SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

ACIT, CORPORATE CIRCLE 1(1), CHENNAI vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (FORMERLY FUTURE SOFT PRIVATE LIMITED), CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.420/Chny/2024 िनधा"रण वष"/Assessment Year: 2006-07 V. The Acit, Capgemini Technology Corporate Circle-1(1), Services India Ltd., Block 3, ‘C’ Wing, 4Th Floor, Chennai. Capgemini Knowledge Park, Airoli Knowledge Park, Thane Belapur Road, Navi Mumbai- 400 708. [Pan: Aaacf 0482 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowing the deduction u/s 10A of the Act. The appellant’s counsel respectfully submits that the audit report in Form 56F was duly filed along with the original return of income. During the reassessment proceedings, only supplementary ITA No.420 /Chny/2024 (AY 2006-07) Capgemini Technology Services India Ltd. :: 15 :: information specifically, the date of commencement of production and details

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

1) of section 142 of the Act, no right to question the jurisdiction of an Assessing Officer would survive. 2.6 In the present case, the assessee has not challenged the assumption of concurrent jurisdiction by the JCIT within the time stipulated in the statute and reproduced hereinabove. The case law filed by the assessee has no application to the facts

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

1) of section 142 of the Act, no right to question the jurisdiction of an Assessing Officer would survive. 2.6 In the present case, the assessee has not challenged the assumption of concurrent jurisdiction by the JCIT within the time stipulated in the statute and reproduced hereinabove. The case law filed by the assessee has no application to the facts

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

1) of section 142 of the Act, no right to question the jurisdiction of an Assessing Officer would survive. 2.6 In the present case, the assessee has not challenged the assumption of concurrent jurisdiction by the JCIT within the time stipulated in the statute and reproduced hereinabove. The case law filed by the assessee has no application to the facts

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are

142(1) of the Act, wherein, the Assessing Officer specifically sought information about the claim of exemption under section 10(38) of the Act as well as section 14A of the Act vide question No. 12(1) and dealt the issue extensively. The reasons recorded by us in the aforementioned paragraphs are equally applicable to the present issue

UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

142(1) of the Act, wherein, the Assessing Officer specifically sought information about the claim of exemption under section 10(38) of the Act as well as section 14A of the Act vide question No. 12(1) and dealt the issue extensively. The reasons recorded by us in the aforementioned paragraphs are equally applicable to the present issue

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section 147. 17. In Rakesh

SQS INDIA BFSI LTD. (FORMERLY KNOWN AS M/S. THINKSOFT GLOBAL SERVICES LTD.),CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 223 & 224/Chny/2019 िनधा"रण वष"/Assessment Years:2012-13 & 2013-14 M/S. Sqs India Bfsi Ltd. (Formerly The Deputy Commissioner Of Known As M/S. Thinksoft Global Vs. Income Tax, Services Ltd.) Door No. 6A, 6Th Floor, Corporate Circle 6(2), Prince Infocity Ii, 283/3 & 283/4, Rajiv Chennai. Gandhi Salai (Omr), Kandanchavadi, Chennai 600 036. [Pan:Aabct0976G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Vikram Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.03.2021 घोषणा की तारीख /Date Of Pronouncement : 03.05.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Same Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2018 Relevant To The Assessment Years 2012-13 & 2013-14. Besides Challenging Confirmation Of Disallowance Of Export Commission Payment In The Assessment Year 2012-13, The Assessee Also Challenged Confirmation Of Disallowance Towards Payments For Professional Services Rendered For Both The Assessment Years 2012-13 & 2013-14. 2

1) of the Act in the hands 10 I.T.A. Nos. 223 & 224/Chny/19 of the non-resident agents and accordingly, the provisions of section 195(2) of the Act would not come into operation at all. The head notes in the case of GE Technology Center Pvt. Ltd. in 327 ITR 456 (SC) are reproduced hereunder:- Section 195 of the Income

SQS INDIA BFSI LTD. (FORMERLY KNOWN AS M/S. THINKSOFT GLOBAL SERVICES LTD.),CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 223 & 224/Chny/2019 िनधा"रण वष"/Assessment Years:2012-13 & 2013-14 M/S. Sqs India Bfsi Ltd. (Formerly The Deputy Commissioner Of Known As M/S. Thinksoft Global Vs. Income Tax, Services Ltd.) Door No. 6A, 6Th Floor, Corporate Circle 6(2), Prince Infocity Ii, 283/3 & 283/4, Rajiv Chennai. Gandhi Salai (Omr), Kandanchavadi, Chennai 600 036. [Pan:Aabct0976G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Vikram Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.03.2021 घोषणा की तारीख /Date Of Pronouncement : 03.05.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Same Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2018 Relevant To The Assessment Years 2012-13 & 2013-14. Besides Challenging Confirmation Of Disallowance Of Export Commission Payment In The Assessment Year 2012-13, The Assessee Also Challenged Confirmation Of Disallowance Towards Payments For Professional Services Rendered For Both The Assessment Years 2012-13 & 2013-14. 2

1) of the Act in the hands 10 I.T.A. Nos. 223 & 224/Chny/19 of the non-resident agents and accordingly, the provisions of section 195(2) of the Act would not come into operation at all. The head notes in the case of GE Technology Center Pvt. Ltd. in 327 ITR 456 (SC) are reproduced hereunder:- Section 195 of the Income

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

142(1) of the Act and verification of relevant books of accounts and other details, in our opinion, reopening of assessment for denying the exemption is a mere change of opinion and it is not justified. Thus, the reassessment order dated 21.03.2022 under section 147 r.w.s. 144B of the Act made by the Assessing Officer and confirmed