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

161 taxmann.com 160/465 ITR 101 (Delhi\n).\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the\nmanner in which the period of six or ten years is required to be reckoned\nin respect of reopening of the assessment for a period prior to six years\nand/or before the expiry of ten years from the relevant assessment years

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

161 taxmann.com 160/465 ITR 101 (Delhi\n).\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the\nmanner in which the period of six or ten years is required to be reckoned\nin respect of reopening of the assessment for a period prior to six years\nand/or before the expiry of ten years from the relevant assessment years

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

161 taxmann.com 160/465 ITR 101 (Delhi\n).\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the\nmanner in which the period of six or ten years is required to be reckoned\nin respect of reopening of the assessment for a period prior to six years\nand/or before the expiry of ten years from the relevant assessment years

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

161 taxmann.com 160/465 ITR 101 (Delhi\n).\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the\nmanner in which the period of six or ten years is required to be reckoned\nin respect of reopening of the assessment for a period prior to six years\nand/or before the expiry of ten years from the relevant assessment years

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

161 taxmann.com 160/465 ITR 101 (Delhi\n).\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the\nmanner in which the period of six or ten years is required to be reckoned\nin respect of reopening of the assessment for a period prior to six years\nand/or before the expiry of ten years from the relevant assessment years

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

161 taxmann.com 160/465 ITR 101 (Delhi\n).\n11. In Ojjus Medicare Pvt. Limited (supra), the Court also explained the\nmanner in which the period of six or ten years is required to be reckoned\nin respect of reopening of the assessment for a period prior to six years\nand/or before the expiry of ten years from the relevant assessment years

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

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

disallowances on the basis of the incriminating\nmaterials seized during the course of search at the appellant's premises\nas well as the materials seized during the course of search at M/s. SNJ\nGroup of concerns. Therefore, in the absence of such findings, the\ninitiation of proceedings u/s 153C

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

disallowances on the basis of the incriminating\nmaterials seized during the course of search at the appellant's premises\nas well as the materials seized during the course of search at M/s. SNJ\nGroup of concerns. Therefore, in the absence of such findings, the\ninitiation of proceedings u/s 153C

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

161 The provisions of Section 194J(1) of the IT Act cast liability on the persons responsible for paying to resident any sum by way of fees for professional services. The assessee availed the professional services and responsible for paying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the explanation of section 40(a), 'Professional Services' have

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

161 The provisions of Section 194J(1) of the IT Act cast liability on the persons responsible for paying to resident any sum by way of fees for professional services. The assessee availed the professional services and responsible for paying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the explanation of section 40(a), 'Professional Services' have

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

161 The provisions of Section 194J(1) of the IT Act cast liability on the persons responsible for paying to resident any sum by way of fees for professional services. The assessee availed the professional services and responsible for paying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the explanation of section 40(a), 'Professional Services' have

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

161\nThe provisions of Section 194J(1) of the IT Act cast liability on the persons\nresponsible for paying to resident any sum by way of fees for professional\nservices. The assessee availed the professional services and responsible for\npaying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the\nexplanation of section 40(a), 'Professional Services' have

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

161\nThe provisions of Section 194J(1) of the IT Act cast liability on the persons\nresponsible for paying to resident any sum by way of fees for professional\nservices. The assessee availed the professional services and responsible for\npaying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the\nexplanation of section 40(a), 'Professional Services' have

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

161\nThe provisions of Section 194J(1) of the IT Act cast liability on the persons\nresponsible for paying to resident any sum by way of fees for professional\nservices. The assessee availed the professional services and responsible for\npaying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the\nexplanation of section 40(a), 'Professional Services' have

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

161\nThe provisions of Section 194J(1) of the IT Act cast liability on the persons\nresponsible for paying to resident any sum by way of fees for professional\nservices. The assessee availed the professional services and responsible for\npaying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the\nexplanation of section 40(a), 'Professional Services' have

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

161\nThe provisions of Section 194J(1) of the IT Act cast liability on the persons\nresponsible for paying to resident any sum by way of fees for professional\nservices. The assessee availed the professional services and responsible for\npaying fees to M/s Paramount Health Services TPA PVt. Ltd. Further, in the\nexplanation of section 40(a), 'Professional Services' have