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

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

Charitable Trust was not at all in existence. X. Hence, we find no reason to hold that the search assessment order dated 28.09.2021 u/s 153A r.w. section 144

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

Charitable Trust\nwas not at all in existence.\nX. Hence, we find no reason to hold that the search assessment order dated\n28.09.2021 u/s 153A r.w. section 144

SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST,PERAMBALUR vs. ACIT, CENTRAL COIRCLE-2, , TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

SRINIVASAN CHARITABLE AND EDUCATION TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, TRICHY, TRICHY vs. SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST, PERAMBALUR

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

SRINIVASAN CHARITABLE AND EDUCATION TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRLCE-2, , TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

SRINIVASAN CHARITABLE AND EDUCATION TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, TRICHY, TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, , TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

SRINIVASAN CHRITABLE AND EDUCATIONAL TRUST, ,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-2, TRICHY

In the result, appeals filed by the assessee and appeal filed by the

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section and submit a report of the estimate to the said officer within a period of sixty days from the date of receipt of such reference.- 34. The Investigating officer is thus, empowered to refer an issue to valuation even during the process of search. However, such report has to be put to the assessee and his full and complete

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

144 of the Income Tax Act was altogether without jurisdiction because such assessment was made for all the five years on the basis of survey conducted under section 133A of the Income Tax Act. He submitted that the power under section 153C read with section 153A cannot be exercised on the basis of any discovery made during survey under section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

144 of the Income Tax Act was altogether without jurisdiction because such assessment was made for all the five years on the basis of survey conducted under section 133A of the Income Tax Act. He submitted that the power under section 153C read with section 153A cannot be exercised on the basis of any discovery made during survey under section

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

144 r.w.s 153A of the Income Tax Act, 1961 (in short ‘the Act’) and for the A.Y. 2014-15 u/s.144 of the Act all are dated 31.03.2016. 2. The assessee is in appeal for A.Ys.2011-12 to 2013-14 whereas the revenue is in further appeal for A.Ys.2011-12 to 2014-15. The facts as well as issues

SRINIVASAN CHARITABLE AND EDUCATIONAL TRUST,PERAMBALUR vs. ACIT,CENTRAL CIRCLE-2, TRICHY

In the result, appeals filed by the assessee and appeal filed by the\nRevenue are allowed for statistical purposes

section and submit a report of\nthe estimate to the said officer within a period of sixty days from\nthe date of receipt of such reference.-\n34. The Investigating officer is thus, empowered to refer an issue to\nvaluation even during the process of search. However, such report has to\nbe put to the assessee and his full and complete