CRR LEATHERS,CHENNAI vs. ITO, CHENNAI

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

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.616/Mds/2017 "नधा"रण वष"/Assessment Year:2008-09 M/S. Crr Leathers, The Income Tax Officer, 9/5, Patnool Sardarjung Street, Vs. Non Corporate Ward 4(3), Periamet, Chennai 600 003. Chennai 600 006. [Pan: Aaafc4173G] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri K. Ravi, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 08.06.2017 घोषणा क" तार"ख /Date Of Pronouncement : 21.08.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 5, Chennai Dated 27.10.2016 Relevant To The Assessment Year 2008-09, Wherein, In The Grounds Appeal, Besides Challenging The Confirmation Of Various Additions For Want Of Tds Under Section 195 Of The Income Tax Act, 1961 [“Act” In Short], The Assessee Has Mainly Challenged Confirmation Of Reopening Of Assessment, Which Is Barred By Limitation.

3 I.T.A. No.616/M/17 explanation. Similarly tax was not deducted in certain payments made under job work charges amounting to ₹. 2,56,895/-. Hence, a sum of ₹. 5,71,745/- was disallowed under section 40(a)(ia) of the Act and the same was brought to tax. Accordingly, the Assessing Officer has completed the assessment under section 143

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:1872, 1873, 1875, 1877 & 1878/Chny/2025 निर्धारण वर्ष / Assessment Years: 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18 Acit, Central Circle -2, Madurai. Vs. Transworld Garnet India Pvt. Ltd., 500, Pantheaon Road, Egmore S.O., Chennai - 600 008. [Pan: Aaact-3408-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. R.Venkata Raman, C.A. प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, C.I.T. सुनवाई की तारीख /Date Of Hearing : 24.09.2025 घोषणा की तारीख/Date Of Pronouncement : 23.10.2025 आदेश /Order Per S. R. Raghunatha, Am : These Five Appeals Preferred By The Revenue Are Directed Against The Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [Hereinafter Referred To As “The Id.Cit(A)”]. The Impugned Orders Of The Id.Cit(A) Arise Out Of The Assessment Orders Framed By The Assistant Commissioner Of Income Tax, Central Circle-2, Madurai [Hereinafter Referred To As “The Ao”], In Respect Of The Assessment Years 2013-14 To 2017-18. The Particulars Of The Respective Appeals Filed By The Revenue Are Set Out Hereinbelow:- S. No

Section under which assessment order was passed 1 1872/Chny/2025 2013-14 07.04.2025 05.05.2021 153A r.w.s 143(3) 2 1873/Chny/2025 2014-15 07.04.2025 05.05.2021 153A r.w.s 143(3) 3 1875/Chny/2025 2015-16 09.04.2025 06.05.2021 153A r.w.s 143(3) 4 1877/Chny/2025 2016-17 09.04.2025 06.05.2021 153A r.w.s 143(3) 5 1878/Chny/2025 2017-18 09.04.2025 06.05.2021 153A r.w.s 143(3) 2. The issues

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

Section under | | | | order of | assessment | which | | | | CIT(A) | order | assessment order | | | | | | was passed | 1 | 1872/Chny/2025 | 2013-14 | 07.04.2025 | 05.05.2021 | 153A r.w.s 143(3) | 2 | 1873/Chny/2025 | 2014-15 | 07.04.2025 | 05.05.2021 | 153A r.w.s 143(3) | 3 | 1875/Chny/2025 | 2015-16 | 09.04.2025 | 06.05.2021 | 153A r.w.s 143(3) | 4 | 1877/Chny/2025 | 2016-17 | 09.04.2025 | 06.05.2021 | 153A r.w.s 143(3) | 5 | 1878/Chny/2025 | 2017-18 | 09.04.2025 | 06.05.2021 | 153A

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

disallowed. The submission that has been urged on behalf of the assessee is that, since the assessment was opened and an order of reassessment was passed only one issue namely, the claim under Section 72A, when the Commissioner as a Revisional Authority under Section 263 seeks to exercise his jurisdiction on matters which did not form the subject

N.PURUSHOTHAMAN,COIMBATORE vs. DCIT, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

section 148, the assessment u/s 143(3) is not valid.” In view of the above, the CIT(A) agreed with the arguments of the assessee and statement made by the Assessing Officer in remand report that only Rs.16.67 lakhs, out of total disallowance

DCIT, OOTY vs. N.PURUSHOTHAMAN, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

section 148, the assessment u/s 143(3) is not valid.” In view of the above, the CIT(A) agreed with the arguments of the assessee and statement made by the Assessing Officer in remand report that only Rs.16.67 lakhs, out of total disallowance

M/S. SHRIRAM CONSTRUCTION FINANCE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.317/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 M/S. Shriram Construction Finance, Vs. The Assistant Commissioner Of Mookambika Complex, No. 4, Income Tax, Lady Desika Road, Mylapore, Non Corporate Circle 2, Chennai 600 004. Chennai. [Pan:Aaafs2597N] आयकर अपील सं./I.T.A. No.343/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Construction Income Tax, Finance, Mookambika Complex, Non Corporate Circle 2(1), No. 4, Lady Desika Road, Chennai. Mylapore, Chennai 600 004. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.03.2022 घोषणा की तारीख /Date Of Pronouncement : 13.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 26.11.2018 Relevant To The Assessment Year 2013-14. The Grounds Raised By The Assessee Are Reproduced As 2

disallowance under section 14A of the Act has already come across under section 143(1) of the Act as well as under section 143(3

DCIT CORPORATE CIRCLE 2, CHENNAI vs. SHRIRAM CONSTRUCTION FINANCE, CHENNAI

In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.317/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 M/S. Shriram Construction Finance, Vs. The Assistant Commissioner Of Mookambika Complex, No. 4, Income Tax, Lady Desika Road, Mylapore, Non Corporate Circle 2, Chennai 600 004. Chennai. [Pan:Aaafs2597N] आयकर अपील सं./I.T.A. No.343/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Construction Income Tax, Finance, Mookambika Complex, Non Corporate Circle 2(1), No. 4, Lady Desika Road, Chennai. Mylapore, Chennai 600 004. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.03.2022 घोषणा की तारीख /Date Of Pronouncement : 13.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 26.11.2018 Relevant To The Assessment Year 2013-14. The Grounds Raised By The Assessee Are Reproduced As 2

disallowance under section 14A of the Act has already come across under section 143(1) of the Act as well as under section 143(3

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

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) of the Act within a period

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

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) of the Act within a period

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

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) of the Act within a period

SHRIRAM FINANCE LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.173/Chny/2024 िनधा"रण वष"/Assessment Year: 2020-21 Shriram Finance Limited Vs. The Deputy Commissioner Of [Formerly Known As Shriram Transport Income Tax, Finance Company Limited), Corporate Circle 3(1), Sri Towers, Plot No. 14A, South Phase, Chennai. Industrial Estate, Guindy, Chennai 600 017. [Pan: Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.07.2024 घोषणा की तारीख /Date Of Pronouncement : 09.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. Ground No. 1 Is General In Nature & Requires No Adjudication.

disallowances taking into account the same income as made under section 143(1) of the Act by separate order passed under section 143(3

ABT LIMITED,CHENNAI vs. THE PCIT(CENTRAL), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 61 & 62/Chny/2021 िनधा"रण वष"/Assessment Years:2013-14 & 2014-15 M/S. Abt Limited, The Principal Commissioner Of 180, Race Course Road, Vs. Income Tax (Central), Coimbatore 641 018. Chennai-2, Chennai. [Pan:Aabca8398K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, C.A. ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 01.08.2022 घोषणा की तारीख /Date Of Pronouncement : 24.08.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Principal Commissioner Of Income Tax (Central), Chennai-2, Chennai, Dated 04.03.2021 & 05.03.2021 Relevant To The Assessment Years 2013-14 & 2014-15 Respectively Challenging The Revision Orders Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

143(3) of the Act dated 08.02.2016 by assessing total income of the assessee under normal provisions at ₹.16,37,88,681/- after making disallowance of claim of revenue expenditure after allowing depreciation @ 10% treating the expenditure as capital. 3. Thereafter, a search action under section

ABT LIMITED,COIMBATORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 61 & 62/Chny/2021 िनधा"रण वष"/Assessment Years:2013-14 & 2014-15 M/S. Abt Limited, The Principal Commissioner Of 180, Race Course Road, Vs. Income Tax (Central), Coimbatore 641 018. Chennai-2, Chennai. [Pan:Aabca8398K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, C.A. ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 01.08.2022 घोषणा की तारीख /Date Of Pronouncement : 24.08.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Principal Commissioner Of Income Tax (Central), Chennai-2, Chennai, Dated 04.03.2021 & 05.03.2021 Relevant To The Assessment Years 2013-14 & 2014-15 Respectively Challenging The Revision Orders Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

143(3) of the Act dated 08.02.2016 by assessing total income of the assessee under normal provisions at ₹.16,37,88,681/- after making disallowance of claim of revenue expenditure after allowing depreciation @ 10% treating the expenditure as capital. 3. Thereafter, a search action under section

CLASSIC LINEN INTERNATIONAL PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, the appeal filed by assessee in iTA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा$रण वष$ /Assessment Year: 2011-12

section 32, the written down value of any asset used for the purposes of the business of the undertaking shall be computed as if the assessee had claimed and been actually allowed the deduction in respect of depreciation for each of the relevant assessment year. (7) The provisions of sub-section (8) and sub-section (10) of section

SUNTEC BUSINESS SOLUTIONS PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

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

Bench: Shri George George Kand Shri S.R. Raghunatha

section 143(3) :- 2 -: r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2021-22. 2. Brief facts of the case are as follows: The assessee is a private limited company engaged in software development services for banking and financial institutions. For the assessment year 2021-22, the return of income

ACIT, CHENNAI vs. M/S. KAYCEE DISTILLERIES, THIRUSSUR

In the result, the appeals of the Revenue in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance under section 40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3

ACIT, CHENNAI vs. M/S. KAYCEE DISTILLERIES, THIRUSSUR

In the result, the appeals of the Revenue in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance under section 40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3

ACIT, CHENNAI vs. M/S. KAYCEE DISTILLERIES, THIRUSSUR

In the result, the appeals of the Revenue in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance under section 40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3