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

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

ACIT CIRCLE 1, TRICHY vs. DALMIA BHARAT LTD., TRICHY

In the result, appeal of the revenue being devoid of merits is dismissed

Bench: S/Shri Shri Chandra Mohan Garg, Judicial & Arun Khodpia & Arun Khodpia & Arun Khodpiaassessment Year : 2014-15 Acit, Circle-1, Vs. M/S. M/S. Dalmia Dalmia Bharat Bharat Trichy Ltd.,Dalmiapuram, Tamilnadu - Ltd.,Dalmiapuram, Tamilnadu 621 651, Pan/Gir No.Aajcs 7366 K Aajcs 7366 K (Appellant) (Appellant .. ( Respondent Respondent) Assessee By : N O N E Revenue By : Dr S.Palanikumar, Cit (Dr Dr) Date Of Hearing : 24 /2/ 2022 2 Date Of Pronouncement : 31/3/20 /2022 O R D E R Per C.M.Garg, Jm , Jm

condone the delay P a g e 1 | 17 Assessment Year : 2014-15 days in filing the appeal before the Tribunal and admit the appeal for hearing. 3. The sole grievance of the revenue in this appeal is that the ld CIT(A) erred in directing the AO to compute the disallowance under Rule 8D(2)(iii) after excluding investment

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

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

M/S. BHARATHI RAJAA HOSPITAL & RESEARCH CENTRE PVT. LTD.,,CHENNAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

delay in filing each of the above appeals be condoned and they may be directed to be decided on merits and due justice be rendered to the assessee. 4. Per contra, the ld. DR supported the orders of the ld.CIT(A) and relied on the decision of the Hon’ble Bombay High Court in the case of M/s. Alfa Properties

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 1 filed before the CBDT 1.1. Form 26AS of the Appellant for AY 2018-19 5 1.2. Form 26AS of the Appellant for AY 2019-20 9 1.3. Tax Audit Report in Form 3CA and 3CD of the Appellant 13 for AY 2018-19 1.4. Tax Audit Report in Form 3CA and 3CD of the Appellant

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone

M/S. THIRUMURUGAN PLASTICS P. LTD.,,THIRUMAZHISAI vs. ACIT, CPC,, GHAZIABAD

In the result, all the above appeals of the assessee are partly allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 282 of the Act. In this case, the Revenue has not brought to our notice any such communication with the assessee. Considering the totality of the facts and circumstances, the reasons canvassed by the assessee towards the delay in filing the impugned appeals appears reasonable and sufficient on this count also and hence, we condone