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

149, section 151 and section 153, in the case of\na person where a search is initiated under section 132 or books of\naccount, other documents or any assets are requisitioned under\nsection 132A after the 31st day of May, 2003, the Assessing Officer\nshall\n(a) issue notice to such person requiring him to furnish within such\nperiod

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

149, section 151 and section 153, in the case of\na person where a search is initiated under section 132 or books of\naccount, other documents or any assets are requisitioned under\nsection 132A after the 31st day of May, 2003, the Assessing Officer\nshall\n(a) issue notice to such person requiring him to furnish within such\nperiod

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

149, section 151 and section 153, in the case of\na person where a search is initiated under section 132 or books of\naccount, other documents or any assets are requisitioned under\nsection 132A after the 31st day of May, 2003, the Assessing Officer\nshall\n(a) issue notice to such person requiring him to furnish within such\nperiod

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

149, section 151 and section 153, in the case of\na person where a search is initiated under section 132 or books of\naccount, other documents or any assets are requisitioned under\nsection 132A after the 31st day of May, 2003, the Assessing Officer\nshall\n(a) issue notice to such person requiring him to furnish within such\nperiod

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

271(1)(c) of the Act, the same principle would equally apply to Section 270A of the Act d) No prejudice Caused to the assessee The Ld.DR submitted that prejudice has been caused to the assessee, as the assessee was given opportunity of being heard. Our Submission When the impugned penalty notice is invalid, the entire proceedings gets vitiated

ST.JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

271(1)(c) of the Act, the same principle would equally apply to Section 270A of the Act d) No prejudice Caused to the assessee The Ld.DR submitted that prejudice has been caused to the assessee, as the assessee was given opportunity of being heard. Our Submission When the impugned penalty notice is invalid, the entire proceedings gets vitiated

ST. JOSHEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

1) of the Act dated 29-09-2021, which has been\nissued for the search initiated on 07-11-2019, instead of section 271AAB(1A)\nof the Act and also without mentioning the specific limb is valid or not.\nIn fact, the submission of the Ld. DR supports the appellant's contention that\nthe impugned penalty notice was vague

ST. JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

1) of the Act dated 29-09-2021, which has been\nissued for the search initiated on 07-11-2019, instead of section 271AAB(1A)\nof the Act and also without mentioning the specific limb is valid or not.\nIn fact, the submission of the Ld. DR supports the appellant's contention that\nthe impugned penalty notice was vague

SREE NAVALADIAN FINANCE,NAMAKKAL vs. ITO, SALEM

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

SREE NAVALADIYAN FINANCE,SALEM vs. DCIT,CENTRAL CIRCLE, SALEM

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

SREENAVALADIAN FINANCE,SALEM vs. DCIT,CENTRALCIRCLE, SALEM

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

SREE NAVALADIYAN FINANCE,NAMAKKAL vs. DCIT, CENT CIRCLE, SALEM

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), CHENNAI, CHENNAI vs. BONDALAPATI SHIVAJI RAO, CHENNAI

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

149, Section 151 & Section 153, the Assessing Officer will issue notice as per provisions of 153A. The intention of the parliament for separate Sections for issuing notice u/s 143(2) and Section 153A is specifically different ITA No.1103/Chny/2023 (AY 2019-20) Bondalapati Shivaji Rao :: 27 :: and falls in particular circumstances mentioned in those particular Sections. It cannot be interlocated

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2, COIMBATORE, COIMBATORE vs. SRI MAHESWARY GRANITES (P) LTD, COIMBATORE

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 3054/Chny/2025 िनधा"रण वष"/Assessment Year:2015-16 The Asst. Commissioner Of Sri Maheswary Granites (P) Income Tax, Vs. Ltd., Central Circle – 2, Old No.115, New No.84, Coimbatore Bashyakarlu Road West, R.S.Puram, Coimbatore Pan: Aafcs 9118K (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. V. Aswathy, Jcit ""यथ" क" ओर से/Respondent By : Shri K.M.C.R. Mohan, Advocate सुनवाई क" तारीख/Date Of Hearing : 19.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 20.02.2026

Section 271(1)(c) was issued, initiating the proceedings of imposing the penalty. The assessee had sufficient notice of the action of imposing penalty. It was thus concluded, that there was no jurisdictional error or unjust exercise of power by the authority." III. To sumamrise, following points may also kindly be considered in this case: 1. The requirement of issuing

BONDALAPATI SHIVAJI RAO,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), CHENNAI, CHENNAI

In the result, appeal filed by the assessee stands allowed and\nappeal filed by the Revenue is dismissed

149,\nSection 151 & Section 153, the Assessing Officer will issue notice as per\nprovisions of 153A. The intention of the parliament for separate Sections\nfor issuing notice u/s 143(2) and Section 153A is specifically different\nITA No.1044/Chny/2023 (AY 2019-20)\nITA No.1103/Chny/2023 (AY 2019-20)\nBondalapati Shivaji Rao\n:: 27 ::\nand falls in particular circumstances mentioned in those particular

MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

271(1) (c) of the Act was also legal. \" (p. 787)\n7. Addl. CIT v. Badri Prasad Kashi Prasad [1993] 200 ITR 206 (All.) \"Held, that the\nlevy of penalty was based on the addition to income made by the Income-tax\nOfficer. The addition was deleted by the Tribunal. Hence, the Tribunal was justified\nin cancelling the penalty

M/S ENRICE ENTERPRISES PVT. LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

149 ITR 731 (Patna) 7. Sundaram Finance Limited Vs ACIT ( 2008) 99 taxmann.com 152 8.Jyothirmoy yamsani Vs DCIT ITA No 1519/Hyd/20l6 9. Manjeet kaur saran Vs DCIT ITA No 2639 to 2643/del/2017 10. HPCL Mittal Energy Vs Addl CIT 97 Taxmann.com 3 7.3.12 It is clear from.= penalty order that penalty of Rs.10,92,92,064/- has been levied

M/S ENRIA ENTERPRISES PVT. LTD,CHENNAI vs. DCIT. CENTRAL CIRCLE - 3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

149 ITR 731 (Patna) 7. Sundaram Finance Limited Vs ACIT ( 2008) 99 taxmann.com 152 8.Jyothirmoy yamsani Vs DCIT ITA No 1519/Hyd/20l6 9. Manjeet kaur saran Vs DCIT ITA No 2639 to 2643/del/2017 10. HPCL Mittal Energy Vs Addl CIT 97 Taxmann.com 3 7.3.12 It is clear from.= penalty order that penalty of Rs.10,92,92,064/- has been levied