“escapement of income”

ReassessmentSection 147Section 1473,765 judgments

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

Leading authorities on escapement of income

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.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.

291 ITR 500 · 2007 · Supreme Court

1,030

citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

Raymond Woollen Mills Ltd. v. ITO

236 ITR 34 · 1999 · Supreme Court

862

citing judgments

For reassessment proceedings under Section 148, the Assessing Officer only needs prima facie material to have a reason to believe income has escaped assessment. Conclusive proof or evaluation of the sufficiency and correctness of such material is not required at the stage of issuing the notice.

CIT v. Sun Engineering Works (P) Ltd.

198 ITR 297 · 1992 · Supreme Court

814

citing judgments

A court's pronouncement derives its scope and color from the specific questions involved in the case, thus, due regard must always be given to the questions framed before the court when interpreting its judgment.

ITO v. Lakhmani Mewal Das

103 ITR 437 · 1976 · Supreme Court

721

citing judgments

For reassessment proceedings, the 'reason to believe' that income has escaped assessment must be based on some material and not mere suspicion, establishing a live link between the information and the belief. Furthermore, for reassessment beyond four years, there must be a specific finding of the assessee's failure to disclose fully and truly all material facts.

Hindustan Lever Ltd. v. R.B. Wadkar

268 ITR 332 · 2004 · High Court

695

citing judgments

The validity of reassessment proceedings initiated under Section 147, by issuing a notice under Section 148, must be judged solely on the reasons originally recorded by the Assessing Officer. These recorded reasons cannot be supplemented, improved upon, or modified at any later stage.

CIT v. Jet Airways (I) Ltd.

331 ITR 236 · 2011 · High Court

694

citing judgments

The Assessing Officer loses jurisdiction and the entire reassessment becomes invalid if no addition is made in respect of the income that formed the basis of the reopening. Explanation 3 to Section 147 does not permit assessing other escaped income unless an addition is made for the original income forming the reason to believe.

PCIT v. Meenakshi Overseas Pvt. Ltd.

395 ITR 677 · 2017 · High Court

471

citing judgments

Reassessment proceedings initiated solely based on an investigation wing/appraisal report, without the Assessing Officer's independent application of mind to form a 'reason to believe' that income has escaped assessment, are beyond jurisdiction, bad in law, and void ab initio.

Judgments citing escapement of income

Shital Dhorda, Mumbai vs. ITO-22(3)(1), Mumbai

In the result the appeal filed by the assessee stands allowed

ITA 4625/MUM/2023[2012-13]Status: DisposedITAT Mumbai14 Jan 2025AY 2012-13

Bench: Shri Sandeep Gosainvs. Ito – 22(3)(3) Shital Dhorda 408, Piramal Chambers 1002, 10Th Floor, Lalbaug, Mumbai – Vibgyor, S.V. Road, 400012. Santacruz (W), Mumbai – 400054. Pan/Gir No. Ajvpd0456H (Applicant) (Respondent) Assessee By Shri Snehal Shah Revenue By Shir Vithal Machindra Bhosale, Sr. Dr सुनवाई क" तारीख/Date Of Hearing 16.12.2024 घोषणा क" तारीख/Date Of Pronouncement 14.01.2025 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order Dated 04.07.2023, Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The Learned Commissioner Of Income Tax (Appeals) / National Faceless Appeal Centre, Delhi (‘Ld. Cit(A)’), For The Assessment Year 2012-13. The Assessee Has Raised The Following Grounds Of Appeal:

Section 131Section 132Section 143(3)Section 250

issued neither having a requisite belief nor having requisite jurisdiction as claimed. Accordingly, a bonafide 'belief towards escapement of income is clearly absent in the present case. The entire action of the Learned Assessing Officer is a complete non-starter and thus requires to be struck down

Anish Garg, Patiala vs. ITO Ward-4, Patiala

In the result, the appeal of the assessee is allowed

ITA 739/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh13 Jan 2025AY 2012-13

For Appellant: Shri Rajiv Saldi, C.AFor Respondent: Shri Vivek Vardhan, Addl.CIT

Section 133ASection 142(1)Section 143(3)Section 147Section 148Section 151Section 250(4)

that the notice U/s 148 has been issued without any impounded material much less incriminating material on record to form an opinion of escapement of income, as such the notice U/s 148 and all further proceedings are bad in law. 3. That the CIT(A) has failed to give ... issued by the AO merely on presumption without any material much less incriminating material on record to form the opinion of escapement of income and even the approval by competent authority under section 151 has been provided in a mechanical manner and therefore the notice so issued and the subsequent

Mustasq Ahmad, Chennai vs. ITO, Intl Tax Ward 1(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 1351/CHNY/2023[2013-14]Status: DisposedITAT Chennai13 Jan 2025AY 2013-14

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.1351/Chny/2023 िनधा"रण वष"/Assessment Year: 2013-2014. Mustaq Ahmad, The Income Tax Officer, No.160, Mustafa Centre, Vs. International Taxation, Usman Road, Ward 1(1) T. Nagar, Chennai. Chennai 600 017. Pan: Adepa 1181B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Lekha, C.A, ""यथ" क" ओर से/Respondent By : Mr. Nilay Baran Som, Cit. सुनवाई क" तारीख/Date Of Hearing : 30.10.2024 घोषणा क" तारीख/Date Of Pronouncement : 13.01.2025 आदेश /O R D E R Per Manu Kumar Giri () This Appeal Filed By The Assessee Is Directed Against The Order Of The Commissioner Of Income Tax (A), Chennai-16 [‘Cit(A)’ Short] Dated 27.09.2023 For Assessment Year 2013-14. 2. In This Appeal, The Assessee Has Raised Five (5) Grounds Of Appeal. However, The Counsel For The Assessee Has Vehemently Pressed A Ground No.2 That There Was No Fresh Material On Which The Ao Has Issued Notice Dated 31.03.2021 U/S 148 Of The Income Tax Act, 1961 (‘Act’ In Short). G.No.2 Is As Under: ‘’2. At The Outset, The Ao Has No Jurisdiction To Reopen The Assessment, As All The Material Facts Were With The Ao Even At The Time Of Completing The Original Assessment & There Was No Fresh Material On Which The Ao Has Issued Notice. The Notice Issued By The Ao U/S.148 Of The Act Is Ab Initio Void & On This Ground Alone The Reassessment Deserves To Be Cancelled’’.

For Appellant: Ms. Lekha, C.AFor Respondent: Mr. Nilay Baran Som, CIT

Section 143(3)Section 147Section 148Section 2(22)(e)

after 01-04-1989, Assessing Officer has power to reopen, provided, there is "tangible material" to come to the conclusion that there is escapement of income from assessment. Reasons must have a link with the formation of the belief. Our view gets support from the changes made to section

Vijay Maneklal Bhansali, Mumbai vs. Income Tax Officer-19(3)(5), Mumbai

In the result, the appeal is partly allowed

ITA 1773/MUM/2024[2010-2011]Status: DisposedITAT Mumbai13 Jan 2025AY 2010-2011

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri K. Shivram / Shri Shashi Bekal,ARsFor Respondent: Ms. Nidhi Agarwal (Sr. DR)

Section 143(3)Section 151Section 153CSection 68

facie there was live link between material coming to the notice of Assessing Officer and formation of his belief that there have been escapement of income due to assessee’s failure to disclose fully and truly all materials facts, initiation of reassessment was justified. Recently

Gourishankar Education Society, Satara vs. CIT Exemption, Pune

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

ITA 1235/PUN/2024[2014-15]Status: DisposedITAT Pune10 Jan 2025AY 2014-15

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.1234 & 1235/Pun/2024 िनधा"रण वष" / Assessment Years : 2013-14 & 2014-15 Gourishankar Education Vs. Cit, Exemption, Pune. Society, Panchganga Apartment, Opp. Axis Bank, Radhika Road, Satara- 415001. Pan : Aaatg6668A Appellant Respondent Assessee By : Shri Kishor B. Phadke Revenue By : Shri Amol Khairnar Date Of Hearing : 21.11.2024 Date Of Pronouncement 10.01.2025 : आदेश / Order Per Vinay Bhamore, Jm: These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 30.03.2024 Passed By Ld. Cit, Exemption, Pune U/S 263 Of The It Act For The Assessment Years 2013-14 & 2014-15 Respectively. 2. Since Identical Facts & Common Issues Are Involved In Both The Above Captioned Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 3. First, We Shall Take Up The Appeal Of The Assessee In Ita No.1234/Pun/2024 For A.Y. 2013-14 For Adjudication.

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amol Khairnar

Section 12ASection 13(2)(a)Section 133ASection 147Section 148Section 263

enhanced to such other areas / issues, which required detailed probing / verification. Appellant contends that, only such other issue of escapement of income, which comes to "notice" of the learned ITO can be considered in the 147 proceedings. Appellant thus contends that, directions issued by learned CIT(E) for verification

Gourishankar Education Society, Satara vs. CIT Exemption, Pune

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

ITA 1234/PUN/2024[2013-14]Status: DisposedITAT Pune10 Jan 2025AY 2013-14

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amol Khairnar

Section 12ASection 13(2)(a)Section 133ASection 147Section 148Section 263

Minal Shroff, Rs Puram Tamilnadu vs. ITO, Non Corp Ward -2(3), Coimbatore

ITA 2424/CHNY/2024[2014-15]Status: DisposedITAT Chennai10 Jan 2025AY 2014-15

For Appellant: Mr.S.K.Tulsiyan, AdvocateFor Respondent: Ms.T.M.Suganthamala

Section 143(2)Section 143(3)Section 147Section 148Section 2(40)

gain from penny stocks and the same has been claimed as exempt income. 6. Basis of forming reason to believe and details of escapement of Income: On basis of the above facts as established in Paragraph-5, I have reason to believe that income chargeable to tax has escaped assessment ... meaning of section 147 and such income is likely to amount to Rupees One lakh or more for the AY 2014-15. 7. Escape of income chargeable to tax in relation to any assets (Including financial interest in any entity) located outside India: Not Applicable. 8. Applicability of the provisions

Kyocera Document Solutions India Pvt. Ltd., Gurgaon vs. DCIT, Circle-14(2), New Delhi

In the result, the appeal filed by the assessee for AY 2012-13 is allowed

ITA 7104/DEL/2018[2012-13]Status: DisposedITAT Delhi10 Jan 2025AY 2012-13

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar Us

For Appellant: Shri S.K. Aggarwal, CAFor Respondent: Shri Om Parkash, Sr. DR

Section 143(2)Section 250(6)Section 40A(7)Section 43Section 92C

same exercise is repeated by the Appellant for any balance amount in the provision account. Therefore, the Appellant submits that there is no escapement of income from assessment and the entire exercise is revenue neutral The accounting passed on the reversal of such provision was: Provision for expense

Pehal, Chhatarpur vs. ITO (Exemption), Gwalior

In the result, appeal of the assessee is allowed for statistical purposes

ITA 46/AGR/2024[2010-11]Status: DisposedITAT Agra09 Jan 2025AY 2010-11

Bench: SHRI RAMIT KOCHAR (Accountant Member)

For Appellant: Sh. Sanjay Parekh, CAFor Respondent: Sh. Shailendra Srivastava, Sr. DR

Section 11Section 11(1)(a)Section 12ASection 12A(2)Section 143(3)Section 144Section 147Section 148Section 250

comes to Rs. 225,280/- (including interest u/s 234B @ 25%) Hence, considering the above, I have reasons to believe that there is an escapement of income during the A.Y. 2010-11 and the case is reopened u/s 147 of the IT Act 1961 and notice

Assistant Commissioner of Income Tax Circle- 3(4) Mumbai, Mumbai vs. The Shipping Corporation of India Limited, Mumbai

In the result, appeal of the assesse is allowed and that of the

ITA 1970/MUM/2024[2016-2017]Status: DisposedITAT Mumbai09 Jan 2025AY 2016-2017

Bench: Sunil Kumar Singh, Hon'Ble

For Appellant: Shri Nitesh Joshi & Neha Vikam, A/RsFor Respondent: Shri Dr. Kishor Dhule, CIT D/R

Section 115JSection 139(1)Section 143(3)Section 148

Hence, after 1.4.1989, the AO has power to re-open, provided there is "tangible material" to come to the conclusion that there is escapement of income from assessment. Reasons must have a live link with the formation of the belief. This is supported by Circular No.549 dated 31.10.1989 which clarified ... assessee to disclose fully and truly all material facts necessary for assessment and even on merits there is no case of escapement of income. We shall be pleased to clarify any pertinent aspects. Thanking you, Yours faithfully For The Shipping Corporation of India Ltd. कृते भारतीय नौवहन निगम लिमिटेड

The Shipping Corporation of India, Mumbai vs. DCIT-3(4), Mumbai

In the result, appeal of the assesse is allowed and that of the

ITA 1752/MUM/2024[2016-17]Status: DisposedITAT Mumbai09 Jan 2025AY 2016-17

Bench: Sunil Kumar Singh, Hon'Ble

For Appellant: Shri Nitesh Joshi & Neha Vikam, A/RsFor Respondent: Shri Dr. Kishor Dhule, CIT D/R

Section 115JSection 139(1)Section 143(3)Section 148

Yogesh Chandulal Sheth, Ahmedabad vs. The ACIT, Circle-3(1)(1), Ahmedabad

ITA 1879/AHD/2024[2013-14]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 1868, 1869 & 1879/Ahd/2024 ("नधा"रण वष" / Assessment Years : 2012-13 & 2013-14) बनाम/ Yogesh Chandulal Sheth Dcit B/46, Jivraj Park Society, Circle - 3(3), Ahmedabad Vs. Jivraj Park, Ahmedabad, Gujarat - 380014 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Amdps7781H (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Samit L. Jain, A.R. ""यथ" क" ओर से/Respondent By : Shri B. P. Srivastava, Sr. Dr Date Of Hearing 02/01/2025 08/01/2025 Date Of Pronouncement

For Appellant: Shri Samit L. Jain, A.RFor Respondent: Shri B. P. Srivastava, Sr. DR

Section 133(6)Section 142Section 144Section 147Section 148Section 271(1)(c)

Income Tax Act, 1961 (in short ‘the Act’), which was not responded by the assessee. Thereafter, the AO recorded his reason for escapement of income u/s.147 of the Act and issued notice u/s.148 of the Act on 26.03.2019. However, neither the assessee filed any return of income in response ... assessment ex-parte u/s.144 r.w.s. 147 of the Act on 16.10.2019 at total income of Rs.14,20,000/-. The penalty proceeding for escapement of income was also initiated by the AO and subsequently the AO passed penalty order u/s.271(1)(c) of the Act on 16.03.2022 imposing penalty of Rs.7

Yogesh Chandulal Sheth, Ahmedabad vs. ACIT, Circle 3(1)(1), Ahmedabad

ITA 1869/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2012-13

For Appellant: Shri Samit L. Jain, A.RFor Respondent: Shri B. P. Srivastava, Sr. DR

Section 133(6)Section 142Section 144Section 147Section 148Section 271(1)(c)

Yogesh Chandulal Sheth, Ahmedabad vs. DCIT Circle-3(3), Ahmedabad

ITA 1868/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2012-13

For Appellant: Shri Samit L. Jain, A.RFor Respondent: Shri B. P. Srivastava, Sr. DR

Section 133(6)Section 142Section 144Section 147Section 148Section 271(1)(c)

Income-Tax Officer, Ward-4(1)(1), Ahmedabad vs. Solace Capital Services Private Limited, Ahmedbad

The appeal of the Revenue is dismissed and the Cross Objection filed by the Assessee is also dismissed as infructuous

ITA 1438/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad08 Jan 2025AY 2011-12

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokar

For Appellant: Shri M. S. Chhajed, ARFor Respondent: Shri Rignesh Das, Sr.DR

Section 131Section 143(1)Section 143(3)Section 147Section 148Section 151Section 68

filed on 28/03/2012, declaring an income of Rs.8,450/-. The return was processed u/s 143(1) of the Act. Later on, an escapement of income was noticed, and the AO reopened the case under Section 147 of the Act. A notice under Section 148 of the Act was issued

Nishank Sakariya, Chennai vs. ACIT, CC-4(1), Chennai

In the result, appeal filed by the assessee is allowed

ITA 2343/CHNY/2024[2013-14]Status: DisposedITAT Chennai08 Jan 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.P.M.Kathir, AdvocateFor Respondent: Mr.Vinod D. Mudaliar, JCIT

Section 143(3)Section 148Section 14ASection 2(47)(v)

LTCG arising from it ought to have been offered in AY 2013-14 and therefore, there has been escapement of income; and therefore, he re-opened the assessment. [There was another issue also for which re-opening was resorted to i.e. Client Code Modification (CCM) which has been dropped/no adverse ... LTCG on sale of land should have been admitted during A.Y. 2013-14. Basis of forming reason to believe and details of escapement of income: In this case return of income was filed for the year under consideration and regular assessment u/s. 143(3) was made on 24.02.2016. Mr. Nishank

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

In the result, the appeals of the assesse and Revenue are dealt

ITA 93/CHNY/2018[2014-15]Status: DisposedITAT Chennai08 Jan 2025AY 2014-15

Bench: Shri Aby T Varkey & Shri Amitabh Shuklastaal 3H Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 Frefzor Af /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15

For Appellant: Shri Vikaram Vijayaraghavan, AdvocateFor Respondent: Shri A.Sanjay for Ms V.Pushpa

Section 143(3)Section 148

impugned reasons were very much before him during original assessment proceedings. Thus, no case of any valid escapement of income falling within the tenets of section 147 rws 148 is made out against the assesse. As the reasons u/s 147 / 148 themselves are not supported by valid legal authority, consequent

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

In the result, the appeals of the assesse and Revenue are dealt as under:-

ITA 92/CHNY/2018[2013-14]Status: DisposedITAT Chennai08 Jan 2025AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

For Respondent: Shri A.Sanjay for Ms V.Pushpa

Section 143(3)Section 148

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

ITA 90/CHNY/2018[2011-12]Status: DisposedITAT Chennai08 Jan 2025AY 2011-12

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ष /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Insurance Company Limited, Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] Dy. Commissioner Of Income Tax, Large Tax Payer Unit, Chennai. आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ष /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, Large Tax Payer Unit, Chennai. M/S.Royal Sundaram General Insurance Company Limited, (अपीलार्थी/Appellant) Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से / Assessee By Shri Vikaram Vijayaraghavan, Advocate प्रत्यर्थी की ओर से /Revenue By Shri A.Sanjay For Ms V.Pushpa, सुनवाई की तारीख/Date Of Hearing Sr.Standing Counsel For It Dept. घोषणा की तारीख /Date Of Pronouncement 15.10.2024 08.01.2025 Per Bench: आदेश / Order The Following Appeals Have Been Raised By The Appellant Assessee & Appellant Revenue Contesting Assessment / Appellate Orders For Ays 2008-09 To Ay 2014-15. As The Grounds Of Appeal In Respective Appeals Of Assessee & Revenue Are Largely Common, All The Appeals Are Adjudicated Through This Common Orders. S. No. Appeal Nos. Ays Appellate Cit(A) Order Details Revenue A B C D E F 1

Section 143(3)Section 148

Royal Sundaram General Insurance Company Ltd, Chennai vs. DCIT, Ltu, Chennai

ITA 87/CHNY/2018[2009-10]Status: DisposedITAT Chennai08 Jan 2025AY 2009-10

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ष /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Insurance Company Limited, Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] Dy. Commissioner Of Income Tax, Large Tax Payer Unit, Chennai. आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ष /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से / Assessee By : Shri Vikaram Vijayaraghavan, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, सुनवाई की तारीख/Date Of Hearing : Sr.Standing Counsel For It Dept. 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025 आदेश / Order Per Bench: The Following Appeals Have Been Raised By The Appellant Assessee & Appellant Revenue Contesting Assessment / Appellate Orders For Ays 2008-09 To Ay 2014-15. As The Grounds Of Appeal In Respective Appeals Of Assessee & Revenue Are Largely Common, All The Appeals Are Adjudicated Through This Common Orders. S. No. Appeal Nos. Ays Appellate Cit(A) Order Details Revenue A B C D E F 1 2 3

For Appellant: Shri Vikaram Vijayaraghavan, AdvocateFor Respondent: Shri A.Sanjay for Ms V.Pushpa

Section 148