑथŎ/Respondent) अपीलाथŎ की ओर से / Appellant by : Shri Girish Kumar, Advocate ŮȑथŎ की ओर से/Respondent by : Shri Y. Sudarshan, JCIT सुनवाई की तारीख/ Date of hearing : 27.01.2026 घोषणा की तारीख /Date of Pronouncement : 02.02.2026 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This appeal filed by the assessee is directed against the order dated 31.12.2024 passed by the Addl./JCIT(A), Faridabad for the assessment year 2022-23. 2. We find that this appeal is filed with a delay of 273 days. The assessee filed an affidavit for condonation of delay stating the reasons. Upon hearing both the parties and on examination of the said affidavit, in Printed from counselvise.com I.T.A. No.3586/Chny/25 2 the interest of justice, we condone the delay and admit the appeal for adjudication. 3. At the outset, we note that the assessee filed return of income under section 139(1) of the Income Tax Act, 1961 [“Act” in short] on 06.10.2022 admitting a total income of ₹.37,31,961/- for AY 2022-23 and the same was processed under section 143(1) of the Act dated 24.02.2023. Thereafter, the companies Royalsoft Services Limited [PAN: AAACX0016E] and Amaryllis Properties Private Limited [PAN; AAJCA4663M] got amalgamated with the assessee vide NCLT order dated 06.04.2022. Thereafter, the assessee filed return of income under section 170A of the Act on 15.03.2023 declaring total income of ₹.37,31,960/-. Accordingly, the Assessing Officer passed giving effect order under section 170A r.w.s. 143(1) of the Act dated 30.12.2023 determining sum of ₹.3,78,558/- as payable towards tax liability. Since the assessee did not file any documentary evidence in support of its contention towards TDS credit, the ld. CIT(A) dismissed the appeal of the assessee and confirmed the order of the Assessing Officer. 4. The ld. AR Shri Girish Kumar, Advocate submits that the Assessing Officer denied TDS credit of ₹.3,30,000/- pertaining to one Printed from counselvise.com I.T.A. No.3586/Chny/25 3 of the amalgamated entities M/s. Amaryllis Properties Pvt. Ltd. The ld. AR prayed to remand the matter to the file of the Assessing Officer for verification of TDS credit by filing various details in the form of paper book containing 238 pages. Considering the submissions of the ld. AR and the ld. DR, we deem it proper to remand the matter to the file of the Assessing Officer to verify the TDS credit pertaining to the amalgamated entities M/s. Amaryllis Properties Pvt. Ltd. and pass order in accordance with law by affording an opportunity to the assessee. The assessee is at liberty to furnish documentary evidence in support of its claim before the Assessing Officer. Thus, the grounds raised by the assessee are allowed for statistical purposes. 5. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on 02nd February, 2026 at Chennai. Sd/- Sd/- (INTURI RAMA RAO) ACCOUNTANT MEMBER (S.S. VISWANETHRA RAVI) JUDICIAL MEMBER Chennai, Dated, 02.02.2026 Vm/- Printed from counselvise.com I.T.A. No.3586/Chny/25 4 आदेश की Ůितिलिप अŤेिषत/Copy to: 1. अपीलाथŎ/Appellant, 2.ŮȑथŎ/ Respondent, 3. आयकर आयुƅ/CIT, Chennai/Madurai/Coimbatore/Salem 4. िवभागीय Ůितिनिध/DR & 5. गाडŊ फाईल/GF. Printed from counselvise.com "