THANARAJ SUMATHI,MAYILADUTHURAI vs. ITO, WARD-1,, KUMBAKONAM

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

condone the delay and admit the appeal of the assessee for adjudication. 3. Though the assessee has raised several grounds of appeal, the preliminary issue to be decided is whether the assumption of jurisdiction for reopening the assessment by Jurisdictional Assessment Officer(JAO) as against Faceless Assessment Officer (FAO) could be considered as valid. This goes to the root

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

condone the delay and treat the reasons as ‘sufficient cause’ and admit the appeal for adjudication. 3. The assessee has raised the following grounds of appeal for AYs 2016-17 and 2017-18: Grounds of appeal for assessment year 2016-2017 ‘’1. The order of the Dispute Resolution Panel against the draft assessment order by the Id. AO is contrary

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

condone the delay and treat the reasons as ‘sufficient cause’ and admit the appeal for adjudication. 3. The assessee has raised the following grounds of appeal for AYs 2016-17 and 2017-18: Grounds of appeal for assessment year 2016-2017 ‘’1. The order of the Dispute Resolution Panel against the draft assessment order by the Id. AO is contrary

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, all the three appeals of the assessee for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

delay, was neither deliberate nor intentional but occurred due to bona fide reasons, and thus deserved to be condoned in the interest of substantial justice. 2. Without prejudice to the above, that the Ld.CIT(A) erred in not appreciating that the assessment order dated 23.03.2022 passed by the National Faceless Assessment Centre [“Assessing Officer”] u/s.147 r.w.s

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI , CHENNAI

In the result, all the three appeals of the assessee for the A

section 147 r.w.s 144 of the Income-tax Act, 1961. The assessee contended that the delay was due to bona fide reasons and should be condoned.", "held": "The Tribunal condoned the delay of 604 days, citing Supreme Court precedents that substantive justice should prevail over technicalities. It was held that the notice issued u/s. 148

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, all the three appeals of the assessee for the A

Section 147 r.w.s 144 of the Income-tax Act, 1961.", "held": "The Tribunal held that the delay of 604 days in filing the appeal before the CIT(A) was due to sufficient cause and ought to be condoned. The Tribunal further held that the notice u/s 148

NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

condone the delay and admit the appeal. 3. The assessee has raised the following grounds of appeal: - ‘’A. For that the order of the Ld. Commissioner of Income-Tax (Appeals)- 16, Chennai ["CIT(A)"] and Assessing Officer ("AO"), is erroneous, bad in law, and was passed ignoring the facts and merits of the case, disregarding the evidences and the case

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, the appeal of the assessee is allowed

Section 148 of the Act was barred by limitation as it was issued beyond the prescribed period. The assessee had sufficiently demonstrated cause for condonation of delay

CLAN LABORATORIES PVT. LTD.,CHENNAI vs. DCIT, CORPORATE WARD-1(2), CHENNAI

In the result the appeal of the assessee is allowed

section 148 of the new\nregime, which are in pursuance of the deemed notices, ought to be issued\nwithin the time limit surviving under the Income-tax Act read with Taxation\nand other Laws (Relaxation and Amendment of Certain Provisions) Act,\n2020. A reassessment notice issued beyond the surviving time limit will be\ntime-barred.\n14. The Hon'ble Supreme

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

condone the delay of two days in filing the appeals and admit the appeals for adjudication. Since, the identical facts and issues are involved in these 3. appeals, we proceed to dispose the same vide this common order. For the sake of convenience and clarity the facts relevant to 4. the appeal in ITA No.2280/Chny/2018 for assessment year

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

condone the delay of two days in filing the appeals and admit the appeals for adjudication. Since, the identical facts and issues are involved in these 3. appeals, we proceed to dispose the same vide this common order. For the sake of convenience and clarity the facts relevant to 4. the appeal in ITA No.2280/Chny/2018 for assessment year

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

condone the delay of two days in filing the appeals and admit the appeals for adjudication. Since, the identical facts and issues are involved in these 3. appeals, we proceed to dispose the same vide this common order. For the sake of convenience and clarity the facts relevant to 4. the appeal in ITA No.2280/Chny/2018 for assessment year

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

condone the delay of two days in filing the appeals and admit the appeals for adjudication. Since, the identical facts and issues are involved in these 3. appeals, we proceed to dispose the same vide this common order. For the sake of convenience and clarity the facts relevant to 4. the appeal in ITA No.2280/Chny/2018 for assessment year

DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE-10, CHENNAI vs. ARUNCHALAM VEERAIAH, CHENNAI

In the result, the revenue's appeal is dismissed and allow the cross objection\nof the assessee

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Jagadish\N\Nआयकर अपील सं./ Ita No.2320/Chny/2024\N& C.O.No.78/Chny/2024\N(In Ita No.2320/Chny/2024)\N(निर्धारणवर्ष / Assessment Year: 2011-2012)\N\Nthe Deputy Commissioner Of\Nincome Tax,\Ncorporate Circle 10,\Nchennai\N(Appellant)\Nvs. Arunchalam Veeraiah,\Nno.34, 14B, Beach Home Avenue,\Nbesant Nagar,\Nchennai 600 090.\N[Pan No.Aaipa 9044Q]\N(Respondent/Cross Objector)\N\Nassessee By\N: Shri S. Sridhar, Advocate\Nrevenue By\N: Shri. P.K. Senthil Kumar, Addl. Cit.\N\Nसुनवाई की तारीख/Date Of Hearing\N: 30.01.2025\Nघोषणा की तारीख / Date Of Pronouncement : 14.02.2025\N\Nआदेश / Order\N\Nmanu Kumar Giri ()\N\Nthe Appeal Of The Revenue & Cross Objection By The Assessee Are Arising\Nout Of The Order Dated 21.06.2024 Of The Commissioner Of Income Tax (Appeals),\Nnfac, Delhi (In Short The `Ld. Cit(A)"). The Assessment Order U/S 144 R.W.S 147 Of\Nthe Income Tax Act, 1961 (Hereinafter The 'Act'), Was Passed Vide Order Dated\N19.12.2019.\N\N2.\Nthe Registry Has Noted Delay Of 14 Days In Filing The Appeal By The Revenue.\Nconsidering Reasons Stated In The Affidavit By The Revenue, We Condone The Delay\Nand Admit The Appeal For Adjudication.\N\N3.\Ngrounds Of Appeal Filed By The Revenue Are As Under:\N\N\"1. The Order Of The Cit (A) Is Contrary To The Facts & Circumstances Of The Case\Nand Provisions Of Income Tax Act 1961.\N2. The Id. Cit (A) Erred To Hold That The Notice U/S 148 Was Sent For The Service\Nafter 10 Months Delay & Holding The Assessment Order Dated 19.12.2019 As Time\Nbarred.\N2.

condone the delay\nand admit the appeal for adjudication.\n\n3.\nGrounds of appeal filed by the revenue are as under:\n\n\"1. The order of the CIT (A) is contrary to the facts and circumstances of the case\nand provisions of Income Tax Act 1961.\n2. The Id. CIT (A) erred to hold that the notice u/s 148

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

148 days in filing the cross objection. Considering the reasons stated in the affidavit by the Assessee, we condone the delay and treat the reasons as ‘sufficient cause’ and admit the cross objection for adjudication. 3. The revenue has raised the following grounds of appeal: 1. The order of the learned Commissioner of Income Tax (Appeals) is erroneous on facts

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.

condonation of delay II Reassessment proceedings under Section 148 of the Act 4 31-Mar 23 Notice under section 148

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, the assessee succeeds on the legal ground

Section 148 of the Act were\nnot issued in a faceless manner, the entire further proceeding founded upon\nit and assessment orders stand vitiated. Thus, the impugned notices under\nSection 148 of the Act and all consequential assessment orders based\nthereupon are set aside. Liberty is reserved to the respondents to proceed\nagainst the petitioners in accordance with

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

condonation\nunder section 119(2)(b) of the Act before the Id. CIT(E). The Id. CIT(E)\ncondoned the said delay in filing Form 10A vide his order dated\n30.11.2016 and referred to page 82 of the paper book. He vehemently\nargued that the Assessing Officer, considering all the details, accepted\nthe returned income and formed an opinion that

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

condoned the said delay in filing Form 10A vide his order dated 30.11.2016 and referred to page 82 of the paper book. He vehemently argued that the Assessing Officer, considering all the details, accepted the returned income and formed an opinion that the assessee was eligible for claiming exemption under section 11 of the Act during scrutiny assessment. He further