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

condone the delay of 5 days in filing\nthese appeals and proceed to dispose off the same on merits.\n3.\nCommon issues are raised in these appeals, hence they\nwere heard together and are being disposed off by this\nconsolidated order. We shall first adjudicate the appeal preferred\nby the Revenue in ITA No.1650/Chny/2025 pertaining to the\nA.Y.2015-16, which arises

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

condone the delay of 5 days in filing\nthese appeals and proceed to dispose off the same on merits.\n3.\nCommon issues are raised in these appeals, hence they\nwere heard together and are being disposed off by this\nconsolidated order. We shall first adjudicate the appeal preferred\nby the Revenue in ITA No.1650/Chny/2025 pertaining to the\nA.Y.2015-16, which arises

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

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

condone the delay of 5 days in filing\nthese appeals and proceed to dispose off the same on merits.\n3.\nCommon issues are raised in these appeals, hence they\nwere heard together and are being disposed off by this\nconsolidated order. We shall first adjudicate the appeal preferred\nby the Revenue in ITA No.1650/Chny/2025 pertaining to the\nA.Y.2015-16, which arises

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

condone the delay of 5 days in filing\nthese appeals and proceed to dispose off the same on merits.\n3.\nCommon issues are raised in these appeals, hence they\nwere heard together and are being disposed off by this\nconsolidated order. We shall first adjudicate the appeal preferred\nby the Revenue in ITA No.1650/Chny/2025 pertaining to the\nA.Y.2015-16, which arises

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), CHENNAI vs. ASTROTECH STEELS PRIVATE LIMITED, CHENNAI

The appeal stand dismissed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1150/Chny/2023 (िनधा)रण वष) / Assessment Year: 2018-19) Dcit M/S Astrotech Steels Private Limited बनाम/ Corporate Circle-1(1) 19, Ii Floor, Right Wing, Ghatala Towers, Chennai. Avenue Road, Nungambakkam Vs. Chennai-34. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aakca-0128-L (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri P. Sajit Kumar (Jcit)- Ld. Sr. Dr " थ"कीओरसे/Respondent By : Shri T. Vasudevan (Advocate) -Ld. Ar सुनवाईकीतारीख/Date Of Final Hearing : 27-06-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-07-2024 आदेश / O R D E R

condone the delay and admit the appeal for adjudication on merits. 3. The Ld. Sr. DR, at the outset, referred to the recent judgment of Hon'ble Supreme Court in the case of Pr. CIT Vs Wipro Ltd. (2022) 140 Taxmann.com 223 (SC) as well as other decisions in Checkmate Services P. Ltd Vs. CIT (2022) 143 Taxmann.com

HARI FOUNDATION,COIMBATORE vs. DLC-CA-(211)(1), ACIT EXEMPTIONS, COIMBATORE

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.917/Chny/2024 िनधा"रणवष"/Assessment Year: 2020-21 V. Hari Foundation, The Acit (Exemptions), 3-1, Indira Nagar, Coimbatore. Kuniamuthur S.O., Coimbatore-641 035. [Pan: Aabth 2056 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

139 and sub-section (5) provides mechanism to file a belated return, therefore, even if assessee files return before last date of filing of belated return same should be treated as due compliance to Section 12A(1)(ba) - Whether in view of said order of Tribunal, assessee was entitled for exemption under section 11-Held, yes [Paras

FAURECIA EMISSIONS CONTROL TECHNOLOGIES INDIA PRIVATE LIMITED,CHENNAI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX - CORPORATE CIRCLE 1(1) CHE, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1223/Chny/2025 Assessment Years: 2023-24 Faurecia Emissions Control Assistant Commissioner Of Technologies India Pvt Ltd, Income Tax, 1St Floor, No.634, Karumuthu Center, Corporate Circle-1(1), Anna Salai, Nandanam, Chennai. Chennai-600 035 [Pan: Aaaca8450F] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.Siddhesh Chaugula, C.A. प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 04.09.2025 घोषणा की तारीख /Date Of Pronouncement : 14.11.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

Section 139 (9) of the Act Return of income. 20 139. 21 22[(1) Every person,- (a)being a company 23[or a firm]; or (b)being a person other than a company 23[or a firm], if his total income or the total income of any other person in respect of which he is assessable under this Act during

F.V. 112 THE VILLUPURAM DISTRICT PUBLIC HEALTH DEPARTMENT EMPLOYEES COOP THRIFT AND CREDIT SOCIETY,VILLUPURAM vs. INCOME TAX OFFICER, VILLUPURAM

In the result the appeal is allowed

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./ Ita No.2047/Chny/2025 िनधा8रण वष8 /Assessment Year: 2019-20 Fv 112 The Villupuram District Public The Income Tax Officer, Vs. Health Department Employees Co-Op. Ward-1, Thrift & Credit Society, 60, Vilupuram. Kandasamy Layout, 1St Street, (K.K. Road), Villupuram 605 602, Viluppuram [Pan: Aaaaf4857B]

delay request before the appropriate authority in accordance with CBDT Circular No. 13 of 2023 and the Assessing Officer shall revisit the deduction claim of the assessee on disposal of the condonation petition. 6. The ld.AR filed the coordinate orders of the Tribunal which have decided the issue in question in favour of the assessee. The details of the orders

THE ERODE CITY MUNICIPAL CORPORATION EMP CO-OP T& C LIMITED,CHENNAI vs. ITO, WARD 1 (1), ERODE

In the result, the appeal in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

9. Grounds of appeal are as under: ‘’1)The order passed by the Learned CIT(A) dated 08.01.2024 is erroneous in law and opposed to the facts and circumstances of the case. 2) The Learned Commissioner of Income Tax (Appeals) erred in disallowing the deduction claimed under Section 80P(2)(a)(i). Furnishing of Return of Income - Section 139

THE ERODE CITY MUNICIPAL CORPORATION EMP CO-OP T& C LIMITED,ERODE vs. ITO, WARD 1(1), ERODE

In the result, the appeal in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

9. Grounds of appeal are as under: ‘’1)The order passed by the Learned CIT(A) dated 08.01.2024 is erroneous in law and opposed to the facts and circumstances of the case. 2) The Learned Commissioner of Income Tax (Appeals) erred in disallowing the deduction claimed under Section 80P(2)(a)(i). Furnishing of Return of Income - Section 139

K864 MURALI CHENNAMPATTI PRIMARY AGRICULTURE CO-OP CREDIT SOCIETY,ERODE vs. INCOME TAX OFFICER, WARD 2(1), ERODE, ERODE

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.: 516 & 517/Chny/2024 िनधा"रण वष"/Assessment Years: 2018-19 & 2019-20 M/S. K864 Murali Chennampatti The Income Tax Officer, Primary Agriculture Co-Op Vs. Ward 2(1), Credit Society, Erode. Mulari Post, Anthiyur Taluk, Erode – 638 504. Pan: Aabak 3671M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. A. Vijayalakshmi, Fca ""यथ" क" ओर से/Respondent By : Shri Ar.V. Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 27.06.2024 आदेश /O R D E R Per Mahavir Singh: These Appeals By The Assessee Are Arising Out Of The Orders Of The Commissioner Of Income Tax (Appeals), Addl/Jcit(A),Prayagraj In Order No.Itba/Apl/S/250/2023-23/1058743474 (1) & 1058743723(1) Both Dated 14.12.2023. The Return Of Income For The Assessment Years 2018-19 & 2019-20 Were Processed & Intimation U/S.143(1) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Were Issued By The Asst. Director Of Income Tax, Central Ita Nos.516 &517/Chny/2024 Processing Center (Cpc), Bengaluru Vide Orders Dated 12.07.2019 & 20.09.2020 Respectively.

condoning the delay u/s.119(2)(b) of the Act, we direct the AO to allow the claim of deduction. Consequently the order of CIT(A) and the return processed by AO u/s.143(1) are quashed and the AO is directed to allow the relief. Accordingly, the appeal of the assessee is allowed. 5. Coming to ITA No.517/CHNY/2024 for assessment year

K864 MURALI CHENNAMPATTI PRIMARY AGRICULTURE CO-OP CREDIT SOCIETY,ERODE vs. INCOME TAX OFFICER, WARD 2(1), ERODE, ERODE

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.: 516 & 517/Chny/2024 िनधा"रण वष"/Assessment Years: 2018-19 & 2019-20 M/S. K864 Murali Chennampatti The Income Tax Officer, Primary Agriculture Co-Op Vs. Ward 2(1), Credit Society, Erode. Mulari Post, Anthiyur Taluk, Erode – 638 504. Pan: Aabak 3671M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. A. Vijayalakshmi, Fca ""यथ" क" ओर से/Respondent By : Shri Ar.V. Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 27.06.2024 आदेश /O R D E R Per Mahavir Singh: These Appeals By The Assessee Are Arising Out Of The Orders Of The Commissioner Of Income Tax (Appeals), Addl/Jcit(A),Prayagraj In Order No.Itba/Apl/S/250/2023-23/1058743474 (1) & 1058743723(1) Both Dated 14.12.2023. The Return Of Income For The Assessment Years 2018-19 & 2019-20 Were Processed & Intimation U/S.143(1) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Were Issued By The Asst. Director Of Income Tax, Central Ita Nos.516 &517/Chny/2024 Processing Center (Cpc), Bengaluru Vide Orders Dated 12.07.2019 & 20.09.2020 Respectively.

condoning the delay u/s.119(2)(b) of the Act, we direct the AO to allow the claim of deduction. Consequently the order of CIT(A) and the return processed by AO u/s.143(1) are quashed and the AO is directed to allow the relief. Accordingly, the appeal of the assessee is allowed. 5. Coming to ITA No.517/CHNY/2024 for assessment year

TIRUPUR ARUNACHALA GOUNDER RADHAMBIKAI KUPPUSAMY,TIRUPUR vs. CIT(A), NFAC, DELHI

In the result, appeal filed by the assessee in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.363/Chny/2024 (िनधा"रणवष" / Assessment Year: 2018-19) T A G Radhambikai Kuppusamy, Vs. The Income Tax Officer, No.5, Mp Nagar Extension, Che –C (68) (1) Suriya Prabha Garden, Chennai. Tirupur 641 607

delay initially along with Form 35, When in fact it was filed along with Form 35 and also repeatedly informed in response to all the notices citing the deficiency. [please see para 6.3 of the CIT(A) Order / pages 5 to 9] 4. The learned First Appellate Authority has erred in stating that the Assessee is a Habitual Defaulter (last

PALAM RURAL CENTRE,TIRUPPUR vs. ACIT, EXEMPTIONS,, COIMBATORE

In the result, the appeal filed by the assessee is allowed for statistical purposes and the Stay Application filed by the assessee is dismissed as infructuous

Bench: Shri George George K & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:1560/Chny/2025 & S.A.No.51Chny/2025 [Arising In Ita No.: 1560/Chny/2025] िनधा"रण वष" / Assessment Year:2018-19 Palam Rural Centre, The Asst. Commissioner Of Pethampalayam, Vs. Income Tax (Exemptions), Veerapandi S.O., Coimbatore. Tiruppur – 641 605. [Pan: Aaatp-2929-F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. Edser Raj, Advocate ""थ" की ओर से/Respondent By : Ms. Sita Krishnamoorthy, J.C.I.T.

condonation request only after Centralised Processing Centre ("CPC") sent an intimation about non-filing of Form 10B." "9. Having considered the matter in its entirety, we are satisfied that the delay was not intentional or 2024:KER:59378 WP(C) 17059/2024 and Conn.Cases deliberate. Petitioner cannot be prejudiced on account of an ignorance or error committed by professional engaged

K1578 SENJERIPUTHUR PACCS,TIRUPUR vs. ITO,WARD-2(4), TIRUPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.783/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 K1578 Senjeriputhur Primary Vs. The Income Tax Officer, Agricultural Co-Operative Credit Ward 2(4), Society, Senjeriputhur, Senjeriputhur Tirupur. Post, Palladam, Tirupur 641 671. [Pan:Aabak0914F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 25.07.2023 घोषणा की तारीख /Date Of Pronouncement : 25.07.2023 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), National Faceless Appeal Centre [Nfac], Delhi Dated 04.05.2023 Relevant To The Assessment Year 2019-20. 2. Brief Facts Of The Case Are That The Assessee Has Filed The Return Of Income For The Assessment Year 2019-20 On 30.09.2020 Admitting Nil Income After Claiming Deduction Under Section 80P Of The Income Tax Act

139(1) of the Act, the assessee filed the return of income belatedly. On perusal of the appellate order, we find that the ld. CIT(A) has noted that the assessee has filed a petition dated 05.03.2021 before the CBDT for condonation of delay under section 119 of the Act. 8. In view of the fact that the assessee

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

139(1) of the Act to furnish its return of income for the subject AY. However, the Appellant was under a bona fide belief that it did not have any obligation to furnish its return of income in India since appropriate withholding of taxes had been deducted. On being aware that the bona fide belief was incorrect

T1461 KOOTHANALLUR PACB LTD.,THIRUVARUR vs. ITO, WARD-1, THIRUVARUR

In the result, the stay application filed by the assessee is dismissed and the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.2195/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 & S.A. No. 73/Chny/2025 [In Ita No. 2195/Chny/2025] T1461 Koothanallur Pacb Ltd., Vs. The Income Tax Officer, Rep. By Its Secretary Mr. T. Ward 1, Singaravelu, No. 27, Big Nazaar Street, Thiruvarur. Koothanallur Post, Mannargudi Taluk, Thiruvarur 614 101. [Pan:Aacat6581C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. T.V. Paarkavi, Advocate For Shri J. Ashok, Advocate ""थ" की ओर से/Respondent By : Shri C. Sivakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 19.08.2025 घोषणा की तारीख /Date Of Pronouncement : 22.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2

9. Heard both the parties and perused the material available on record. The assessee is a cooperative society registered under the Tamil Nadu Co-operative Societies Act, 1983, which is part of the Tamil Nadu State Government. We note that admittedly, the assessee filed an appeal before the ld. CIT(A) with a delay of 169 days and prayed

PREETHA REDDY,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(1), CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.305/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 Preetha Reddy, Vs. The Assistant Commissioner Of 1A, Jhavar Plaza, Nungambakkam Income Tax High Road, Chennai 600 034. Central Circle 3(1), [Pan:Aaepr5656F] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 27.03.2023 घोषणा की तारीख /Date Of Pronouncement : 31.03.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax (Central), Chennai-1, Chennai Dated 30.03.2022 Relevant To The Assessment Year 2017-18. 2. The Appeal Filed By The Assessee Is Delayed By 284 Days In Filing The Appeal & The Assessee Has Filed A Petition For Condonation Of Delay In The Form Of An Affidavit By Stating As Under: “3. I State & Submit That My Case Has Been Handled By Mrs. K. Rajalakshmi Who Is A Chartered Accountant By Profession & She Has Advised Me After Perusal Of The Order Of Pcit (Central), Chennai-1. She Was Of The Opinion

condone the delay and admit the appeal for adjudication. 5. So far as merits of the case is concerned, in this case, the assessment was completed under section 143(3) of the Income Tax Act, 1961 [“Act” in short] dated 26.12.2019. Thereafter, on perusal of the assessment records for the assessment year 2017-18, the ld. PCIT has noticed that