Foramer France v. CIT

247 ITR 436High Court2001#1471 most cited

What is Foramer France v. CIT authority for?

The High Court, affirmed by the Supreme Court, clarifies the scope of reassessment under the new Section 147 (post-1989 amendment), holding that reassessment is invalid if the assessee fully disclosed material facts or if the issue was already examined during the original assessment under Section 143(3), especially for proceedings initiated beyond four years.

77

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2010 to 2025.

Also referred to as

Foramer France v. CIT · 247 ITR 436 · reassessment · Section 147 · escaped assessment · Section 147 proviso · failure to disclose material facts · original assessment · Section 143(3) · beyond four years · 1989 amendment Section 147 · reason to believe

Sections most often in play

Section 143(3)Section 147Section 148Section 142(1)Section 131Section 132Section 133(6)Section 139

Issues it is cited on

section 147(1)section 11(4)section 4asection 164(2)section 11(6)advancement of general public utilitysection 153(3)section 44bbsection 147(b)section 44bsection 13(2)section 11(4a)

Judgments citing Foramer France v. CIT

M/S. ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, NCC-8(1), LTU-II,, CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

…f relevant AY 2010-11 and in the absence of failure on part of the Appellant to disclose material facts as per First Proviso to section 147, the order passed by AO is required to be quashed in light of the following judicial precedents • Foramer v. CIT [2001] 247 ITR 436 (All.) (affirmed by SC in CIT v. Foramer France [2003] 264 ITR 566 (SC); • Fenner (India) Ltd. v. DCIT [2000] 241 ITR 672 (Madras HC) 3.2. The CIT(A) ought to have appreciated that the appellant has not merely submitted the books of accounts before the AO, whereas a complete scrutiny has been done, wherein the issues / addition made in the reass…

INCOME TAX OFFICER, CHENNAI vs. MACMILLAN EDUCATION INDIA PRIVATE LIMITED, CHENNAI

In the result, the appeal filed by the revenue and cross objection filed by the assessee are dismissed

ITA 2036/CHNY/2024[2013-14]Status: DisposedITAT Chennai30 Jan 2025AY 2013-14

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 2036/Chny/2024 & Co No.: 66/Chny/2024 िनधा"रणवष" / Assessment Year: 2013-14 Income Tax Officer, Macmillan Education India Corporate Ward -4(1), V. Private Limited, Chennai – 600 034. No.21, Patullos Road, Chennai – 600 002. [Pan:Aafcm-5564-R] (अपीलाथ"/Appellant) (Respondent/Cross Objector) Assessee By : Mr. S.P. Chidambaram, Advocate : Ms. R. Anita, Addl.Cit Department By सुनवाई क" तार"ख/Date Of Hearing : 22.11.2024 घोषणा क" तार"ख/Date Of Pronouncement : 30.01.2025 आदेश /O R D E R

For Appellant: Mr. S.P. Chidambaram, Advocate
Section 143(2)Section 147

…No: 66/Chny/2024 relying on the decision of the Hon’ble Supreme Court in the case of CIT Vs.Foramer France (2003) 264 ITR 566, wherein the Hon’ble Supreme Court affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France Vs. CIT (2001) 247 ITR 436, in its order dated 26.09.2022 vide ITA No. 2784/Chny/2019 by holding as under: “6.3 Having gone through the reasons for re-opening u/s 147 of the Act and the appellant's written submission and other documentary evidence, I find that the issue of returns rights at Rs.3,33,34,000/- was considered by the Ld AO while passing original order u/s 143(…

S.P. SINGLA CONSTRUCTION PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CHANDIGARH

In the result, the appeal is allowed

ITA 514/CHANDI/2023[2012-2013]Status: DisposedITAT Chandigarh02 Jan 2025AY 2012-2013

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Ashwani Kumar, CAFor Respondent: Smt. Kusum Bansal, CIT-DR
Section 127Section 132Section 143(3)Section 147Section 148Section 148(2)Section 153Section 153A

…hanged and this has been explained by Hon'ble Supreme Court in the case of Foramer France (supra) ITA 514/CHD/2023 A.Y. 2012-13 21 wherein Hon'ble Supreme Court has affirmed the decision of Hon'ble Allahabad High Court in the case of Foramer Vs CIT (2001) 247 ITR 436 (All), wherein Hon'ble Allahabad High Court has considered this issue as under : “14. It may be mentioned that a new Section substituted Section 147 of the Income- tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section 147 is as follows : "147. If the Assessing Officer, has re…

BEST REALTRECH INDIA P.LTD,NEW DELHI vs. ITO, WARD-4(3), NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 390/DEL/2020[2011-12]Status: DisposedITAT Delhi27 Dec 2024AY 2011-12

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahmanm/S Best Realtrech Income Tax Officer, (India) Pvt. Ltd., Ward-4(3), New Delhi H-8, First Floor, Vs. Best Plaza, Netaji Subhash Place, Pitampura, Delhi-110034 Pan:Aadcb1848D (Appellant) (Respondent)

Section 132Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 153CSection 68

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘A’: NEW DELHI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER M/s Best Realtrech Income Tax Officer, (India) Pvt. Ltd., Ward-4(3), New Delhi H-8, First Floor, Vs. Best Plaza, Netaji Subhash Place, Pitampura, Delhi-110034 PAN:AADCB1848D (Appellant) (Respondent) Assessee by Shri Salil Kapoor, Adv. & Shri Anil Chachra, Adv. Department by Shri Javed Akhtar, CIT-DR Date of Hearing 11/12/2024 Date of Pronouncement 27/12/2024 O R D E R PER BENCH: This appeal by assessee is arising out of the order of Learned Commissioner of Inc…

MANIPAL FINANCIAL SERVICES,CHENNAI vs. ITO, BUSINESS WARD XV(4), CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 947/CHNY/2024[2005-06]Status: DisposedITAT Chennai12 Sept 2024AY 2005-06

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.:947/Chny/2024 िनधा"रण वष"/Assessment Year:2005-06 Manipal Financial Services, The Income Tax Officer, 328, Plaza Centre, Business Ward Xv(4), Vs. 129 Gn Chetty Road, Chennai. Chennai – 600 006. Pan: Aakfm 7449R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms. R.Anita, Jcit सुनवाई क" तारीख/Date Of Hearing : 10.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 12.09.2024 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi In Order No.Itba/Nfac/S/250/2023-24/ 1061661390(1) Dated 28.02.2024. The Assessment Was Framed By The Income Tax Officer, Business Ward Xv(4), Chennai For The Assessment Year 2005-06 U/S.147 R.W.S. 143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 25.03.2013. 2. The First Issue In This Appeal Of Assessee Is As Regards To The Order Of Cit(A)-Nfac Confirming The Action Of The Ao In Assuming Jurisdiction U/S.147 Of The Act & Consequently Confirmed The Reassessment Order.

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Ms. R.Anita, JCIT
Section 143(1)Section 143(3)Section 147Section 148Section 47

…y covered by the decision of Hon’ble Supreme Court in the case of CIT vs. Foramer France, reported in (2003) 264 ITR 566, wherein the Hon’ble Supreme Court has affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France vs. CIT, (2001) 247 ITR 436, wherein it is held as under:- 14. Having heard learned counsel for the parties, we are of the view that these petitions deserve to be allowed. 15. It may be mentioned that a new Section substituted Section 147 of the Income-tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, TIRUNELVELI, TIRUNELVELI vs. MS.AARTHI SCANS, KOVILPATTI

In the result, the appeal filed by the Revenue is dismissed

ITA 75/CHNY/2024[2012-13]Status: DisposedITAT Chennai30 May 2024AY 2012-13

Bench: Shri Mahavir Singhand Shri Jagadish

For Appellant: Shri P. Sajit Kumar, JCITFor Respondent: Shri Vijay Kumar, CA
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148

…the decision of Hon’ble Supreme Court in the case of CIT vs. Foramer France, reported in (2003) 264 ITR 566, wherein the Hon’ble Supreme Court has affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France vs. CIT, reported in (2001) 247 ITR 436 by observing as under:- 14. Having heard learned counsel for the parties, we are of the view that these petitions deserve to be allowed. 15. It may be mentioned that a new Section substituted Section 147 of the Income-tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section 147 is…

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1638/CHNY/2023[2018-19]Status: DisposedITAT Chennai27 Mar 2024AY 2018-19

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1637/CHNY/2023[2017-18]Status: DisposedITAT Chennai27 Mar 2024AY 2017-18

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1636/CHNY/2023[2016-17]Status: DisposedITAT Chennai27 Mar 2024AY 2016-17

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1635/CHNY/2023[2015-16]Status: DisposedITAT Chennai27 Mar 2024AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1634/CHNY/2023[2014-15]Status: DisposedITAT Chennai27 Mar 2024AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1633/CHNY/2023[2013-14]Status: DisposedITAT Chennai27 Mar 2024AY 2013-14

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

ITA 1632/CHNY/2023[2012-13]Status: DisposedITAT Chennai27 Mar 2024AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

For Appellant: Shri B. Ramakrishna, FCA &For Respondent: Shri V. Nandakumar, CIT
Section 11Section 11(4)Section 13(1)(c)Section 147Section 164(2)

…jurisdiction, there was no merit in plea that petitioner was to be relegated to alternative remedy - Held, yes. 15. The Hon’ble Supreme Court has also affirmed the decision of the Hon’ble Allahabad High Court in the case of Foramer v. CIT reported in [2001] 247 ITR 436 (Allahabad). The Hon’ble Allahabad High Court held that when there is no failure on the part of the assessee to make a full and true disclosure of facts necessary for the assessment year, the provisions of Sec.147 of the Act, is squarely applied and the impugned notices issued u/s.148 of the Act were bad in law. The Hon’ble Allahabad High Cou…

STAR PLASTICS,CHENNAI vs. DCIT, CHENNAUI

In the result, the appeal filed by the assessee is allowed

ITA 707/CHNY/2023[2011-12]Status: DisposedITAT Chennai22 Mar 2024AY 2011-12

Bench: SHRI MAHAVIR SINGH, VICE PRESIDENTAND SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Ms.N.V. Lakshmi, AdvocateFor Respondent: Shri AR.V. Sreenivasan, Addl.CIT
Section 143(3)Section 147Section 148

…his view of ours is supported by the decision of Hon’ble Supreme Court in the case of CIT vs. Foramer France, (2003) 264 ITR 566, wherein the Supreme Court has affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France vs. CIT, (2001) 247 ITR 436 by observing as under:- 14. Having heard learned counsel for the parties, we are of the view that these petitions deserve to be allowed. 15. It may be mentioned that a new Section substituted Section 147 of the Income-tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section 147 is…

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 209/CHNY/2020[2010-11]Status: DisposedITAT Chennai23 Feb 2024AY 2010-11

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…his view of ours is supported by the decision of Hon’ble Supreme Court in the case of CIT vs. Foramer France, (2003) 264 ITR 566, wherein the Supreme Court has affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France vs. CIT, (2001) 247 ITR 436 by observing as under:- 14. Having heard learned counsel for the parties, we are of the view that these petitions deserve to be allowed. 15. It may be mentioned that a new Section substituted Section 147 of the Income-tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section 147 is…

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 208/CHNY/2020[2009-10]Status: DisposedITAT Chennai23 Feb 2024AY 2009-10

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…his view of ours is supported by the decision of Hon’ble Supreme Court in the case of CIT vs. Foramer France, (2003) 264 ITR 566, wherein the Supreme Court has affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France vs. CIT, (2001) 247 ITR 436 by observing as under:- 14. Having heard learned counsel for the parties, we are of the view that these petitions deserve to be allowed. 15. It may be mentioned that a new Section substituted Section 147 of the Income-tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section 147 is…

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

ITA 207/CHNY/2020[2008-09]Status: DisposedITAT Chennai23 Feb 2024AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri D. Anand, Advocate
Section 139Section 139(5)Section 143(3)

…his view of ours is supported by the decision of Hon’ble Supreme Court in the case of CIT vs. Foramer France, (2003) 264 ITR 566, wherein the Supreme Court has affirmed the decision of Hon’ble Allahabad High Court in the case of Foramer France vs. CIT, (2001) 247 ITR 436 by observing as under:- 14. Having heard learned counsel for the parties, we are of the view that these petitions deserve to be allowed. 15. It may be mentioned that a new Section substituted Section 147 of the Income-tax Act by the Direct Tax Laws (Amendment) Act, 1987, with effect from April 1, 1989. The relevant part of the new Section 147 is…

DCIT CENTRAL CIRCLE-3(1), CHENNAI vs. SANTHA BUILD TECH INIDA PRIVATE LIMITED, EKKATUTHANGAL

In the result, the appeal filed by the Revenue is dismissed

ITA 573/CHNY/2023[2013-14]Status: DisposedITAT Chennai08 Nov 2023AY 2013-14

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri AR.V. Sreenivasan, Addl.CITFor Respondent: None
Section 143(3)Section 147Section 148Section 194A

…आयकर अपीलीय अिधकरण, ‘ए’ "यायपीठ,चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं "ी मंजुनाथ. जी, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI MANJUNATHA.G, ACCOUNTANT MEMBER आयकर अपीलसं./ITA No.: 573/CHNY/2023 िनधा"रण वष"/Assessment Year: 2013-14 The Deputy Commissioner Santha Build Tech India Pvt. of Income Tax, vs. Ltd., Central Circle-3(1), TS65, OM Shakthy Tower-II, Chennai SIDCO Industrial Estate, Ekkatuthangal, Chennai – 600 032. PAN: AACCS 9327H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri AR.V. Sreenivasan, Addl.…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

ITA 981/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…आयकर अपीलीय अिधकरण, ‘सी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं "ी मंजुनाथ. जी, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI MANJUNATHA.G, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.: 981/CHNY/2020 िनधा"रण वष"/Assessment Year: 2008-09 The ACIT, The Villupuram District Circle - 1, vs. Central Co-operative Bank Cuddalore Ltd., No.2, Hospital Road, Villupuram – 605 602. PAN: AAAJV 0332Q (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./ITA Nos.: 854, 855, 856, 857 & 858/CHNY/2020 िनधा"रण वष"/Assessment Years: 2010-11, 2011-12, 2012-13…

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

ITA 858/CHNY/2020[2009-10]Status: DisposedITAT Chennai18 Oct 2023AY 2009-10

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…आयकर अपीलीय अिधकरण, ‘सी’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी महावीर "सह, उपा"य" एवं "ी मंजुनाथ. जी, लेखा सद"य के सम" BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI MANJUNATHA.G, ACCOUNTANT MEMBER आयकरअपीलसं./ITA No.: 981/CHNY/2020 िनधा"रण वष"/Assessment Year: 2008-09 The ACIT, The Villupuram District Circle - 1, vs. Central Co-operative Bank Cuddalore Ltd., No.2, Hospital Road, Villupuram – 605 602. PAN: AAAJV 0332Q (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपीलसं./ITA Nos.: 854, 855, 856, 857 & 858/CHNY/2020 िनधा"रण वष"/Assessment Years: 2010-11, 2011-12, 2012-13…

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Foramer France v. CIT (247 ITR 436) — Cited in 77 Judgments | BharatTax