“fresh tangible material”

ReassessmentSection 147Section 147398 judgments

The decision most relied on for fresh tangible material is CIT v. Kelvinator of India Ltd. (320 ITR 561), cited in 1,673 judgments on BharatTax.

Leading authorities on fresh tangible material

CIT v. Kelvinator of India Ltd.

320 ITR 561 · 2010 · Supreme Court

1,673

citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. Kelvinator of India Ltd.

256 ITR 1 · 2002 · High Court

439

citing judgments

An Assessing Officer cannot reopen an assessment under Section 147 based on a mere change of opinion regarding the same material available during the original assessment. Reopening requires fresh, tangible material or information that leads to a reason to believe income has escaped assessment.

CIT v. Orient Craft Ltd.

354 ITR 536 · 2013 · High Court

366

citing judgments

Reassessment of income, especially after a summary assessment under Section 143(1), requires the Assessing Officer to possess fresh, tangible material to form a reason to believe that income has escaped assessment; a mere reappraisal of existing records or a change of opinion without new material is not permissible.

CIT v. SFIL Stock Broking Ltd.

325 ITR 285 · 2010 · High Court

243

citing judgments

Reassessment proceedings under Section 147 are invalid and void ab initio if initiated based on 'borrowed satisfaction' without the Assessing Officer's independent application of mind, or merely on documents already available on record without fresh tangible material.

CIT v. Usha International Ltd.

348 ITR 485 · 2012 · High Court

231

citing judgments

A reassessment is invalid due to 'mere change of opinion' if an issue was raised during original assessment but no addition was made, implying the issue was examined. However, if a subject matter was not examined and no opinion was formed, the principle of 'change of opinion' does not apply.

ITO v. TechSpan India (P) Ltd.

92 Taxmann.com 361 · 2018 · Supreme Court

194

citing judgments

Reassessment under Section 147/148 is invalid if it constitutes a mere change of opinion by the Assessing Officer without any fresh tangible material, especially after the assessee made a full and truthful disclosure during the original scrutiny assessment under Section 143(3).

Prashant S. Joshi v. ITO

324 ITR 154 · 2010 · High Court

179

citing judgments

Reasons recorded under Section 148 for reopening an assessment are jurisdictional facts that form the sole basis for assuming power and cannot be changed, supplemented, or corrected later. Such reasons must be based on fresh tangible material indicating income escapement.

Asian Paints Ltd. v. DCIT

308 ITR 195 · 2009 · High Court

175

citing judgments

An Assessing Officer cannot issue a notice under Section 148 to reopen an assessment when all material facts were already before the AO during the original assessment, even if the AO failed to apply their mind at that time. Such an action constitutes an impermissible review of a concluded assessment rather than a reassessment based on fresh tangible material.

Judgments citing fresh tangible material

Hero Motocorp Ltd (As Successor of Hero Investment P.Ltd), New Delhi vs. DCIT, Circle 11(1), New Delhi

The appeal is allowed

ITA 1053/DEL/2023[2011-12]Status: DisposedITAT Delhi24 Jul 2024AY 2011-12

Bench: Shri G.S. Pannu & Shri Anubhav Sharmaassessment Year: 2011-12

Section 143(3)

proceedings, the AO cannot come out of the rigour of law, which mandates that re-opening can only be on the basis of fresh tangible material. Reliance can be placed on the decision of Hon'ble Supreme Court in the case of Kelvinator of India 320 ITR 561 (SC), wherein

Interarch Building Products P.Ltd, New Delhi vs. DCIT, Circle-11(1), New Delhi

In the result, the appeal of the assessee is allowed

ITA 8280/DEL/2018[2006-07]Status: DisposedITAT Delhi23 Jul 2024AY 2006-07

Bench: Shri M. Balaganesh & Shri Vimal Kumarinterarch Building Products Pvt. Ltd, Vs. Dcit, B-30, Sector-57, Noida, Circle-11(1), Uttar Pradesh New Delhi (Appellant) (Respondent) Pan:Aaaci0106J

For Appellant: Shri M. P. Rastogi, AdvFor Respondent: Shri Sandeep Kr. Mishra, Sr. DR

Section 143Section 143(3)Section 147Section 154Section 80I

issued to assessee." 5. On perusal of the aforesaid reasons, it could be safely concluded that the ld. AO did not possess any fresh tangible material which has live link with formation of belief that income of the assessee had escaped assessment warranting reopening within the meaning of section

Green Orchand Farm Houses, Bangalore vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bangalore

In the result, appeal of the assessee is partly allowed

ITA 879/BANG/2024[2016-17]Status: DisposedITAT Bangalore22 Jul 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Smt. Sheetal Borkar, A.RFor Respondent: Sri Saravanan B., D.R

Section 133(6)Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 151Section 154Section 43C

invoked the provisions of section 43CA of the Act while framing the assessment order itself. According to the ld. A.R., there was no fresh tangible material to invoke the provisions of section 147 r.w.s. 148 of the Act and there was no enquiry of whatsoever required to come

Tanvi Sandeep Mathur, Ahmedabad vs. The DCIT, Circle-7(1), Ahmedabad

In the result, appeal of the assessee is allowed

ITA 20/AHD/2020[2011-12]Status: DisposedITAT Ahmedabad15 Jul 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Ms. Suchitra Kambleassessment Year: 2011-12

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 151(2)Section 54

that the reopening of the assessment is bad and illegal as reopening is on the basis of review of assessment records without any fresh tangible material on record. It is clear that the Assessing Officer has reopened the assessment by verifying the case records and no new tangible material came

Uma Maheswara Rao Bodapati, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

ITA 292/HYD/2024[2016-17]Status: DisposedITAT Hyderabad03 Jul 2024AY 2016-17

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No. 292/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Uma Maheshwara Rao Vs. Dy. C. I. T. Bodapati, Circle 2(1) Hyderabad Hyderabad Pan:Atnpb5755D (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Adv. T. Chaitanya Kumar राज" व "ारा/Revenue By:: Shri Shakeer Ahmed, Dr सुनवाई की तारीख/Date Of Hearing: 13/06/2024 घोषणा की तारीख/Pronouncement: 03/07/2024 आदेश/Order

For Appellant: Adv. T. Chaitanya KumarFor Respondent: : Shri Shakeer Ahmed, DR

Section 143(3)Section 148Section 50C

observed that the Assessing Officer has reopened the assessment on the basis of reasons to believe which is further supported by fresh tangible material on the basis of Assessing Officer which suggests escapement of income. The learned CIT (A) also rejected the argument of the assessee in light of additional

Indu Mahendra Shah (L/H of Late Shri Mahendra G. Shah), Mumbai vs. ACIT, Circle-20(2), Mumbai

Appeal are dismissed as being infructuous

ITA 856/MUM/2024[2011-12]Status: DisposedITAT Mumbai20 Jun 2024AY 2011-12

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Devendra JainFor Respondent: Shri H.M. Bhatt

Section 10(38)Section 143(3)Section 147Section 148Section 151Section 68Section 69C

initiating the reassessment proceedings u/s 147 of the Act merely on the basis of change of opinion without being in possession of any fresh tangible material after completion of the first reassessment. 3. In the facts and circumstances of the case and in law, the Learned CIT(A) has erred ... satisfied. In our view, in the facts and circumstances of the present case, the report received from the Investigation Wing constitutes fresh tangible material for reopening the assessment, and it cannot be said that the re-assessment proceedings have been initiated without there being any fresh tangible material. However, mere

Star Aviation Private Limited, Mylapore vs. The Assistant Commissioner of Income Tax, Corporate Circle 6, Chennai, Nungambakkam

The appeal stand allowed in terms of our above order

ITA 1497/CHNY/2023[2009-10]Status: DisposedITAT Chennai11 Jun 2024AY 2009-10

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1497/Chny/2023 (िनधा*रण वष* / Assessment Year: 2009-10) M/S. Star Aviation Private Limited Acit Chennai Citi Centre, 4Th Floor बनाम/ Corporate Circle-6, 10 & 11, Dr.Radhakrishnan Salai, Chennai. Vs. Mylapore, Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aajcs-6206-J (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri V. Padmanabhan & Shri R. Venkata Raman (Cas) - Ld. Ar " थ"कीओरसे/Respondent By : Dr. D. Praveen (Jcit) -Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 16-05-2024 घोषणाकीतारीख /Date Of Pronouncement : 11-06-2024 आदेश / O R D E R

For Appellant: Shri V. Padmanabhan & Shri RFor Respondent: Dr. D. Praveen (JCIT) -Ld. Sr. DR

Section 143Section 143(3)Section 148

before Ld. AO during the course of original assessment proceedings. The reasons do not indicate any event as to the receipt of any fresh tangible material coming to the possession of Ld. AO subsequent to culmination of original assessment proceedings. The formation of belief is on the same ... similar facts, this Tribunal, in many decisions as cited by Ld. AR, has held that the reassessment proceedings, without there being any fresh tangible material, would be bad-in-law. These decisions include the decision in Indian Overseas Bank (ITA No.782/Chny/2001 dated 15.06.2022); V.K. Sasikala (ITA No.2785/Chny/2018 dated

Krishna Developers Pvt Ltd., Mumbai vs. Assistant Commissioner of Income Tax, Circle -10(1)(2), Mumbai

In the result, the appeal of the assessee is allowed

ITA 4292/MUM/2023[2009-10]Status: DisposedITAT Mumbai30 May 2024AY 2009-10

Bench: Shri B.R. Baskaran & Ms.Kavitha Rajagopalassessment Year : 2009-10 M/S. Krishna Developers Pvt. Ltd. 508, Gundecha Chambers, Nagindas Master Road, Fort, Mumbai – 400 023. Pan: Aabck-5678-G ---- Appellant Vs. Assistant Commissioner Of Income Tax, Circle – 10(1)(2), Mumbai Room No.651, 6Th Floor, Aaykar Bhavan, M.K. Road, Mumbai – 400 020. --- Respondent

For Appellant: Shri Rakesh JoshiFor Respondent: Shri P.D. Chougule, Sr. DR

Section 115JSection 133ASection 143(1)Section 143(3)Section 148Section 68

first reassessment proceedings. Hence there is failure on the part of the assessee on this count. He submitted that the survey report constitutes fresh tangible material and hence it is not a case of change of opinion. 10. We heard rival contentions and perused the record. We have gone through

DCIT 19 3, Mumbai vs. Sanjiv Mahendra Parikh, Mumbai

ITA 3515/MUM/2023[2012-13]Status: DisposedITAT Mumbai24 May 2024AY 2012-13

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Vijay MehtaFor Respondent: Shri Veerbhandra Mahajan

Section 142(1)Section 143(3)Section 147Section 148

Assessee against which objections were filed by the Assessee contending, inter alia, that the Assessing Officer did not have any fresh tangible material to form the basis of belief that income had escaped assessment. Reassessment proceedings were initiated merely on account of change of opinion on re- examination ... part of the Assessing Officer while recording reasons for reopening assessment. Assessing Officer has failed to appreciate the correct facts. There was no fresh tangible material available with the Assessing Officer. The Assessment was framed on the Assessee under Section 143(3) of the Act and while recording reasons

Srujitha Annapareddy, Secunderabad vs. Income Tax Officer, Ward-12(1), Hyderabad

In the result, appeal filed by the assessee is allowed

ITA 253/HYD/2024[2016-17]Status: DisposedITAT Hyderabad22 May 2024AY 2016-17

Bench: Shri Manjunatha, G.आ.अपी.सं /Ita No.253/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2016-17) Smt. Surjitha Annapareddy Vs. Income Tax Officer Secunderabad Ward 12(1) Pan:Bnwpa6703L Hydrabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A.V. Raghuram, Advocate राज" व "ारा/Revenue By:: Shri Y Srikanth Reddy, Dr सुनवाई की तारीख/Date Of Hearing: 22/05/2024 घोषणा की तारीख/Pronouncement: 22/05/2024

For Appellant: Shri A.V. Raghuram, AdvocateFor Respondent: : Shri Y Srikanth Reddy, DR

Section 10(38)Section 143(1)Section 147Section 148Section 68

including the investigation carried out by the Investigation Wing, Kolkata opined that, the Assessing Officer has reopened the assessment on the basis of fresh tangible material vis-à-vis escapement of income. The learned CIT (A) had also rejected the explanation of the assessee with regard to Long-Term Capital

M/S. Vadera Enterprises, Gondia vs. Income Tax Officer, Circle-5, Nagpur

Appeal is allowed in above terms

ITA 101/NAG/2023[2011-12]Status: DisposedITAT Nagpur10 May 2024AY 2011-12

Bench: Shri Satbeer Singh Godara

For Appellant: -None-For Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 143(3)Section 147Section 148

that too in case of sec.143(3) regular assessment since there is no discussion in the assessment herein about the discovery of any fresh tangible material. No reply came from Revenue side. That being the case, I hereby quote CIT vs. Kelvinator of India Limited [2010] 187 Taxman

ITO, Ward-30(4), New Delhi vs. Rashmi Rajiv Mehta, Gurgaon

In the result appeal of the Revenue is dismissed and cross objection is dismissed as not pressed

ITA 4399/DEL/2018[2011-12]Status: DisposedITAT Delhi24 Apr 2024AY 2011-12

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarasstt. Year: 2011-12 Ito, Ward-30(4), Vs. Rashmi Rajiv Mehta New Delhi E-52, Raheja Atlantis, Sector – 31, Nh-8, Gurgaon Haryana Pin 122002 Pan Akspm6239M (Appellant) (Respondent) Co No. 181/Del/2018 Arising Out Of Ita 4399/Del/2018 Asstt. Year 2011-12 Rashmi Rajiv Mehta Vs. Ito, Ward-30(4), E-52, Raheja New Delhi Atlantis, Sector – 31, Nh-8, Gurgaon Haryana Pin 122002 Pan Akspm6239M (Appellant) (Respondent)

For Appellant: Shri Ved Jain, AdvocatFor Respondent: Shri Vivek Vardhan, Sr. DR

Section 143(3)Section 147Section 148Section 68

assessment despite the fact that the Learned AO had reopened the assessment on the basis of doubt and suspicion. There was no fresh tangible material with the Learned AO to form any opinion regarding escapement of income. 6. At the time of hearing, Learned AR submitted that assessee preferred

P and Y Enterprises Pvt Ltd, Mumbai vs. ITO 5 (2) 1, Mumbai

In the result, the appeal of the assessee is partly allowed

ITA 3685/MUM/2023[2015-16]Status: DisposedITAT Mumbai12 Apr 2024AY 2015-16

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am Ito P & Y Enterprises Pvt. Ltd. Ward 5 (2) 1 123, A Wing Mittal Court, Aayakar Bhavan, Nariman Point, Vs. Mumbai 400021 M K Road, Mumbai 400020 (Appellant) (Respondent) Pan No. Aahcp2579B Assessee By : Shri Prakash Jhunjhunwala, Ar Revenue By : Shri H M Bhatt, Sr. Dr Date Of Hearing: 28.03.2024 Date Of Pronouncement : 12.04.2024

For Appellant: Shri Prakash Jhunjhunwala, ARFor Respondent: Shri H M Bhatt, Sr. DR

Section 143(2)Section 143(3)Section 147Section 194ASection 68

Learned. CIT(A) erred in confirming the validity of notice under Section. 148, though had been issued in absence of fresh tangible material and on the basis of borrowed satisfaction and without having reason to believe of escapement of income; 2. ON facts and circumstance of the case

ACIT, Cent Circle-1, Trichy vs. M/S Mangal & Mangal, Trichy

In the result, appeal filed by the revenue is dismissed

ITA 511/CHNY/2022[2012-13]Status: DisposedITAT Chennai09 Apr 2024AY 2012-13

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 511/Chny/2022 िनधा"रण वष" / Assessment Year: 2012-13 The Assistant Commissioner Of M/S. Mangal & Mangal, Income Tax, V. 25, N.S.B. Road, Teppakulam, Central Circle -2, Trichy – 620 002. No. 44, Williams Road, [Pan: Aaifm-3378-B] Cantonment, Trichy – 620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. S. Sridhar, Advocate : Shri. Nlay Baran Som, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 06.02.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. S. Sridhar, Advocate

Section 143(3)Section 147Section 148

assessee challenged reopening of assessment on the ground that, the Assessing Officer has reopened assessment on ‘change of opinion’ without there being any fresh tangible material came to his possession, subsequent to completion of assessment u/s. 143(3) r.w.s. 153A of the Act. The assessee, further contended that the assessment ... part of the AO is that on account· of non-furnishing of evidence the appellant has suppressed material facts. (e) There was no fresh tangible material which came to the possession of the Assessing Officer after completion of original assessment for forming a prima facie belief regarding the escapement

Blue Coast Infrastructure Development P.Ltd, Solan vs. DCIT, Central Circle-1, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 2984/DEL/2022[2012-13]Status: DisposedITAT Delhi05 Apr 2024AY 2012-13

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Ved Jain, AdvFor Respondent: Shri Kanv Bali, Sr. DR

Section 143(2)Section 143(3)Section 147Section 148Section 151

Assessing Officer that the assessee had claimed expenditure of Rs. 832.23 lakhs. This fact clearly reveals that the Assessing Officer had no fresh tangible material in his possession while reopening assessment u/s 147 of the Act. 16. In fact, while making bald allegation regarding failure of the assessee in disclosing

ITO, International Taxation Ward1(2), Chennai vs. Rajamanickam Arulselvan, Chennai

In the result, the appeal filed by the Revenue and the Cross

ITA 479/CHNY/2023[2013-14]Status: DisposedITAT Chennai01 Apr 2024AY 2013-14

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./I.T.A. No.479/Chny/2023 िनधा"रण वष"/Assessment Year: 2013-14 & C.O. No. 44/Chny/2023 [In I.T.A. No. 479/Chny/2023] The Income Tax Officer, Vs. Shri Rajamanickam Arulselvan, 65, Defence Officer Colony, 2Nd International Taxation Ward 1(2), Bsnl Building Tower-1, 4Th Floor, Avenue, 6Th Cross Street, Guindy, Greams Road, Thousand Light, Guindy Industrial Estate S.O., Chennai 600 006. Chennai 600 032. [Pan:Aappa2346C] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri P. Sajit Kumar, Jcit Assessee By : Shri N.V. Balaji, Advocate सुनवाई की तारीख/ Date Of Hearing : 03.01.2024 घोषणा की तारीख /Date Of Pronouncement : 01.04.2024 आदेश /O R D E R Per Manjunatha, G.: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-16, Chennai, Dated 22.02.2023 Passed In Ita No. 10039/Cit(A)-16/2012-2013 Relevant To The Assessment Year 2013-14. The Revenue Has Raised Following Grounds: 1. That The Order Of The Ld. Cit(A) Is Erroneous On The Facts, The Merits Of The Case & Provisions Of Law As Well & Hence Unsustainable. 2. That The Ld. Cit(A) Erred In Failing To Appreciate That When The Assessee Had Applied For Conversion Of The Vacant Land Into A Plotted

For Appellant: Shri N.V. Balaji, AdvocateFor Respondent: Shri P. Sajit Kumar, JCIT

Section 139Section 143(1)Section 147Section 148Section 2(14)Section 45(3)

assessee has challenged reopening of assessment on the ground that the assessment has been reopened on change of opinion without there being any fresh tangible material came to the possession of the Assessing Officer after completion of original assessment order under section 143(1) of the Act. The assessee also

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)

ground that re-opening of assessment has been carried out on the basis of ‘change of opinion’ without there being any fresh tangible material which suggest escapement of income. The assessee had also challenged re-assessment on the ground that the assessment has been re-opened after a period ... opened, is illogical and devoid of merits. Further, the assessments have been re-opened for these two assessment years on the basis of fresh tangible material which suggest escapement of income on account of under assessment rental income and said escapement of income was noticed during the course of survey

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)

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)

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)