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

u/s 271(1)(c) of the IT Act. The ld.\nAO imposed penalty by invoking the Explanation 5A to section\n271(1)(c) of the Act, which has been confirmed by Id. CIT (A) by\nconsidering the judgement of Hon'ble Supreme Court in the case of MAK\nData Pvt. Ltd. (supra). But for imposing the penalty under Explanation

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

u/s 271(1)(c) of the IT Act. The\nAO imposed the penalty by invoking the Explanation 5A to section\n271(1)(c) of the Act, which has been confirmed by Id. CIT (A) by\nconsidering the judgement of Hon'ble Supreme Court in the case of MAK\nData Pvt. Ltd. (supra). But for imposing the penalty under Explanation

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

u/s 271(1)(c) of the IT Act. The ld.\nAO imposed penalty by invoking the Explanation 5A to section\n271(1)(c) of the Act, which has been confirmed by ld. CIT (A) by\nconsidering the judgement of Hon'ble Supreme Court in case of MAK\nData Pvt. Ltd. (supra). But for imposing the penalty under Explanation

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

u/s 271(1)(c) of the IT Act. The ld.\nAO imposed penalty by invoking the Explanation 5A to section\n271(1)(c) of the Act, which has been confirmed by Id. CIT (A) by\nconsidering the judgement of Hon'ble Supreme Court in the case of MAK\nData Pvt. Ltd. (supra). But for imposing the penalty under Explanation

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. 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

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

u/s 271(1)(c) of the IT Act. The ld.\nAO imposed the penalty by invoking the Explanation 5A to section\n271(1)(c) of the Act, which has been confirmed by ld. CIT (A) by\nconsidering the judgement of Hon'ble Supreme Court in the case of MAK\nData Pvt. Ltd. (supra). But for imposing the penalty under Explanation

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

154 of the Act by the appellation towards rectification of\nmistakes apparent from the order.\n2. The Ld. AO erred in computing undisclosed income as assessed vide the\nsearch assessment order u/s 153A of the Act dated 29-09-2021, without giving\neffect to the application of income as claimed u/s 11 of the Act.\n3. Without prejudice

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

u/s 132 of the Act,\nunearthed unaccounted cash transactions, which warrants penalty of 60%.\nInvalidating the notice on technical issue, would defeat the intent of the\nlegislature.\ne) Holistic Interpretation of the Notice\nThe Ld. DR submitted that the notice must be read in conjunction with the\nassessment order, penalty order and search proceedings.\nf) Assessee's Conduct Warrants Penalty

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

154 of the Act for the subject AY 2017-18.\nConsidering the above, it is most respectfully and humbly prayed that Your Authority\nmay be pleased to uphold the decision of CIT(A) and dismiss the Grounds of Appeal\nfiled by the AO and/or provide such other relief as the case deems fit, for which act of\njustice, the Respondent

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1), CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1), CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1),, CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1), CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1), CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1), CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1),, CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated

SRINIVASAN CHANDRASEKARA CHANDILYA,CHENNAI vs. ACIT, NCC-7(1), CHENNAI

In the result, the appeal of the assesse is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1478, 1479, 1480, 1481, 1482, 1483, 1484, 1485, 1486 & 1487/Chny/2024 निर्धारण वर्ा /Assessment Years: 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17 Srinivasan Chandrasekara Chandilya Asst. Commissioner Of Income Tax, K.V.Ranganathan & Co., Non-Corporate Circle-7(1), No.113/574, Ii Floor, Congress Chennai. Building, Tenampet, Chennai [Pan: Aaupc3096J]

154. Thus as the assesse has accepted OGE the income determined therein cannot be disputed now. The controversy raised qua lack of clarity as to whether assesse had concealed its income or had furnished inaccurate particulars thereof, is also not supported by facts as the Ld. AO in the assessment order dated ITA No.1478 & 9 others/Chny/2024 :- 6 -: 13.12.2019 clearly indicated