DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

271(1)(c) of the Act, subsequent to the date of the\nassessment order, is merely of academic relevance. Accordingly,\nwe refrain from rendering any finding thereon.\n43. Furthermore, it is pertinent to observe that the Revenue\nhas failed to raise a specific ground of appeal challenging the\nfinding of the CIT(A) that the show cause notice dated\n27.03.2022

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

271(1)(c) of the Act, subsequent to the date of the\nassessment order, is merely of academic relevance. Accordingly,\nwe refrain from rendering any finding thereon.\n43.\nFurthermore, it is pertinent to observe that the Revenue\nhas failed to raise a specific ground of appeal challenging the\nfinding of the CIT(A) that the show cause notice dated\n27.03.2022

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

271(1)(c) of the Act, subsequent to the date of the\nassessment order, is merely of academic relevance. Accordingly,\nwe refrain from rendering any finding thereon.\n43.\nFurthermore, it is pertinent to observe that the Revenue\nhas failed to raise a specific ground of appeal challenging the\nfinding of the CIT(A) that the show cause notice dated\n27.03.2022

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

271(1)(c) of the Act, subsequent to the date of the\nassessment order, is merely of academic relevance. Accordingly,\nwe refrain from rendering any finding thereon.\n43.\nFurthermore, it is pertinent to observe that the Revenue\nhas failed to raise a specific ground of appeal challenging the\nfinding of the CIT(A) that the show cause notice dated\n27.03.2022

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

271(1)(c) of the Act, subsequent to the date of the\nassessment order, is merely of academic relevance. Accordingly,\nwe refrain from rendering any finding thereon.\n43.\nFurthermore, it is pertinent to observe that the Revenue\nhas failed to raise a specific ground of appeal challenging the\nfinding of the CIT(A) that the show cause notice dated\n27.03.2022

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

271(1)(c) of the Act, subsequent to the date of the\nassessment order, is merely of academic relevance. Accordingly,\nwe refrain from rendering any finding thereon.\n43.\nFurthermore, it is pertinent to observe that the Revenue\nhas failed to raise a specific ground of appeal challenging the\nfinding of the CIT(A) that the show cause notice dated\n27.03.2022

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

disallowance under section 40(a)(ia) of the Act, the Assessing Officer proposed for initiating penalty proceedings under section 271(1

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

disallowance under section 40(a)(ia) of the Act, the Assessing Officer proposed for initiating penalty proceedings under section 271(1

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

disallowance under section 40(a)(ia) of the Act, the Assessing Officer proposed for initiating penalty proceedings under section 271(1

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

disallowance under section 40(a)(ia) of the Act, the Assessing Officer proposed for initiating penalty proceedings under section 271(1

M.ARUN,CHENNAI vs. DCIT,CC-2(4), CHENNAI

In the result, the appeal of the assessee is allowed in terms of our above order

Bench: Shri Manoj Kumar Aggarwal & Shri Manomohan Dasआयकर अपील सं./Ita No.573/Chny/2021 िनधा)रण वष) /Assessment Year: 2008-09

271(1)(c) for Rs.6,78,134/- as levied by learned DCIT, Central Circle- II (4), Chennai vide penalty order dated 28-03-2013. The assessment for the year was framed by Ld. Assessing Officer [AO] under section 153A read with section 143(3) of the Act on 31-12-2010 wherein certain addition of Rs.15,95,100/- representing disallowance

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

disallowance under section 40(a)(i) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under section 10A/ 10AA of the Act.\nOthers\n18. The learned AO has erred in law and facts, by initiating penalty\nproceedings under section 274 read with section 271(1

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

disallowance under section 40(a)(i) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under section 10A/ 10AA of the Act.\n\nOthers\n\n18. The learned AO has erred in law and facts, by initiating penalty\nproceedings under section 274 read with section 271(1

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

disallowance under section 40(a)(ia) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under section 10A/ 10AA of the Act.\nOthers\n18. The learned AO has erred in law and facts, by initiating penalty\nproceedings under section 274 read with section 271(1

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

disallowance under section 40(a)(i) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under section 10A/ 10AA of the Act.\nOthers\n19. The learned AO has erred in law and facts, by initiating penalty\nproceedings under Section 274 read with Section 271(1

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

disallowance under section 40(a)(i) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under section 10A/ 10AA of the Act.\nOthers\n19. The learned AO has erred in law and facts, by initiating penalty\nproceedings under section 274 read with section 271(1

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

disallowance under Section 40(a)(i) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under Section 10A/ 10AA of the Act.\nOthers\n18. The learned AO has erred in law and facts, by initiating penalty\nproceedings under Section 274 read with Section 271(1

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

disallowance under section 40(a)(i) results in\nenhancement of business income and the same shall be eligible for enhanced\ndeduction under section 10A/ 10AA of the Act.\n\nOthers\n\n18. The learned AO has erred in law and facts, by initiating penalty\nproceedings under section 274 read with section 271(1