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

151 and section 153, in the case of a person52\nwhere a search is initiated under section 132 or books of account, other\ndocuments or any assets are requisitioned under section 132A after the\n31st day of May, 2003 but on or before the 31st day of March, 2021, the\nAssessing Officer shall-\n(a)issue notice to such person

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

151 and section 153, in the case of a person52\nwhere a search is initiated under section 132 or books of account, other\ndocuments or any assets are requisitioned under section 132A after the\n31st day of May, 2003 but on or before the 31st day of March, 2021, the\nAssessing Officer shall-\n(a)issue notice to such person

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JSR INFRA DEVELOPERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

151 and 153. 8.2 Having noticed the above, we may also refer t 8.2 Having noticed the above, we may also refer to the second and the third o the second and the third proviso to section 153A(1). For the sake of convenience, the second and third proviso to section 153A(1). For the sake of convenience, the second

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.\nSection 153A(1) of the Act is set out below:.......\n12. It is apparent from the above that Section 153A of the Act refers to\ntime periods within which the assessments could be reopened. In terms\nof Section 153A(1) of the Act, the assessments can be reopened for a\nblock of six years preceding

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

151 and section 153, in the case of a person52\nwhere a search is initiated under section 132 or books of account, other\ndocuments or any assets are requisitioned under section 132A after the\n31st day of May, 2003 but on or before the 31st day of March, 2021, the\nAssessing Officer shall-\n(a)issue notice to such person

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

151 and section 153, in the case of a person52\nwhere a search is initiated under section 132 or books of account, other\ndocuments or any assets are requisitioned under section 132A after the\n31st day of May, 2003 but on or before the 31st day of March, 2021, the\nAssessing Officer shall-\n(a)issue notice to such person

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

151 and section 153, in the case of a person52\nwhere a search is initiated under section 132 or books of account, other\ndocuments or any assets are requisitioned under section 132A after the\n31st day of May, 2003 but on or before the 31st day of March, 2021, the\nAssessing Officer shall-\n(a)issue notice to such person

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\nLd. Counsel for the assesse informed that the Ld. First Appellate\nAuthority considered the issue of interpretation of Rule-6ABA for the\npurposes of section 36(1)(viia) and granted relief to the assesse.\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\nBench of this Tribunal in the case

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\r\nLd. Counsel for the assesse informed that the Ld. First Appellate\r\nAuthority considered the issue of interpretation of Rule-6ABA for the\r\npurposes of section 36(1)(viia) and granted relief to the assesse.\r\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\r\nBench of this

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\nLd. Counsel for the assesse informed that the Ld. First Appellate\nAuthority considered the issue of interpretation of Rule-6ABA for the\npurposes of section 36(1)(viia) and granted relief to the assesse.\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\nBench of this Tribunal in the case

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\nLd. Counsel for the assesse informed that the Ld. First Appellate\nAuthority considered the issue of interpretation of Rule-6ABA for the\npurposes of section 36(1)(viia) and granted relief to the assesse.\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\nBench of this Tribunal in the case

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

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 of the\nAct without assigning proper reasons and justification.\n9) The PCIT failed to appreciate that there was complete scrutiny of facts referred\nto in the revision

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

151 TTJ 126\n(Hyd. ITAT)\n\nΟ Bharti AXA General Insurance Co. Ltd: 326 ITR 477 (AAR)\n\n13. The revenue, on the other hands, vehemently argued that the\nsoftware AMC payments made in relation to vendors from countries\nwhere there is no 'make available clause' (i.e. Germany and Austria)\nis taxable in India by virtue of Section

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

151 TTJ 126\n(Hyd. ITAT)\n• Bharti AXA General Insurance Co. Ltd: 326 ITR 477 (AAR)\n13. The revenue, on the other hands, vehemently argued that the\nsoftware AMC payments made in relation to vendors from countries\nwhere there is no 'make available clause' (i.e. Germany and Austria)\nis taxable in India by virtue of Section 9(1

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

151 TTJ 126\n(Hyd. ITAT)\n- Bharti AXA General Insurance Co. Ltd: 326 ITR 477 (AAR)\n13. The revenue, on the other hands, vehemently argued that the\nsoftware AMC payments made in relation to vendors from countries\nwhere there is no 'make available clause' (i.e. Germany and Austria)\nis taxable in India by virtue of Section 9(1

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

151 TTJ 126\n(Hyd. ITAT)\nΟ Bharti AXA General Insurance Co. Ltd: 326 ITR 477 (AAR)\n13. The revenue, on the other hands, vehemently argued that the\nsoftware AMC payments made in relation to vendors from countries\nwhere there is no 'make available clause' (i.e. Germany and Austria)\nis taxable in India by virtue of Section 9(1