MOHIT CHANDAK,CHENNAI vs. DCIT CENTRAL CIRCLE 3(3), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ Ita Nos.191 & 194/Chny/2025 िनधा=रण वष= /Assessment Years: 2017-18 & 2016-17

section 148A(b) and the details of material/ information on the basis of which the assessment is sought to be reopened was also provided to the appellant vide letter dated 01.06.2022. Later, order u/s 148A(d) was passed on 31.07.2022 and proceedings u/s 147 was initiated by issue of notice u/s 148 of the Act dated

MOHIT CHANDAK,CHENNAI vs. DCIT CENTRAL CIRCLE 3(3), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ Ita Nos.191 & 194/Chny/2025 िनधा=रण वष= /Assessment Years: 2017-18 & 2016-17

section 148A(b) and the details of material/ information on the basis of which the assessment is sought to be reopened was also provided to the appellant vide letter dated 01.06.2022. Later, order u/s 148A(d) was passed on 31.07.2022 and proceedings u/s 147 was initiated by issue of notice u/s 148 of the Act dated

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153A of the Act prior to\nissuance of notice u/s 148 of the Act for AY 2016-17, which fell beyond\nthe six year block period, under the new 148 regime. The Hon'ble High\nCourt observed that, the AO had sought to disallow

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153A of the Act prior to\nissuance of notice u/s 148 of the Act for AY 2016-17, which fell beyond\nthe six year block period, under the new 148 regime. The Hon'ble High\nCourt observed that, the AO had sought to disallow

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153A of the Act prior to\nissuance of notice u/s 148 of the Act for AY 2016-17, which fell beyond\nthe six year block period, under the new 148 regime. The Hon'ble High\nCourt observed that, the AO had sought to disallow

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153A of the Act prior to\nissuance of notice u/s 148 of the Act for AY 2016-17, which fell beyond\nthe six year block period, under the new 148 regime. The Hon'ble High\nCourt observed that, the AO had sought to disallow

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

148 regime, in terms of proviso to Section\n149(1)(b) of the Act.\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 33 ::\n23. Per contra, the Ld. AR vehemently opposed the contention of the\nRevenue and he argued that, in terms

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

148 regime, in terms of proviso to Section\n149(1)(b) of the Act.\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 33 ::\n23. Per contra, the Ld. AR vehemently opposed the contention of the\nRevenue and he argued that, in terms

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

148, the assessee filed return of income on 13.12.2021 declaring a total income of Rs. 0/-. In response to notice under C.O.No.27/Chny/2025 section 142(1) the AR had submitted Income Computation statement. Profit & Loss Account for the AY 2017-18, Balance Sheet as on 31.03 2017, details of assets etc. The AO has not made any addition

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

disallow exemption under section\n11 of the Act to assume jurisdiction to reopen the assessment. He argued\nthat in the case of Songwoon Speciality Chemicals India (P.) Ltd. v. DCIT\n[2024] 169 taxmann.com 184 (Gujarat), when the claim was accepted in\nthe original assessment proceedings and the Assessing Officer could not\nhave reopened assessment on the same facts which

SRI KRISHA TRADERS,SIVAGANGAI vs. DCIT, NON CORPORATE CIRCLE-1,, MADURAI

In the result, the appeal of the assessee is allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2223/Chny/2025 िनधा%रण वष% /Assessment Year: 2017-18

148. Further to that, assessee did not submit any documents proving that the transactions mentioned above were related to the business activities claimed by the assessee. Even though, the above transactions were considered as part of the business activities, the entire purchase consideration was paid by the assessee in cash and in violation of section 40A(3). Assessee also failed

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

disallow exemption under section 11 of the Act to assume jurisdiction to reopen the assessment. He argued that in the case of Songwoon Speciality Chemicals India (P.) Ltd. v. DCIT [2024] 169 taxmann.com 184 (Gujarat), when the claim was accepted in the original assessment proceedings and the Assessing Officer could not have reopened assessment on the same facts which were

MAHASAKTHI BIO ENERCON PVT. LTD.,COIMBATORE vs. ACIT, CENTRAL CIRCLE-1,, COIMBATORE

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:467/Chny/2025 िनधा"रण वष" / Assessment Year: 2013-14 Mahasakthi Bio Enercon Private Assistant Commissioner Of Limited, Vs. Income Tax, No.64, Dr. Nanjappa Road, Central Circle -1, Coimbatore – 641 018. Coimbatore. [Pan:Aabci-0022-N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. T. Banusekar, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, C.I.T.

section 148 of the Act, 1961 were without jurisdiction.” 6. The ld.AR argued that from the plain reading of the discussion rendered by the Hon’ble Allahabad High Court it is clear that if the notice issued u/s.148 of the Act is issued without obtaining prior approval from the prescribed authority then the impugned notice issued by the Assessing officer

MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

disallow the claim\nof deduction under Section 80P of the Act to the tune of Rs.10,91,802/- forming\npart of the return of income filed in response to notice under Section 148

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

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

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

disallow exemption under section\n11 of the Act to assume jurisdiction to reopen the assessment. He argued\nthat in the case of Songwoon Speciality Chemicals India (P.) Ltd. v. DCIT\n[2024] 169 taxmann.com 184 (Gujarat), when the claim was accepted in\nthe original assessment proceedings and the Assessing Officer could not\nhave reopened assessment on the same facts which

DCIT,CC-2(1), CHENNAI vs. M/S, JAN DE NUL DREDGING (I)(P)LTD, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.870/Chny/2020 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. Jan De Nul Dredging (I)(P) Ltd., “Capital”, 10Th Floor, No. 554/555, Income Tax, Corporate Circle 2(1), Room No. 511, 5Th Floor, Wanaparthy Mount Road, Chennai 600 018. Block, No. 121, M.G. Road, Chennai 600 034. [Pan:Aaacj6482G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri Ashik Shah, C.A. & Ms. C. Sowndarya, C.A. सुनवाई की तारीख/ Date Of Hearing : 02.02.2023 घोषणा की तारीख /Date Of Pronouncement : 08.02.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai, Dated 26.08.2020 Relevant To The Assessment Year 2011-12. 2. Facts Are, In Brief, That The Assessee Is Engaged In The Business Of Dredging Services & Filed Its Return Of Income For The Assessment Year 2011-12 On 30.11.2011 Admitting Total Income Of ₹.3,86,20,850/-. The Return Filed By The Assessee Was Initially Processed Under Section 143(1)

148 of the Act for reopening of assessment under section 147 of the Act and the reasons recorded were supplied to the assessee on 19.03.2018. Thereafter, the Assessing Officer has completed the assessment under section 143(3) r.w.s. 147 of the Act dated 20.07.2018 and made certain additions/ disallowances