SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-1, ERODE

disallowances made\nby the AO and confirmed by the CIT(A) in the impugned CIT(A)'s\norder.\"\n10. We have heard the both parties and perused the paper books,\nwritten submissions.\n11. The relevant portion of section 153 is as under:\n153 (3) Notwithstanding anything contained in sub-sections (1) [, (1A)] and (2), an\norder of fresh assessment

K 1247 THALAKKARAI PACCS,TIRUPPUR vs. ITO, WARD-2(4), TIRUPUR

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2674/Chny/2025 िनधा;रण वष; /Assessment Year: 2018-19 K1247 Thalakkarai Primary The Income Tax Officer, Agricultural Co-Op. Credit Society, Vs. Ward-2(4), No.1247, Thalakkarai Post, Tirupur. Kethanur, Via Salur Taluk, Tirupu – 641 671. Pan: Aabak 0929Q

disallowances. 3. At the outset, the Ld. Authorized Representative (A.R) of the assessee has submitted that the assessment was reopened by issuing notice u/s. 148 of the Act on 01.04.2022 by Jurisdictional Assessing Officer (hereinafter “JAO”) and the assessee has taken a specific ground before the Ld. CIT(A) in Ground No.2 challenging the reopening in violation of Section 151A