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

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

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

153D\nof the Act is not amenable to jurisdiction under section 263 of the Act. For this\nproposition he relied on various co-ordinate bench decisions of the ITAT including\nthe latest decision of the Delhi ITAT in the case of Devender Kumar Gupta v. PCIT\n[2024] 166 taxmann.com 95 (Delhi - Trib.).\n9.\nPer contra

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

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

gains, was based simply on conjectures and mistake of\nfact(s).\n15. Overall therefore, the Ld. AR contended that, there was not even an\niota of evidence or material referred to in the entire satisfaction note,\nbasis which any prudent person could have inferred that 50% of the trade\nadvances given by the companies had been received back and utilized

M/S. P.P. ENTERPRISES,DINDIGUL vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

gained any advantage by instituting the\nappeals belatedly. Accordingly, the delay is hereby condoned. In\nrespect of the remaining assessees, there is no delay in filing the\nappeals, and proof of receipt of the orders of the ld. CIT(A) has\nbeen duly enclosed with Form No. 36.\nFurther, since all the 61 appeals arise out of the same search

P KUPPUCHAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36.\nFurther, since all the 61 appeals arise out of the same search

M/S. P.P. FINANCIERS,KARUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

P. PALANISAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

P.P. ENTERPRISES,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

M/S. P.P. ENTERPRISES,BENGALURU vs. ACIT< CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

SELLAMUTHU KABILAN,BENGALURU vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

P. PALANISAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P P ENTERPRISES, BENGALURU

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

PALANISAMY RAGHUPATHY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

L KARUPPUSAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

M/S. P.P. FINANCIERS,KARUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

gained any advantage by instituting the appeals belatedly. Accordingly, the delay is hereby condoned. In respect of the remaining assessees, there is no delay in filing the appeals, and proof of receipt of the orders of the ld. CIT(A) has been duly enclosed with Form No. 36. Further, since all the 61 appeals arise out of the same search

PALANISAMY RAGHUPATHY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, appeal filed by the assessee and department are\nallowed or dismissed as per chart below

gained any advantage by instituting the\nappeals belatedly. Accordingly, the delay is hereby condoned. In\nrespect of the remaining assessees, there is no delay in filing the\nappeals, and proof of receipt of the orders of the ld. CIT(A) has\nbeen duly enclosed with Form No. 36.\nFurther, since all the 61 appeals arise out of the same search

P.P.FINANCIERS,DINDIGUL vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

gained any advantage by instituting the\nappeals belatedly. Accordingly, the delay is hereby condoned. In\nrespect of the remaining assessees, there is no delay in filing the\nappeals, and proof of receipt of the orders of the ld. CIT(A) has\nbeen duly enclosed with Form No. 36.\nFurther, since all the 61 appeals arise out of the same search