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

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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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

disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section 153A(1

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

disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section 153A(1

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

disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section 153A(1

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

disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section 153A(1

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

disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section 153A(1

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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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

1)(a) would be construed to be a return of income under section 139 of the Act. be a return of income under section 139 of the Act. ........ 13. In the present case, search was conducted on the assessee on 30 13. In the present case, search was conducted on the assessee on 30 13. In the present case, search

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

1)/143(3) of the Act and/or the time limit for issue of notice u/s\n143(2) of the Act had expired. Accordingly, the income-tax assessments\nfor AYs 2014-15 to 2017-18 weren't pending before AO on the date of\nsearch, therefore, those years didn't abate consequent to the search. Post\nthe issue of notice

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

1)/143(3) of the Act and/or the time limit for issue of notice u/s\n143(2) of the Act had expired. Accordingly, the income-tax assessments\nfor AYs 2014-15 to 2017-18 weren't pending before AO on the date of\nsearch, therefore, those years didn't abate consequent to the search. Post\nthe issue of notice

ST. JOHN FREIGHT SYSTEMS PVT. LTD.,,TUTUCORIN vs. DCIT, CC-1,, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

1)(a) of the Act the return filed under section 153A of the Act shall be considered as return filed us. 139 of the Act. Hence the requirement of section 8OIA read with section 80AC should be considered on the basis of time limit for filing return u/s 153A of the Act. ITA No.188 & 2898-2900/Chny/2019 :: 9 :: The Deputy

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

1)(a) of the Act the return filed under section 153A of the Act shall be considered as return filed us. 139 of the Act. Hence the requirement of section 8OIA read with section 80AC should be considered on the basis of time limit for filing return u/s 153A of the Act. ITA No.188 & 2898-2900/Chny/2019 :: 9 :: The Deputy

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

1)(a) of the Act the return filed under section 153A of the Act shall be considered as return filed us. 139 of the Act. Hence the requirement of section 8OIA read with section 80AC should be considered on the basis of time limit for filing return u/s 153A of the Act. ITA No.188 & 2898-2900/Chny/2019 :: 9 :: The Deputy

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

1)(a) of the Act the return filed under section 153A of the Act shall be considered as return filed us. 139 of the Act. Hence the requirement of section 8OIA read with section 80AC should be considered on the basis of time limit for filing return u/s 153A of the Act. ITA No.188 & 2898-2900/Chny/2019 :: 9 :: The Deputy

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

153A. The disallowances made by the assessing officer were upheld by the CIT(A) but the learned Tribunal deleted those disallowances. 10. We find no infirmity in the aforesaid act of the learned Tribunal. The appeal is, therefore, dismissed.”(emphasis supplied) 16. In the light of the aforesaid discussion and case laws let us examine the legal issue raised before

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

153A. The disallowances made by the assessing officer were upheld by the CIT(A) but the learned Tribunal deleted those disallowances. 10. We find no infirmity in the aforesaid act of the learned Tribunal. The appeal is, therefore, dismissed.”(emphasis supplied) 16. In the light of the aforesaid discussion and case laws let us examine the legal issue raised before

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

1)/143(3) of the Act and/or the time limit for issue of notice u/s\n143(2) of the Act had expired. Accordingly, the income-tax assessments\nfor AYs 2014-15 to 2017-18 weren't pending before AO on the date of\nsearch, therefore, those years didn't abate consequent to the search. Post\nthe issue of notice