Hyder Consulting (UK) Ltd. v. State of Orissa

SP CHIDAMBARAM,KANCHIPURAM vs. ITO, WARD 1, KANCHIPURAM, KANCHIPURAM

Bench: Ms. Padmavathy S. & Shri Manu Kumar Giriआयकर अपील सं./Ita No. 3934/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 Sp Chidambaram 21-A/6, Vallal Pachiyappan Street, Kancheepuram-631501 Tamil Nadu [Pan: Aachc 3681 B] (अपीलार्थी/Appellant) V. The Ito, Ward (1), Kancheepuram, 96, Munuswamy Mudaliar Avenue, Kancheepuram-631501 (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By Mr. K. Subash Anbarasu, Adv प्रत्यर्थी की ओर से / Respondent By Ms. Gouthami Manivasagam, Addl. Cit सुनवाईकीतारीख/Date Of Hearing 28.01.2025 घोषणाकीतारीख /Date Of Pronouncement 29.01.2026 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 17.12.2025 For Ay 2020-21. 2. At The Outset, We Notice That The Assessee By The Ground No.4 Challenges The Jao Jurisdiction To Issue Notice U/S148 Dated 29.03.2024 Of The Act. :: 2 ::

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

SUN POWER LIFE BATTERY CENTRE,KOVILPATTI vs. ITO WARD 2, TUTICORIN, TUTICORIN

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita No 3390/Chny/2025 निर्धारण वर्ष/Assessment Year: 2018-19 Sun Power Life Battery Centre Ito Ward 2 Tuticorin No. 23H-25, Krishnan Kovil St, Kovilpatti-628501 19A Main Building, West Greater Cotton Road, Tuticorin-628001 [Pan: Abnfs 4366 B] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से / Assessee By : Mr. K. Balasubramanian Advocate प्रत्यर्थी की ओर से /Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 21.01.2026 घोषणा की तारीख / Date Of Pronouncement : 27.01.2026 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 14.10.2025 For Ay 2018-19.

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

SHANMUGAM CHINNIA GOUNDER,COIMBATORE vs. ITO NON CORP WARD 1(1), COIMBATORE, COIMBATORE

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita No 3366/Chny/2025 निर्धारण वर्ष/Assessment Year: 2018-19 Shanmugam Chinnia Gounder V. No. 240, Sasthiri Street, Avinashi Road Br Puram, Peelamedu, Coimbatore-641 004 [Pan: Afkpc 1564 Q] (अपीलार्थी/Appellant) Ito Ncw 1(1) Све, Annexe Building, Tamil Nadu (प्रत्यर्थी/Respondent) Mr. Abhishek Murali, C.A. अपीलार्थी की ओर से / Assessee By : प्रत्यर्थी की ओर से / Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 21.01.2026 घोषणा की तारीख / Date Of Pronouncement : 27.01.2026 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 28.05.2024 For Ay 2018-19.

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. ITA No.3366/Chny/2025 (AY 2018-19) Shanmugam Chinnia Gounder Vs ITO NCW 1(1) Coimbatore :: 11 :: 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025,…

VASU SARAVANAN,CHENNAI vs. ITO,NON CORP WARD 1(6),CHENNAI, CHENNAI

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपील सं./Ita No 3331/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 Vasu Saravanan Old No 39, New No. 2, Ramasamy Street, T Nagar, Chennai-600 017 [Pan: Apgps 9284 M] (अपीलार्थी/Appellant) V. Ito, Non Corp Ward 1(6) Chennai, Room No. 412, Main Building Ayakar Bhavan, Nungambakka, Chennai, T.N-600034 (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से / Assessee By Mr. Y Sridhar, F.C.A. प्रत्यर्थी की ओर से / Respondent By Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/Date Of Hearing 20.01.2026 घोषणा की तारीख / Date Of Pronouncement 27.01.2026 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 19.09.2025 For Ay 2020-21.

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

JAYA CHANDRA RAJAN,TIRUNELVELI vs. ITO, WARD 1 TIRUNELVEL, TIRUNELVEL

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

SAMBASIVAM NANDHA,COIMBATORE vs. INCOME TAX OFFICER NON CORP WARD 3(2), COIMBATORE

In the result, appeal filed by the assessee is allowed in terms above and the stay application is dismissed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.3245/Chny/2025 "नधा"रण वष"/Assessment Year: 2018-19 & Sa No.117/Chny/2025 [In Ita No.3245/Chny/2025] V. Shri Sambasivam Nandha, Ito, 10/305, 7Th Street, Nchatra Non-Corporate Ward-3(2), Garden, Oraikalpalayam, Race Course, Coimbatore, Masagoundenchettipalayam, Tamil Nadu-641018 Coimbatore Tamil Nadu. [Pan: Ahepn0682Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. K. Gowtham, Ca : ""यथ" क" ओर से /Respondent By Mr. Guru Prasad, Addl.Cit : सुनवाईक"तार"ख/Date Of Hearing 13.01.2026 : घोषणाक"तार"ख /Date Of Pronouncement 14.01.2026

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

SIDHAMPOONDI PA CULTURAL COOP BANK LTD. S 1392,NAMAKKAL vs. ITO, WARD-2,, NAMAKKAL

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.3070/Chny/2025 निर्धारण वर्ष/Assessment Year: 2019-20 Sidhampoondi Pa Cultural Co-Op Bank Ltd S 1392, 2/173, Main Road, Kondarasampalayam Post P. Velur Tk, Namakkal-637203 Tamil Nadu [Pan: Aabas 0168 F] (अपीलार्थी/Appellant) V. Ito, Ward-02, Namakkal, Tamil Nadu-6370001 (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : None प्रत्यर्थी की ओर से / Respondent By : Mr. Arv Srinivasan, Cit सुनवाईकीतारीख/Date Of Hearing : 18.12.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.12.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeal By The Assessee Is Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac, Delhi Dated 12.08.2025 For Ay 2019-20. 2. At The Outset, We Notice That The Assessee By The Ground No.2 Challenges The Jao Jurisdiction To Issue Notice U/S148 Dated 30.03.2023 Of The Act.

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

CPT ELECY SYSTEM EMPLOYEES COOP T&C SOCIETY,KANCHEEPURAM vs. ITO, WARD-1,, KANCHEEPURAM

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No. 3058/Chny/2025 "नधा"रण वष"/Assessment Year: 2020-21 V. Cpt Elecy System Employees Ito, Coop T & C Society Che-W-(141) (91) No 30 S M Dass Avenue, Chennai, Iyappa Nagar, Tamil Nadu Kancheepuram-631501 [Pan: Aacac8508J] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

SWAMEDAS PANITHASAN,CHENNAI vs. ITO, NON-CORPORATE WARD 17(2) , CHENNAI

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.3056/Chny/2025 "नधा"रण वष"/Assessment Year: 2015-16 V. Swamedas Panithasan Ito, No 14/82 New No 20 Anna Salai, Non-Corporate Ward-17(2), Periyar Nagar A, T. Nagar Chennai. Chennai Alwarthiru Nagar, Alwarthirunagar, Chennai-600087 Tamil Nadu [Pan: Axjpp4321R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

MEENAKSHISUNDARAM SARAVANAN,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, TIRUNELVELI, TIRUNELVELI

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

INDIRAN SELVI,VELLORE vs. ITO, WARD-3,, VELLORE

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

KAMARAJ PRIYA,TIRUVARUR vs. ITO, WARD-1,, TIRUVARUR

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2484/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 V. The Ito, Kamaraj Priya, 2/94, Chinnaian Street, Ward-1, Karuvakurichi, Tiruvarur 614 018. Tiruvarur. [Pan:Dwqpp1186K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

JITHENDER TATIA,CHENNAI vs. ITO, WARD-115(92), CHENNAI

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2618/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 V. Jithender Tatia, The Ito, No.127, 9Th Block, Flat No.9031, Ward-115(92), 3Rd Floor, Tvh Lumbini Square, Chennai. Purasawalkam, Chennai-600 007. [Pan: Aafpj 8967 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). H…

VLSPL 136 VANGLOOR PACCS,VELLORE vs. ITO, WARD-1,, VELLORE

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2609/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 V. Vlspl 136 Vangloor Primary The Ito, Agricultural Coop. Credit Society, Ward-1, Vlspl 136 Vangloor Pacb, Vellore. Walajapet, Vellore-632 513. [Pan: Aabav 0564 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). H…

DICTO DINO RAJ DENNIS,KODIMUNAI, KALKULAM vs. INCOME TAX OFFICER, WARD - 1, NAGERCOIL, INCOME TAX OFFICE, NAGERCOIL

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2561/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 V. Dicto Dino Raj Dennis, The Ito, No.4/218, Anbiyam-23, Kodimunai, Ward-(1), Kodimunai Post, Kalkulam Taluka, Nagercoil. Kanyakumari-629 251. [Pan: Brlpd 0629 M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). H…

PALANIYAPPAN LOGANATHAN,SALEM vs. ITO, WARD-1(2), SALEM

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2549/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 V. Palaniyappan Loganathan, The Ito, 5/95, South Street, Ward-1(2), Navalur Attur, Salem. Salem-636 116. [Pan: Aqjpl 5540 P] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. Palaniyappan Loganathan :: 9 :: 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the rat…

SUNDARAM YESURAJA SUNIL,CHENNAI vs. ITO, NON CORPRATE WARD 9(1), CHENNAI, CHENNAI

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2545/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 V. Sundaram Yesuraja Sunil, The Ito, Dr.No.1/10, Non-Corporate Ward-9(1), Kovur Vaithyanathan Street, Chennai. Chintadripet, Chennai-600 002. [Pan: Gedps 3793 M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr. Girish Kumar. S, Advocate ""थ" की ओर से /Respondent By : Ms.R. Anitha, Addl.Cit : सुनवाईक"तारीख/Date Of Hearing 18.11.2025 घोषणाक"तारीख /Date Of Pronouncement : 26.11.2025

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. Sundaram Yesuraja Sunil :: 9 :: 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the rat…

SATHISKUMAR,NAMAKKAL vs. ITO, WARD 1, TIRUCHENGODE, TIRUCHENGODE

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2537/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 V. Sathishkumar, The Ito, 1/126, Senkuttaipalayam Ward-1, Seerampalayam Post, Tiruchengode. Samayasangali Agraharam, Tiruchengode, Namakkal-638 008. [Pan: Ggwps 7474 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). H…

THURAPSHA SYED IBRAHIM,TIRUNELVELI vs. ITO, WARD-4,, TIRUNELVELI

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1884/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 V. Thurapsha Syed Ibrahim, The Ito, No.6/16, Pallivasal Street, Ward-4, Vedampudur, Aiyampuram P.O., Tirunelveli. Tirunelveli – 627 805. [Pan: Abepi 2962E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). Ho…

SUDHA,TIRUNELVELI vs. ITO, WARD-4,, TIRUNELVELI

In the result, appeal filed by the assessee is allowed in terms above

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.2360/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 V. Sudha, The Ito, 4-254, Panchayat Street, Ward-4, Avaraikulam, Tirunelveli. Radhapuram, Tirunelveli-627 133. [Pan: Gbtps 0255 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

…sdiction of JAO and FAO, is ex facie per incuriam, as it disregards the statutory mandate of Section 151A and binding law under Article 141. The doctrine of per incuriam, as settled by the Supreme Court in Hyder Consulting (UK) Ltd. v. State of Orissa, (2016) 6 SCC 362, squarely applies since the decision of this Court was rendered in disregard of binding pronouncements of the Supreme Court and is thus not good law. 6. He further stated that this Court in PC Jeweller Ltd. v. ACIT, W.P.(C) 13229/2024, dated 23.01.2025, had dismissed the writ petition therein by relying upon the ratio of T.K.S. Builders (Supra). H…