State of Orissa and Anrs v. Dhirendra Sundar Das & Ors.

Sp Chidambaram, Kanchipuram vs. ITO, Ward 1, 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 ::

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

Sun Power Life Battery Centre, Kovilpatti vs. ITO Ward 2, 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.

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

Shanmugam Chinnia Gounder, Coimbatore vs. ITO Non Corp Ward 1(1), 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.

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

Vasu Saravanan, Chennai vs. ITO, Non Corp Ward 1(6), 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.

…ent.” (Emphasis supplied) ITA No 3331/Chny/2025 (AY 2020-21) VASU SARAVANAN (Vs.) ITO NON CORP WARD 1 (6) :: 12 :: 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

Jaya Chandra Rajan, Tirunelveli vs. ITO, Ward 1 Tirunelvel, Tirunelvel

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Periyasamy Anbunathan, Karur

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

…ced on the decisions of the Hon'ble Supreme Court in the cases of Kunhayammed 245 ITR 360 and Khoday Distilleries Ltd. 104 taxmann.com 25 (SC)]. The Hon'ble Supreme Court, in the case of State of Orissa and Another v. Dhirendra Sundar Das And Others - [(2019) 6 SCC 270 (SC)] has clarified this position with the following observations at Para 9.27: ITA No.1488/Chny/2025 (AY 2015-16) & Others Periyasamy Anbunathan :: 20 :: "9.27 It is a well settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Association v. Union of India & Anr. and State of Punja…

Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Periyasamy Anbunathan, Karur

In the result, all the appeals of the Revenue and the assessee are

…laced on the decisions of the Hon'ble Supreme Court in the cases of Kunhayammed 245 ITR 360 and Khoday Distilleries Ltd. 104 taxmann.com 25 (SC)]. The Hon'ble Supreme Court, in the case of State of Orissa and Another v. Dhirendra Sundar Das And Others [(2019) 6 SCC 270 (SC)] has clarified this position with the following observations at Para 9.27: :: 21 :: "9.27 It is a well settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Association v. Union of India & Anr. and State of Punjab v. Davinder Pal Singh Bhullar, that the dismissal of a S.L.P. in l…

Deputy Commissioner of Income Tax, Central Circle-1(4), Chennai vs. Periyasamy Anbunathan, Karur

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

…ced on the decisions of the Hon'ble Supreme Court in the cases of Kunhayammed 245 ITR 360 and Khoday Distilleries Ltd. 104 taxmann.com 25 (SC)]. The Hon'ble Supreme Court, in the case of State of Orissa and Another v. Dhirendra Sundar Das And Others - [(2019) 6 SCC 270 (SC)] has clarified this position with the following observations at Para 9.27: ITA No.1488/Chny/2025 (AY 2015-16) & Others Periyasamy Anbunathan :: 20 :: "9.27 It is a well settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Association v. Union of India & Anr. and State of Punja…

Periyasamy Anbunathan, Karur vs. DCIT, CC-1(4), Chennai

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

…ced on the decisions of the Hon'ble Supreme Court in the cases of Kunhayammed 245 ITR 360 and Khoday Distilleries Ltd. 104 taxmann.com 25 (SC)]. The Hon'ble Supreme Court, in the case of State of Orissa and Another v. Dhirendra Sundar Das And Others - [(2019) 6 SCC 270 (SC)] has clarified this position with the following observations at Para 9.27: ITA No.1488/Chny/2025 (AY 2015-16) & Others Periyasamy Anbunathan :: 20 :: "9.27 It is a well settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Association v. Union of India & Anr. and State of Punja…

Periasamy Anbunathan, Karur vs. DCIT, CC-1(4), Chennai

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

…ced on the decisions of the Hon'ble Supreme Court in the cases of Kunhayammed 245 ITR 360 and Khoday Distilleries Ltd. 104 taxmann.com 25 (SC)]. The Hon'ble Supreme Court, in the case of State of Orissa and Another v. Dhirendra Sundar Das And Others - [(2019) 6 SCC 270 (SC)] has clarified this position with the following observations at Para 9.27: ITA No.1488/Chny/2025 (AY 2015-16) & Others Periyasamy Anbunathan :: 20 :: "9.27 It is a well settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Association v. Union of India & Anr. and State of Punja…

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

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees’ Welfare Assn. V. Union of India [Supreme Court Employees’ Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

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.

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9. 27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pa…

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)

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees’ Welfare Assn. V. Union of India [Supreme Court Employees’ Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

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)

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9.27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees’ Welfare Assn. V. Union of India [Supreme Court Employees’ Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pal…

Meenakshisundaram Saravanan, Chennai vs. Assistant Commissioner of Income Tax, Circle 1, Tirunelveli

…detailed reasons therefore does not constitute any declaration of law or a binding precedent.” (Emphasis supplied) 14. In this regard, we may refer to the judgment of the Supreme Court in State of Orissa and Another vs. Dhirendra Sundar Das and Others, (2019) 6 SCC 270, wherein it was observed as under:- “9. 27. It is a well-settled principle of law emerging from a catena of decisions of this Court, including Supreme Court Employees' Welfare Assn. V. Union of India [Supreme Court Employees' Welfare Assn. V. Union of India, (1989) 4 SCC 187, paras 22 and 23 : 1989 SCC (L&S) 569] and State of Punjab v. Davinder Pa…