SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 132 of the Act is conducted\nor requisition is made under Section 132A of the Act as well as the\nrelevant assessment year or years.\n13. As is apparent from the plain language of Section 153A(1) of the\nAct, the AO has the jurisdiction to issue a notice in respect of each of\nthe assessment years falling within

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 132 was conducted or a requisition under\nSection 132A of the Act was made. Plainly, the said controversy is\nrequired to be addressed by referring to Section 153A of the Act.\nSection 153A(1) of the Act is set out below:.......\n12. It is apparent from the above that Section 153A of the Act refers to\ntime periods within

SOUTHERN AGRIFURANE INDUSTRIES PVT.. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

1 to\nSection 153A(1) of the Act, the Revenue can travel back ten years from\nthe end of the assessment year relevant to the previous year in which\nthe search under Section 132 was conducted or a requisition under\nSection 132A of the Act was made. Plainly, the said controversy is\nrequired to be addressed by referring to Section

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153A of the Act.\nSection 153A(1) of the Act is set out below:.......\n12. It is apparent from the above that Section 153A of the Act refers to\ntime periods within which the assessments could be reopened. In terms\nof Section 153A(1) of the Act, the assessments can be reopened for a\nblock of six years preceding

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149(1)(b) of the Act and therefore the notice for\nreopening the assessment u/s 148 of the Act can be issued, only if such\nAY could have

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149(1)(b) of the Act and therefore the notice for\nreopening the assessment u/s 148 of the Act can be issued, only if such\nAY could have

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

1)/143(3) of the Act and/or the time limit for issue of notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

1)/143(3) of the Act and/or the time limit for issue of notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

1)/143(3) of the Act and/or the time limit for issue of notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

1)/143(3) of the Act and/or the time limit for issue of notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the notice u/s 143(2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

1)/143(3) of the Act and/or the time limit for issue of the Act and/or the time limit for issue of the Act and/or the time limit for issue of notice u/s 143(2) of the Act had expired. Accordingly, the income 143(2) of the Act had expired. Accordingly, the income-tax tax assessments

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

1)/143(3) of the Act and/or the time limit for issue of the Act and/or the time limit for issue of the Act and/or the time limit for issue of notice u/s 143(2) of the Act had expired. Accordingly, the income 143(2) of the Act had expired. Accordingly, the income-tax tax assessments

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021-22\n2022-23\n1\nAddition on a/c of old bottle purchases

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PRIVATE LIMITED, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021-22\n2022-23\n1\nAddition on a/c of old bottle purchases

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021-22\n2022-23\n1\nAddition on a/c of old bottle purchases

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSl\nNo\nParticulars\n2020-21\n2021-22\n2022-23\n1\nAddition on a/c of old bottle purchases

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PRIVATE LIMITED, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021-22\n2022-23\n1\nAddition on a/c of old bottle purchases