Chettinad Corporation Pvt. Ltd. v. CIT

200 ITR 320Supreme Court of India#3704 most cited

What is Chettinad Corporation Pvt. Ltd. v. CIT authority for?

A claim for deduction not related to escaped income is not maintainable during reassessment proceedings under Section 147.

32

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Chettinad Corporation Pvt. Ltd. v. CIT · Section 147 · reassessment proceedings · new claim · escaped income · deduction

Sections most often in play

Section 143(3)Section 147Section 148Section 14ASection 154Section 36(1)(viii)Section 37(1)

Issues it is cited on

section 36(1)(viii)mistake apparent from recordmistake apparent on recordeligible businessfair market valuesection 36(1)section 37(1)double taxationsection 14asection 154scrutiny assessmentreassessment proceedings

Judgments citing Chettinad Corporation Pvt. Ltd. v. CIT

GRUH FINANCE LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

Appeal is dismissed

ITA 1228/AHD/2019[2011-12]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2011-12

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

…new claim during the assessment proceedings carried out u/s.147 of the Act was not maintainable. He, in this respect, relied upon the following case-laws:  CIT Vs. Sun Engineering Works P.Limited (SC) 198 ITR 297  Chettinad Corporation P.Ltd. Vs. CIT (SC) 200 ITR 320  V. Jaganmohan Rao & Ors. Vs. CIT (SC) 75 ITR 373 3.1. The Ld.AO also observed that the aforesaid claim of deduction on account of ESOP cost expense was even not related to the escaped income. He, therefore, disallowed the aforesaid claim made by the assessee. The Ld.CIT(A) confirmed the disallowance of aforesaid deduction claimed by the assess…

GRUH FINANCE LTD.,,AHMEDABAD vs. THE DCIT, CIRCLE-2(1)(1),, AHMEDABAD

Appeal is dismissed

ITA 138/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2014-15

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

…new claim during the assessment proceedings carried out u/s.147 of the Act was not maintainable. He, in this respect, relied upon the following case-laws:  CIT Vs. Sun Engineering Works P.Limited (SC) 198 ITR 297  Chettinad Corporation P.Ltd. Vs. CIT (SC) 200 ITR 320  V. Jaganmohan Rao & Ors. Vs. CIT (SC) 75 ITR 373 3.1. The Ld.AO also observed that the aforesaid claim of deduction on account of ESOP cost expense was even not related to the escaped income. He, therefore, disallowed the aforesaid claim made by the assessee. The Ld.CIT(A) confirmed the disallowance of aforesaid deduction claimed by the assess…

GRUH FINANCE LTD.,,AHMEDABAD vs. THE DY. CIT, CIRCLE-2(1)(1),, AHMEDABAD

Appeal is dismissed

ITA 855/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

…new claim during the assessment proceedings carried out u/s.147 of the Act was not maintainable. He, in this respect, relied upon the following case-laws:  CIT Vs. Sun Engineering Works P.Limited (SC) 198 ITR 297  Chettinad Corporation P.Ltd. Vs. CIT (SC) 200 ITR 320  V. Jaganmohan Rao & Ors. Vs. CIT (SC) 75 ITR 373 3.1. The Ld.AO also observed that the aforesaid claim of deduction on account of ESOP cost expense was even not related to the escaped income. He, therefore, disallowed the aforesaid claim made by the assessee. The Ld.CIT(A) confirmed the disallowance of aforesaid deduction claimed by the assess…

THE ACIT, CIRCLE-2(1)(1),, AHMEDABAD vs. GRUH FINANCE LTD.,, AHMEDABAD

Appeal is dismissed

ITA 1126/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2025AY 2012-13

Bench: Shri Sanjay Garg & Smt. Annapurna Gupta

For Appellant: Ms. Arti Shah, ARFor Respondent: (sl.nos.1&4) Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 147

…new claim during the assessment proceedings carried out u/s.147 of the Act was not maintainable. He, in this respect, relied upon the following case-laws:  CIT Vs. Sun Engineering Works P.Limited (SC) 198 ITR 297  Chettinad Corporation P.Ltd. Vs. CIT (SC) 200 ITR 320  V. Jaganmohan Rao & Ors. Vs. CIT (SC) 75 ITR 373 3.1. The Ld.AO also observed that the aforesaid claim of deduction on account of ESOP cost expense was even not related to the escaped income. He, therefore, disallowed the aforesaid claim made by the assessee. The Ld.CIT(A) confirmed the disallowance of aforesaid deduction claimed by the assess…

DCIT, CENTRAL CIRCLE 2(2), CHENNAI vs. N RAMASAMY, CHENNAI

In the result, the appeal filed by the Revenue in ITA No

ITA 128/CHNY/2019[2016-17]Status: DisposedITAT Chennai29 Dec 2023AY 2016-17

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपील सं./I.T.A Nos.127 & 128/Chny/2019 िनधा"रण वष" /Assessment Years : 2015-2016 & 2016-2017 The Deputy Commissioner Of Vs. Shri. N. Ramasamy, Income Tax, No.14/19, Saraswathi Street, Central Circle 2(2), Mahaingapuram, Nungambakkam High Road, Chennai 600 034. Chennai 600 034. [Pan Adupr 8003P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Nilay Baran Som, Irs, Cit. ""यथ" क" ओर से /Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 18.12.2023. घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023 आदेश / O R D E R Per Mahavir Singh:

For Appellant: Shri. Nilay Baran Som, IRS, CITFor Respondent: Shri. S. Sridhar, Advocate
Section 143Section 143(3)

…of income filed in response to notice u/s.153A is treated as filed u/s.139(1) of the I.T. Act, 1961. 6.2. The Learned CIT(A) failed to appreciate that in the case of CIT v. Sun Engineering Works (P) Ltd. (198 ITR 297) and Chettinad Corporation P. Ltd. v. CIT (200 ITR 320), the Hon'ble Supreme Court has held that reopening is only for the benefit of revenue and that assessments made u/s.153A being in the nature of reassessment proceedings, the said Hon'ble Supreme Court's decisions apply to return of income filed u/s.153A too. 6.3. The Learned CIT(A) ought to have noted that in corporate cases, the accounts have t…

DCIT, CENTRAL CIRCLE 2(2), CHENNAI vs. N RAMASAMY, CHENNAI

In the result, the appeal filed by the Revenue in ITA No

ITA 127/CHNY/2019[2015-16]Status: DisposedITAT Chennai29 Dec 2023AY 2015-16

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपील सं./I.T.A Nos.127 & 128/Chny/2019 िनधा"रण वष" /Assessment Years : 2015-2016 & 2016-2017 The Deputy Commissioner Of Vs. Shri. N. Ramasamy, Income Tax, No.14/19, Saraswathi Street, Central Circle 2(2), Mahaingapuram, Nungambakkam High Road, Chennai 600 034. Chennai 600 034. [Pan Adupr 8003P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Nilay Baran Som, Irs, Cit. ""यथ" क" ओर से /Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 18.12.2023. घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023 आदेश / O R D E R Per Mahavir Singh:

For Appellant: Shri. Nilay Baran Som, IRS, CITFor Respondent: Shri. S. Sridhar, Advocate
Section 143Section 143(3)

…of income filed in response to notice u/s.153A is treated as filed u/s.139(1) of the I.T. Act, 1961. 6.2. The Learned CIT(A) failed to appreciate that in the case of CIT v. Sun Engineering Works (P) Ltd. (198 ITR 297) and Chettinad Corporation P. Ltd. v. CIT (200 ITR 320), the Hon'ble Supreme Court has held that reopening is only for the benefit of revenue and that assessments made u/s.153A being in the nature of reassessment proceedings, the said Hon'ble Supreme Court's decisions apply to return of income filed u/s.153A too. 6.3. The Learned CIT(A) ought to have noted that in corporate cases, the accounts have t…

GAURER & WEIL (INDIA) LTD,MUMBAI vs. ACIT 9(1), MUMBAI

ITA 384/MUM/2017[2008-09]Status: DisposedITAT Mumbai30 Oct 2019AY 2008-09

Bench: Shri S. Rifaur Rahman, Am & Shri Ram Lal Negi, Jm आयकरअपीलसं./ I.T.A. No. 384/Mum/2017 (निर्धारणवर्ा / Assessment Year: 2008-09)

For Appellant: Shri Nitesh Joshi / ShriFor Respondent: Shri V. Vinod kumar, DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 433Section 43B

…notice u/s. 148 was entirely based on the appellant's failure to show his income/loss correctly under a proper head. Relying upon the cases of Raymond Wollen Mills Ltd (236 ITR 34), Dr. Amin’s Pathology Laboratory (252 ITR 673); and Chettinad Corporation Ltd (200 ITR 320) it is held that the re- opening u/s. 147 r.w.s. 148 by the A.O. was justified. Accordingly these grounds of appeal are dismissed. 7. Aggrieved by the order of Ld. CIT(A), assessee preferred the appeal before us on the ground mentioned herein below:- 1. The learned Commissioner of Income-tax (Appeals) erred in upholding the re-opening of assess…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

ITA 226/HYD/2019[2012-13]Status: DisposedITAT Hyderabad30 Aug 2019AY 2012-13

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED , HYDERABAD

In the result, a) ITA Nos

ITA 225/HYD/2019[2012-13]Status: DisposedITAT Hyderabad30 Aug 2019AY 2012-13

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

ITA 224/HYD/2019[2011-12]Status: DisposedITAT Hyderabad30 Aug 2019AY 2011-12

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED, HYDERABAD

In the result, a) ITA Nos

ITA 223/HYD/2019[2010-11]Status: DisposedITAT Hyderabad30 Aug 2019AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1(3), HYDERABAD vs. ASR ENGINEERING AND PROJECTS LIMITED , HYDERABAD

In the result, a) ITA Nos

ITA 222/HYD/2019[2009-10]Status: DisposedITAT Hyderabad30 Aug 2019AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

ITA 1385/HYD/2017[2012-13]Status: DisposedITAT Hyderabad30 Aug 2019AY 2012-13

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

ITA 1384/HYD/2017[2011-12]Status: DisposedITAT Hyderabad30 Aug 2019AY 2011-12

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED, HYDERABAD

In the result, a) ITA Nos

ITA 1383/HYD/2017[2010-11]Status: DisposedITAT Hyderabad30 Aug 2019AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

DY. COMMSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3)., HYDERABAD vs. SAI SUDHIR INFRASTRUCTURES LIMITED., HYDERABAD

In the result, a) ITA Nos

ITA 1382/HYD/2017[2009-10]Status: DisposedITAT Hyderabad30 Aug 2019AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

ITA 1136/HYD/2017[2011-12]Status: DisposedITAT Hyderabad30 Aug 2019AY 2011-12

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

ITA 1135/HYD/2017[2010-11]Status: DisposedITAT Hyderabad30 Aug 2019AY 2010-11

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

ITA 1134/HYD/2017[2009-10]Status: DisposedITAT Hyderabad30 Aug 2019AY 2009-10

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

ASR ENGINERING & PROJECTS LIMITED (FORMERLY SAI SUDHIR INFRASTRUCTURES LIMITED), ,HYDERABAD vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), HYDERABAD

In the result, a) ITA Nos

ITA 1133/HYD/2017[2008-09]Status: DisposedITAT Hyderabad30 Aug 2019AY 2008-09

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahmansrl Appeal Number Pan A.Y. Appellant Respondent 1

Section 132Section 139(1)Section 143(3)Section 153A

…nd the word 'reassess' to completed assessment proceedings". 13. Reliance is also placed on the decision of Hon'ble Supreme Court in the case of Sun Engineering Works Pvt Lt (198 ITR 297) and in the case of Chettinad Corporation Pvt. Ltd. Vs. CIT reported in (200 ITR 320) on the point that fresh claim of deductions cannot be made in reassessment proceedings. In the present case, the proceedings are in the nature of reassessment proceedings because the original assessments were concluded earlier for most of the years.The return in response to notice u/s 153A is also not filed within the time specified. In light of…

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