ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

142(1) notices. Furthermore, the final assessment order did not discuss the applicability of Sections 115QA, 56(2)(vii)(a), or the proportionate disallowance

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

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order 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 Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

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

T.S.R.KHANNAIYANN,CHENNAI vs. ACIT, COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

142, sub-sections (2) and (3) of section 143.” 10 I.T.A. Nos.256 & 257/Chny/18 I.T.A. No.812/Chny/18 10. In view of the above judgment of Apex Court, this Tribunal is of the considered opinion that even though the case was reopened and reason for reopening was supplied, the Assessing Officer was expected to serve the notice under Section 143(2

ITO CORPORATE WARD 2 , COIMBATORE vs. SHRI. T S R KHANNAIYAN, COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

142, sub-sections (2) and (3) of section 143.” 10 I.T.A. Nos.256 & 257/Chny/18 I.T.A. No.812/Chny/18 10. In view of the above judgment of Apex Court, this Tribunal is of the considered opinion that even though the case was reopened and reason for reopening was supplied, the Assessing Officer was expected to serve the notice under Section 143(2

T.S.R.KHANNAIYANN,CHENNAI vs. ACIT, COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

142, sub-sections (2) and (3) of section 143.” 10 I.T.A. Nos.256 & 257/Chny/18 I.T.A. No.812/Chny/18 10. In view of the above judgment of Apex Court, this Tribunal is of the considered opinion that even though the case was reopened and reason for reopening was supplied, the Assessing Officer was expected to serve the notice under Section 143(2

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

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

2(b) along with 8 are relating to disallowance under section 14A of the Act r.w. Rule 8D. 43. Vide para 3 of the impugned order, the Id. PCIT is of the opinion that for the AY 2016-17, the Assessing Officer made disallowance under section 14A r.w.s. Rule 8D, but, however, no disallowance made for AY 2017-18. However

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

2(b) along with 8 are relating to disallowance under section 14A of the Act r.w. Rule 8D. 26 I.T.A. No.1759/Chny/19 & Ors United India Insurance 43. Vide para 3 of the impugned order, the ld. PCIT is of the opinion that for the AY 2016-17, the Assessing Officer made disallowance under section 14A r.w.s. Rule 8D, but, however

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.

2) of the Act. It is, thus, evident that before the I.T.A. Nos. 1202, 1203 & 1204/Chny/2015 6 expiry of the period of one month from the date of service of notice under sub-section (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

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.

2) of the Act. It is, thus, evident that before the I.T.A. Nos. 1202, 1203 & 1204/Chny/2015 6 expiry of the period of one month from the date of service of notice under sub-section (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

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.

2) of the Act. It is, thus, evident that before the I.T.A. Nos. 1202, 1203 & 1204/Chny/2015 6 expiry of the period of one month from the date of service of notice under sub-section (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

THE IKKARAIBOLUVAMPATTI PACCS 33,COIMBATORE vs. ITO,NCW 4(2), COIMBATORE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.461/Chny/2021 िनधा"रण वष" /Assessment Year: 2017-18 M/S.Ikkaraiboluvampatti Paccs, V. The Income Tax Officer, 33, Rajaji Street, Non-Corporate Ward-4(2), Coimbatore. Coimbatore. [Pan: Aaaai 3699 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.J.Saravanan, Adv. ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.10.2022 घोषणा क" तारीख /Date Of Pronouncement : 02.11.2022

disallowed deduction claimed u/s.80P(2)(a)(i) of the Act primarily on two grounds. The first objection of the AO is with regard to claim of deduction in the light of provisions of Section 80A(5) of the Act which restricts the M/s.Ikkaraiboluvampatti PACCS :: 9 :: deduction unless such deduction is claimed in the return of income. We have gone through

UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

2(b) along with 8 are relating to disallowance under section 14A of the Act r.w. Rule 8D. 43. Vide para 3 of the impugned order, the Id. PCIT is of the opinion that for the AY 2016-17, the Assessing Officer made disallowance under section 14A r.w.s. Rule 8D, but, however, no disallowance made for AY 2017-18. However

MR. THANUSHKODI NARAYANAN,CHENNAI vs. ADDL. CIT CENTRAL CIRCLE 3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 to 153. The rest of additions are additions/ disallowances from salary, interest on borrowed capital added and disallowed, deemed rental income from Thillai Ganga Nagar property and additional deemed rental income from Ponniamman Koil Street property and disallowance of deduction u/s.24(a) of the Act and addition u/s.56(2)(vii)(c) of the Act. When these facts were confronted

MRS.JOTHI NARAYANAN ,CHENNAI vs. ACIT , CHENNAI

In the result, the appeals filed by the assessees in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 to 153. The rest of additions are additions/ disallowances from salary, interest on borrowed capital added and disallowed, deemed rental income from Thillai Ganga Nagar property and additional deemed rental income from Ponniamman Koil Street property and disallowance of deduction u/s.24(a) of the Act and addition u/s.56(2)(vii)(c) of the Act. When these facts were confronted

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

2) & 142(1) were issued asking the assessee to furnish further details in respect of deduction claimed u/s.80-IA with supporting documents. During the course of assessment proceedings, the AO being not satisfied with the reply or explanation furnished by the assessee disallowed the entire claim of the assessee made certain additions. 4. Aggrieved, the assessee preferred an appeal before

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

2(b) along with 8 are relating to disallowance under section 14A of the Act r.w. Rule 8D. 26 I.T.A. No.1759/Chny/19 & Ors United India Insurance 43. Vide para 3 of the impugned order, the Id. PCIT is of the opinion that for the AY 2016-17, the Assessing Officer made disallowance under section 14A r.w.s. Rule 8D, but, however

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance made under section 43B of the Act. I.T.A. No. 691/Mds/2017[A.Y. 2011-12] 2. Brief facts of the case are that the assessee has filed its return of income on 28.09.2011 declaring an income of ₹.19,78,00,330/-. The return filed by the assessee was processed under section 143(1) of the Act on 10.01.2012 and accepted

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance made under section 43B of the Act. I.T.A. No. 691/Mds/2017[A.Y. 2011-12] 2. Brief facts of the case are that the assessee has filed its return of income on 28.09.2011 declaring an income of ₹.19,78,00,330/-. The return filed by the assessee was processed under section 143(1) of the Act on 10.01.2012 and accepted