JESUDASON BIJI ,CHENNAI vs. OFFICE OF INCOME TAX OFFICER INT. TAXN WARD1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

condonation of delay in filing the original return u/s.119(2)(b) of the Act and during the process of examining, the correctness of the claim to facilitate the report by the AO, it came to light that while the claim of deduction u/s.54EC was found to be in order, the claim of deduction u/s.54F to the tune of ITA No.567

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

delay in filing the appeal before the CIT(A) warrants condonation. 2. Whether the reassessment proceedings initiated under section 147 r.w.s 144 are valid, considering the date of issuance of the notice u/s 148 and compliance with section 148A

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

condoned the delay, we further note that the ground of appeal relating to validity of the notice u/s.148 of the Act dated 31.03.2021 digitally signed and issued by the JAO on 01.04.2021 urged before us is predominantly legal in nature and go to the very root of the assessment proceedings. It is a settled proposition of law that where

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

delay in filing the appeal before the CIT(A) was to be condoned, and whether the reassessment proceedings initiated under Section 147 r.w.s 148 of the Act were valid, given that the notice was issued after the commencement of Section 148A

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

In the result the appeal of the assessee is allowed

Delay condoned\nHaving regard to the concession made by the petitioner-Department in the\ncase of Union of India vs. Rajeev Bansal, Civil Appeal No.8629 of 2024 on\n03.10.2024 (2024 SCC ONLINE 754), this Special Leave Petition would not\nsurvive for further consideration. Hence, the Special Leave Petition is\ndismissed. Pending application(s), if any, shall stand disposed

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

In the result, the assessee succeeds on the legal ground

condoned the delay, we further note that the ground of appeal\nrelating to validity of the notice u/s.148 of the Act issued by the JAO on\n31.03.2022 urged before us is predominantly legal in nature and go to the very\nroot of the assessment proceedings. It is a settled proposition of law that where\na ground involves a pure question

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

SUDARSANAM BHASKARAN,CHENNAI vs. ITO, NCW-10(3), CHENNAI

The appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3657/Chny/2025 िनधा$रण वष$ /Assessment Year: 2018-19

condone the delay of in filing the appeal and admit the appeal for adjudication. 4. The Ld. AR at the outset submitted that the notice under section 148 of the Act which is dated 21.04.2022 is beyond the period of 03 years and therefore as per the provisions of Section 151 of the Act the AO should have obtained

SELVARAJ AROKIA SAGAYA RAJ,CHENNAI vs. DCIT, NCC-22(1), CHENNAI

In the result, the appeal of the assessee is allowed, and the stay application is dismissed as infructuous

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3597/Chny/2025 & S.A No.118/Chny/2025 िनधा%रण वष% /Assessment Year: 2018-19 Selvaraj Arokia Sagaya Raj, The Dy. Commissioner Of Income 6/9 Ff1, Soundariya Apartments, Vs. Tax, Voc 2Nd Main Road, Non Corporate Circle-22(1), Kodambakkam, Tambaram, Chennai. Chennai – 600 024. Pan: Aeypa 8464Q

condoning the delay in filing the appeal before him. The assessee is in appeal before the Tribunal against the order of CIT(A). 3. The Ld. A.R submitted that out of the various grounds raised by the assessee if ground No.5 which reads as under is adjudicated in favour of the assessee, the rest of the grounds would become academic

GANESH CHAND SURESH KUMAR,CHENNAI vs. ITO, NCW-3(3), CHENNAI

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

delay was reasonable and condoned it. The Tribunal further found that the notice under Section 148A of the Act was issued

MAVILAI PRIMARY AGRICULTURAL COOPERATIVE CREDIT SOCIETY LTD KV 92,KANYAKUMARI vs. INCOME TAX OFFICER - WARD 1, NAGERCOIL

In the result, appeal filed by the assessee is allowed

condone the delay in filing\nthe appeal and now proceed to hear the case on merits.\n3. At the outset, the Ld. AR for the assessee has raised an additional ground\nrelating to jurisdiction of Jurisdictional Assessing Officer (‘JAO') in the light of\nthe CBDT Notification dated 29.03.2022 and the decision of the Hon'ble Madras\nHigh Court

PERIYA VALAVADI PACCS,VALAVADI vs. ITO, WARD-2(4), TIRUPUR

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

Bench: Shri George George Kand Shri Jagadishआयकर अपील सं./Ita No.: 1733/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Periya Valavadi Primary The Income Tax Officer, Agricultural Co-Operative Vs. Ward 2(4), Credit Society, Tirupur K 2579, Periya Valavadi Paccs, Valavadi, Valavadi S.O., Tiruppur – 642 132. Pan: Aabap 9223E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Smt. S. Mathangi, Advocate (Through Virtual Mode) ""यथ" क" ओर से/Respondent By : Shri Ar.V. Sreenivasan, Cit & Smt. Anitha, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 25.08.2025 घोषणा क" तारीख/Date Of Pronouncement : 26.08.2025

condone the delay in filing the appeal and proceed to dispose off the appeal on merits. 4. Brief facts of the case are as follows: The assessee is Co- operative society registered under The Tamilnadu Cooperative Societies Act, 1983. Initially, the assessee society has not filed its return of income for assessment year 2018-19. During the year under consideration

PARTHASARATHI PRABAKARAN,VELLORE vs. ITO, WARD-3,, VELLORE

Appeal of the assessee is allowed

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.3111/Chny/2025 िनधा"रण वष" /Assessment Year: 2018-19

condone the delay in filing the appeal and admit the appeal for adjudication. Parthasarathi Prabakaran :- 3 -: 5. The assessee filed an additional ground before us raised the legal contention that the approval obtained for initiating proceedings u/s. 147 of the Act has not been obtained from the correct authority as per the provisions of Section

ASIA COKE PVT. LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.1403/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 Asia Coke Private Limited, Vs. The Deputy Commissioner Of Bascon Futura Sv, 4Th Floor, Income Tax, Venkatanarayana Road, T. Nagar, Corporate Circle 1(1), Chennai 600 017. Chennai. [Pan: Aakca4655Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. S. Sanchita, Advocate ""थ" की ओर से/Respondent By : Ms. E Pavuna Sundari, Cit सुनवाई की तारीख/ Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.01.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 45 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, In 2

condone the delay and admit the appeal for adjudication. 3. Ground No. 3 is raised challenging the action of the ld. CIT(A) in failing to appreciate the notice under section 148 of the Income Tax Act, 1961 [“Act” in short], was issued by the JAO instead of FAO. 4. We note that the Assessing Officer reopened the assessment

S 1284 THATHAIYANGARPATTY PACCS LTD.,NAMAKKAL vs. ITO, WARD-2,, NAMAKKAL

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.3171 & 3172/Chny/2025 िनधा"रण वष" /Assessment Years: 2017-18 & 2018-19 S 1284 Thathaiyangarpatty Primary The Income Tax Officer, Agricultural Co-Operative Credit Vs. Ward-2, Society Ltd., Namakkal. Karaikuruchipudur P.O., Namakkal – 637 018. Pan: Aagas 9153H

condone the delay in filing the appeal and admit the appeal for adjudication. 4. We have heard the parties, and perused the material available on record. On perusal of the order of the CIT(A), we notice that the CIT(A) has confirmed the addition made by the A.O u/s. 69A of the Act by stating that the assessee

S 1284, THATHAIYANGARPATTY PACCS LTD.,NAMAKKAL vs. ITO, WARD-2,, NAMAKKAL

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.3171 & 3172/Chny/2025 िनधा"रण वष" /Assessment Years: 2017-18 & 2018-19 S 1284 Thathaiyangarpatty Primary The Income Tax Officer, Agricultural Co-Operative Credit Vs. Ward-2, Society Ltd., Namakkal. Karaikuruchipudur P.O., Namakkal – 637 018. Pan: Aagas 9153H

condone the delay in filing the appeal and admit the appeal for adjudication. 4. We have heard the parties, and perused the material available on record. On perusal of the order of the CIT(A), we notice that the CIT(A) has confirmed the addition made by the A.O u/s. 69A of the Act by stating that the assessee

RAMANAIKKAN PA COOP BANK LTD. S-202,NAMAKKAL vs. ITO, WARD-2,, NAMAKKAL

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

condone the delay and admit the appeal for\nadjudication.\n3. When the appeal was taken up for hearing, the Id. AR Shri A.\nTamilamudhan, CA drew our attention to ground No. 3 raised in the\ngrounds of appeal and submits that the assessee challenged assumption\nof jurisdiction under section 147 of the Income Tax Act, 1961 [“Act" in\nshort

C-2016 ITCHIPUTHUR PACCS,VELLORE vs. ITO, WARD-1,, VELLORE

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

Bench: Shri S.S. Viswanethra Ravi & Ms. S. Padmavathyआयकर अपील सं./I.T.A. No.2191/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 C-2016 Itchiputhur Primary Agricultural Vs. The Income Tax Officer, Coop. Credit Society, 12Th Road, Ward 1, Itchiputhur Village, Arakkonam Tk, Vellore. Vellore 631 003. [Pan: Aabac1870C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri J. Saravanan, Advocate ""थ" की ओर से/Respondent By : Ms. Babitha, Jcit सुनवाई की तारीख/ Date Of Hearing : 11.12.2025 घोषणा की तारीख /Date Of Pronouncement : 17.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.05.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2019-20. 2. We Find That This Appeal Is Filed With A Delay Of 5 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, In 2

condone the delay and admitted the appeal for adjudication. 3. When the appeal was taken up for hearing, the ld. AR Shri J.Saravanan, Advocate drew our attention to the application dated 08.12.2025, which was filed with ITAT Registry on 09.12.2025 and submits that the assessee raised additional ground of appeal challenging assumption of jurisdiction under section 147 of the Income