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

disallowance of certain items of expenses.\n3. Aggrieved by the above order(s) of the AO, the assessee preferred\nappeal before the Ld. CIT(A). The assessee is noted to have challenged\nthe validity of the notices issued u/s 153C of the Act on several fronts.\nTaking into account the submissions put forth by the assessee, the Ld.\nCIT

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

disallowance of certain items of expenses.\n3. Aggrieved by the above order(s) of the AO, the assessee preferred\nappeal before the Ld. CIT(A). The assessee is noted to have challenged\nthe validity of the notices issued u/s 153C of the Act on several fronts.\nTaking into account the submissions put forth by the assessee, the Ld.\nCIT

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

disallowance of certain items of expenses.\n3. Aggrieved by the above order(s) of the AO, the assessee preferred\nappeal before the Ld. CIT(A). The assessee is noted to have challenged\nthe validity of the notices issued u/s 153C of the Act on several fronts.\nTaking into account the submissions put forth by the assessee, the Ld.\nCIT

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

disallowance of certain items of expenses.\n3.\nAggrieved by the above order(s) of the AO, the assessee preferred\nappeal before the Ld. CIT(A). The assessee is noted to have challenged\nthe validity of the notices issued u/s 153C of the Act on several fronts.\nTaking into account the submissions put forth by the assessee, the Ld.\nCIT

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

disallowance of certain items of expenses.\n3. Aggrieved by the above order(s) of the AO, the assessee preferred\nappeal before the Ld. CIT(A). The assessee is noted to have challenged\nthe validity of the notices issued u/s 153C of the Act on several fronts.\nTaking into account the submissions put forth by the assessee, the Ld.\nCIT

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

disallowance of certain items of expenses.\n3. Aggrieved by the above order(s) of the AO, the assessee preferred\nappeal before the Ld. CIT(A). The assessee is noted to have challenged\nthe validity of the notices issued u/s 153C of the Act on several fronts.\nTaking into account the submissions put forth by the assessee, the Ld.\nCIT

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 153C of the Act, as was originally introduced by the Finance Act 2003, which prescribed a stronger safeguard for persons who had not been searched viz., the seized material forming the basis of the satisfaction note must ‘belong’ to the ‘other person’. It was judicially held that, where any seized document of the searched person simply ‘pertains

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 153C of the Act, as was originally introduced by the Finance Act 2003, which prescribed a stronger safeguard for persons who had not been searched viz., the seized material forming the basis of the satisfaction note must ‘belong’ to the ‘other person’. It was judicially held that, where any seized document of the searched person simply ‘pertains

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 153C of the Act, as was originally introduced by the Finance Act 2003, which prescribed a stronger safeguard for persons who had not been searched viz., the seized material forming the basis of the satisfaction note must ‘belong’ to the ‘other person’. It was judicially held that, where any seized document of the searched person simply ‘pertains

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 153C of the Act, as was originally introduced by the Finance Act 2003, which prescribed a stronger safeguard for persons who had not been searched viz., the seized material forming the basis of the satisfaction note must ‘belong’ to the ‘other person’. It was judicially held that, where any seized document of the searched person simply ‘pertains

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

153C of the Act is found to be vitiated\nin law.\n43. It is noted that the AO's primary reliance in his 'satisfaction note' to\njustify the invocation of jurisdiction u/s 153C of the Act were the\nstatements of third parties viz., Shri Bhawarlal Jain and Shri\nShanmugavelu, which were recorded in the course of post search\nenquiries

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

2. Mr. Jain, learned Advocate appearing for the assessee, submitted as follows: (a) The assessment under section 153C read with section 153A read with section 144 of the Income Tax Act was altogether without jurisdiction because such assessment was made for all the five years on the basis of survey conducted under section 133A of the Income

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

2. Mr. Jain, learned Advocate appearing for the assessee, submitted as follows: (a) The assessment under section 153C read with section 153A read with section 144 of the Income Tax Act was altogether without jurisdiction because such assessment was made for all the five years on the basis of survey conducted under section 133A of the Income

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

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

MASILAMANI NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, appeals filed by the assessee(s) are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

153C of the Act dated 08.02.2021 requiring the assessee to submit his return of income for AYs 2014-15 to 2018-19. It is noted that, the issuance of the notice was preceded by a satisfaction note drawn up by the AO and since the same would have a material bearing on the legal challenge raised before us, the same

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

2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\"\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:: 11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered

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

2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\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:: 11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered