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

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

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 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- V. The Dcit, Industries Pvt Ltd Central Circle-2(2), Chennai. Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

Section 153C. The power to undertake such an assessment would stand confined to those years to which the material may relate or is likely to influence. Absent any material that may either cast a doubt on the estimation of total income for a particular year or years, the AO would not be justified :: 41 :: ITA Nos.1254, 1255, 1258, 1260/Chny/2025

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

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

153D of the Act is the provision regarding approvals if necessary for assessment in case of search or requisition. 23. Section 153A of the Act is a special provision for assessment of the ‘searched person’ and Section 153C of the Act is a special provision for assessment of income of 'any other person' which is a third party

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

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

153D of the Act is the provision regarding approvals if necessary for assessment in case of search or requisition. 23. Section 153A of the Act is a special provision for assessment of the ‘searched person’ and Section 153C of the Act is a special provision for assessment of income of 'any other person' which is a third party

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

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

153D of the Act is the provision regarding approvals if necessary for assessment in case of search or requisition. 23. Section 153A of the Act is a special provision for assessment of the ‘searched person’ and Section 153C of the Act is a special provision for assessment of income of 'any other person' which is a third party

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

153D of the Act is the provision regarding approvals if necessary for assessment in case of search or requisition. 23. Section 153A of the Act is a special provision for assessment of the 'searched person' and Section 153C of the Act is a special provision for assessment of income of 'any other person' which is a third party

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

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

153D of the Act is the provision regarding approvals if necessary for assessment in case of search or requisition. 23. Section 153A of the Act is a special provision for assessment of the ‘searched person’ and Section 153C of the Act is a special provision for assessment of income of 'any other person' which is a third party

MASILAMANI NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, appeals filed by the assessee(s) are allowed

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

153D of the Act is the provision regarding approvals if necessary for assessment in case of search or requisition. 23. Section 153A of the Act is a special provision for assessment of the ‘searched person’ and Section 153C of the Act is a special provision for assessment of income of 'any other person' which is a third party

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

153D of the Act is the provision regarding\napprovals, for assessment in case of search or requisition as per\nsection153A and 153C of the Act.And as noted, section 153A of the Act is\na special provision for assessment of the ‘searched person’. From a\nreading of Section 153A of the Act, it is noted that in case of ‘searched\nperson

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

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

153D of the Act is the provision regarding approvals, for assessment in case of search or requisition as per section153A and 153C of the Act.And as noted, section 153A of the Act is a special provision for assessment of the ‘searched person’. From a reading of Section 153A of the Act, it is noted that in case of ‘searched person

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

153D of the Act is the provision regarding\napprovals, for assessment in case of search or requisition as per\nsection153A and 153C of the Act.And as noted, section 153A of the Act is\na special provision for assessment of the ‘searched person’. From a\nreading of Section 153A of the Act, it is noted that in case of ‘searched\nperson

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

153D of the Act is the provision regarding\napprovals, for assessment in case of search or requisition as per\nsection153A and 153C of the Act.And as noted, section 153A of the Act is\na special provision for assessment of the ‘searched person’. From a\nreading of Section 153A of the Act, it is noted that in case of ‘searched\nperson

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

153D of the Act is the provision regarding\napprovals, for assessment in case of search or requisition as per\nsection153A and 153C of the Act.And as noted, section 153A of the Act is\na special provision for assessment of the ‘searched person’. From a\nreading of Section 153A of the Act, it is noted that in case of ‘searched\nperson

DCIT, CENTRAL CIRCLE-2.4, CHENNAI vs. SHRI P. RAMA MOHAN RAO, CHENNAI

Accordingly, cross- objections for AYs 2015-16 and 2016-17 stands dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jmand Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.223/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.224/Chny/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.225/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Dcit Shri P. Rama Mohan Rao बनाम Central Circle-2(4) No.17/184, Y Block, First Street, 6Th Main Road, Anna Nagar, Chennai. / Vs. Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpr-2074-N (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. Cross Objection No.10/Chny/2023 (In Ita No.223/Chny/2023) (िनधा"रण वष" / Assessment Year: 2015-16) & 5. Cross Objection No.11/Chny/2023 (In Ita No.224/Chny/2023) (िनधा"रण वष" / Assessment Year: 2016-17) & 6. Cross Objection No.12/Chny/2023 (In Ita No.225/Chny/2023) (िनधा"रण वष" / Assessment Year: 2017-18 बनाम/ Dcit Shri P. Rama Mohan Rao No.17/184, Y Block, First Street, Central Circle-1(4)

Section (2) by the Act 2 of 2006 w.e.f. 16.04.2006, it is well open to the petitioner to work out his right in accordance with law on receipt of the evidence directed to be given. 6. In the result, this writ petition shall stand dismissed. No costs. Consequently, connected Miscellaneous Petition is closed. The Hon’ble Court thus held that

DCIT, CENTRAL CIRCLE-2.4, CHENNAI vs. SHRI P. RAMA MOHAN RAO, CHENNAI

Accordingly, cross- objections for AYs 2015-16 and 2016-17 stands dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jmand Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.223/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.224/Chny/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.225/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Dcit Shri P. Rama Mohan Rao बनाम Central Circle-2(4) No.17/184, Y Block, First Street, 6Th Main Road, Anna Nagar, Chennai. / Vs. Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpr-2074-N (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. Cross Objection No.10/Chny/2023 (In Ita No.223/Chny/2023) (िनधा"रण वष" / Assessment Year: 2015-16) & 5. Cross Objection No.11/Chny/2023 (In Ita No.224/Chny/2023) (िनधा"रण वष" / Assessment Year: 2016-17) & 6. Cross Objection No.12/Chny/2023 (In Ita No.225/Chny/2023) (िनधा"रण वष" / Assessment Year: 2017-18 बनाम/ Dcit Shri P. Rama Mohan Rao No.17/184, Y Block, First Street, Central Circle-1(4)

Section (2) by the Act 2 of 2006 w.e.f. 16.04.2006, it is well open to the petitioner to work out his right in accordance with law on receipt of the evidence directed to be given. 6. In the result, this writ petition shall stand dismissed. No costs. Consequently, connected Miscellaneous Petition is closed. The Hon’ble Court thus held that

DCIT, CENTRAL CIRCLE-2.4, CHENNAI vs. SHRI P. RAMA MOHAN RAO, CHENNAI

Accordingly, cross- objections for AYs 2015-16 and 2016-17 stands dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jmand Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.223/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.224/Chny/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.225/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Dcit Shri P. Rama Mohan Rao बनाम Central Circle-2(4) No.17/184, Y Block, First Street, 6Th Main Road, Anna Nagar, Chennai. / Vs. Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpr-2074-N (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. Cross Objection No.10/Chny/2023 (In Ita No.223/Chny/2023) (िनधा"रण वष" / Assessment Year: 2015-16) & 5. Cross Objection No.11/Chny/2023 (In Ita No.224/Chny/2023) (िनधा"रण वष" / Assessment Year: 2016-17) & 6. Cross Objection No.12/Chny/2023 (In Ita No.225/Chny/2023) (िनधा"रण वष" / Assessment Year: 2017-18 बनाम/ Dcit Shri P. Rama Mohan Rao No.17/184, Y Block, First Street, Central Circle-1(4)

Section (2) by the Act 2 of 2006 w.e.f. 16.04.2006, it is well open to the petitioner to work out his right in accordance with law on receipt of the evidence directed to be given. 6. In the result, this writ petition shall stand dismissed. No costs. Consequently, connected Miscellaneous Petition is closed. The Hon’ble Court thus held that