MOSBACHER INDIA LLC,CHENNAI vs. ADDL. DIT, CHENNAI

In the result, the appeal is partly allowed in the terms indicated above

142 (Del)], is that all these precedents pertain to the situations in which applicability of Section 144C was not in slightest doubt and yet the Assessing Officer did not issue the draft assessment order- as is required to under the scheme of Section 144C. That is not the case here. It was a conscious, and in fact correct, decision

EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri George Mathan & Shri Ramit Kochar

depreciation allowance or any other allowance shall constitute valid reasons for reopening of the concluded assessment by invoking provisions of Section 147 of the 1961 Act. The learned CIT(A) observed that in the present case, the assessee has during the previous year relevant to impugned ay had received certain loans/advances from a subsidiary company in which assessee held

ADP INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, NATIONAL FACELESS ASSESSMENT CENTRE

In the result, the appeal in ITA No

depreciation, and the 5th proviso to Section 32(1) does not restrict this claim. The addition made under Section 56(2)(viib) was deleted as it was not applicable to non-residents. The issue regarding Section 40(a)(i) was remanded to the Assessing Officer for fresh adjudication. \n", "result": "Partly Allowed", "sections": [ "250", "143(1)", "143(2)", "142

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

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year ): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall

ADP INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), CHENNAI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

2) of the Act dated 13.08.2018 was issued and served on the assessee manually also. Notice under section 142(1) of the Act dated 19.10.2019 was also issued on the assessee. ITA Nos.2670 to 2672 & 2698/Chny/2024 6. On perusal of the depreciation

ADP INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

2) of the Act dated 13.08.2018 was issued and served on the assessee manually also. Notice under section 142(1) of the Act dated 19.10.2019 was also issued on the assessee. ITA Nos.2670 to 2672 & 2698/Chny/2024 6. On perusal of the depreciation

ADP INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeal in ITA No

depreciation was set aside.", "result": "Allowed", "sections": [ "250", "143(1)", "143(2)", "142(1)", "32", "43(1)", "47", "170", "40(a)(i)", "195", "56(2

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

depreciation, as her business income. On this\nbasis, the assessee submitted that the business income of Rs.20,64,120/- as\ndisclosed in the return of income filed for the relevant assessment year was in\nline with the statement furnished during the course of survey. It was, therefore,\nrequested that no addition be made to the returned income and that

SIVAKUMARAN PUGAZHENDHI,CHENNAI vs. PCIT,, CHENNAI-4

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.27/Chny/2022 िनधा"रण वष" /Assessment Year: 2014-15 Sivakumaran Pugazhendhi, The Principal Commissioner 70 Raja Agraharam Street, Vs. Of Income Tax, Poonamalle, Chennai-4. Chennai – 600 056. [Pan: Aiapp-7309-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. T.V. Muthu Abirami, Advocate ""यथ" क" ओर से /Respondent By : Shri M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 05.09.2022 : 21.09.2022 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R

142(1), wherein :- 6 -: the details of sundry debtors and creditors, details of investments made during the year and source thereof was called for. The Ld. Counsel for the assessee stated that the assessee received unsecured loan as outstanding as on 31.03.2014 to the extent of Rs. 5,10,11,353/- and advances from customers to the extent

M. NATESAN,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

S. ARAVIND,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

K. BASKAR,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

P. KARUNANITHI,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections