DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

Capital\nGain (LTCG) in his return of income filed under section 139 on\nbasis of seized papers and Assessing Officer completed\nassessment by accepting said LTCG, since income assessed was\nnot greater than income determined in return processed under\nsection 143(1)(a),there was no case of under reporting of income\nas per provisions of section 270A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

Capital\nGain (LTCG) in his return of income filed under section 139 on\nbasis of seized papers and Assessing Officer completed\nassessment by accepting said LTCG, since income assessed was\nnot greater than income determined in return processed under\nsection 143(1)(a),there was no case of under reporting of income\nas per provisions of section 270A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

Capital\nGain (LTCG) in his return of income filed under section 139 on\nbasis of seized papers and Assessing Officer completed\nassessment by accepting said LTCG, since income assessed was\nnot greater than income determined in return processed under\nsection 143(1)(a),there was no case of under reporting of income\nas per provisions of section 270A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

Capital\nGain (LTCG) in his return of income filed under section 139 on\nbasis of seized papers and Assessing Officer completed\nassessment by accepting said LTCG, since income assessed was\nnot greater than income determined in return processed under\nsection 143(1)(a),there was no case of under reporting of income\nas per provisions of section 270A

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 274(1) provides for reasonable opportunity to be given to the assessee so that he can meet the charge. Therefore, from the above, it is very clear that the satisfaction arrived at by the AO before charging the assessee on particular limb of u/s.271(1)(c) of the Act, the AO must clearly record his satisfaction and such satisfaction

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 274(1) provides for reasonable opportunity to be given to the assessee so that he can meet the charge. Therefore, from the above, it is very clear that the satisfaction arrived at by the AO before charging the assessee on particular limb of u/s.271(1)(c) of the Act, the AO must clearly record his satisfaction and such satisfaction

PENTA MEDIA GRAPHICS LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1402/Chny/2015 िनधा"रण वष"/Assessment Year: 2000-01 M/S. Penta Media Graphics Ltd., The Deputy Commissioner Of ‘Taurus’, No. 25, First Main Road, Vs. Income Tax, Media Circle I, Room No. 311, 3Rd Floor, New Block, United India Colony, Kodambakkam, Chennai 600 024. 121, Mahatma Gandhi Road, Nungambakkam, Chennai 600 034. [Pan: Aaacp1647B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Baskar, Advocate & : Smt. Sree Valli Lakshmi, Advocate ""थ" की ओर से/Respondent By None [Dept. Letter Submission] : सुनवाई की तारीख/ Date Of Hearing 12.04.2023 : घोषणा की तारीख /Date Of Pronouncement : 10.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai Dated 30.03.2015 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

capital gain on sale at Rs.67.50 crores. In view of this, I am of the opinion that the assessee has failed to disclose its true and correct income and thereby attracted the provisions of section 271(1)(c

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, appeal filed by the Revenue is dismissed and the\nCross-Objection filed by the assessee is allowed

Capital &Finlease Ltd (supra)\n“11. In fact, when the AO recommended the initiation of penalty\nproceedings the AO appeared to be conscious of the fact that he did not\nhave the power to issue notice as far as the penalty proceedings under\nSection 271-E was concerned. He, therefore, referred the matter\nconcerning penalty proceedings under Section 271

M/S. R R INDUSTRIES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, appeals filed by the assessee are allowed

Section 271(1)(c) of the Act,\nboth limbs in the said provision do not get attracted. Hence, the decision of\nthis Court in the case of Sundaram Finance Ltd., cannot be applied.\n:: 13 ::\nITA Nos.2741 to 2743/Chny/2025\n(AYs 2008-09 to 2010-11)\nM/s. RR Industries Ltd.\nAnd thereafter, the Hon'ble Madras High Court held that

M/S. R R INDUSTRIES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, appeals filed by the assessee are allowed

Section 271(1)(c) of the Act,\nboth limbs in the said provision do not get attracted. Hence, the decision of\nthis Court in the case of Sundaram Finance Ltd., cannot be applied.\n:: 13 ::\nITA Nos.2741 to 2743/Chny/2025\n(AYs 2008-09 to 2010-11)\nM/s. RR Industries Ltd.\nAnd thereafter, the Hon'ble Madras High Court held that

M/S. R R INDUSTRIES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

Section 271(1)(c) of the Act, both limbs in the said provision do not get attracted. Hence, the decision of this Court in the case of Sundaram Finance Ltd., cannot be applied. ITA Nos.2741 to 2743/Chny/2025 (AYs 2008-09 to 2010-11) M/s. RR Industries Ltd. :: 14 :: And thereafter, the Hon’ble Madras High Court held that the notice

ST.JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

capitation fees, failed to disclose them, and did not meet the conditions for a reduced penalty under Section 271AAB(1A)(a). • The 60% penalty under Section 271AAB(IA)(b) is appropriate. Invalidating the notice on a technicality would defeat the legislative intent to deter tax evasion in search cases. e. Holistic Interpretation of the Notice • The notice should be interpreted

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

capitation fees, failed to disclose them, and did not meet the conditions for a reduced penalty under Section 271AAB(1A)(a). • The 60% penalty under Section 271AAB(IA)(b) is appropriate. Invalidating the notice on a technicality would defeat the legislative intent to deter tax evasion in search cases. e. Holistic Interpretation of the Notice • The notice should be interpreted

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n- 4 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n4. Ground No. 1 is general in nature and hence, doesn

ST. JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

271(1)(c) of\nthe Act, the same principle would equally apply to Section 271AAB of the Act\n:: 38 ::\nFurther, the Ld.DR reliance on the decision of the Hon'ble Bombay High Court\nin the case of CIT Vs Kaushalya (1995) 216 ITR 660 (Bom) do not death with\nthe section 292B of the Act at all.\nFurther, this

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n4. Ground No. 1 is general in nature and hence, doesn't require\nany adjudication, therefore, we move to Ground

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n- 4 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n4. Ground No. 1 is general in nature and hence, doesn

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

271(1)(c) of the Act, without\nappreciating the contentions placed in the above grounds.\nThe Appellant craves leave to add, supplement, amend, delete or otherwise\nmodify any of the grounds stated hereinabove at the time of hearing.\n- 4 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n4. Ground No. 1 is general in nature and hence, doesn