DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

264, had taken the view that the subsidy in question was\na capital receipt not taxable under the Act. After the judgment of the Supreme\nCourt in Sahney Steel & Press Works Ltd.'s case (supra ), the Commissioner\nhad taken the view that the subsidy in question was a revenue receipt.\nTherefore, the instant case was a classic illustration of change

ARUSUVAI FOOD PROCESSORS PVT. LTD.,SALEM vs. DCIT, CIRCLE-1(1), SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

271(1) is concerned, the AO to record ‘satisfaction’ to levy penalty whereas in section 270A(1), the AO to give ‘direction’ for levy of penalty u/s.270A of the Act.] In this case, the AO has not given any such direction while passing the assessment order on Arusuvai Food Processors Pvt. Ltd. :: 7 :: 31.03.2022, pursuant to which, he levied penalty

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

264, had taken the view that the subsidy in question was\na capital receipt not taxable under the Act. After the judgment of the Supreme\nCourt in Sahney Steel & Press Works Ltd.'s case (supra ), the Commissioner\nhad taken the view that the subsidy in question was a revenue receipt.\nTherefore, the instant case was a classic illustration of change

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

264, had taken the view that the subsidy in question was\na capital receipt not taxable under the Act. After the judgment of the Supreme\nCourt in Sahney Steel & Press Works Ltd.'s case (supra ), the Commissioner\nhad taken the view that the subsidy in question was a revenue receipt.\nTherefore, the instant case was a classic illustration of change

A.G.T. ELECTRONICS LTD.,COIMBATORE vs. ADIT, CPC, , BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.2767/Chny/2024 िनधा8रण वष8 /Assessment Year: 2018-19

271, 271A and 272A - Commissioners (Appeals) to have the same powers as Appellate Assistant Commissioners in regard to imposition of penalty. Section 245 - Commissioners (Appeals) authorised to set off refund against tax remaining payable. Section 245A - Inclusion of Commissioner (Appeals) as an income-tax authority for purposes of Chapter XIXA relating to settlement of cases. AGT Electronics Ltd. :- 8 -: Sections

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

264 ITR 254 held the same view. In this case it was held that it cannot be said that a transaction, which takes place by way of cheque, is invariably sacrosanct. Once the assessee has proved the identity of his creditors, the genuineness of the transactions, and the creditworthiness of his creditors vis-à-vis the transactions which

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

264 ITR 254 held the same view. In this case it was held that it cannot be said that a transaction, which takes place by way of cheque, is invariably sacrosanct. Once the assessee has proved the identity of his creditors, the genuineness of the transactions, and the creditworthiness of his creditors vis-à-vis the transactions which

P. KRISHNAMURTHY,VILLUPURAM vs. ITO,WARD-2, VILLUPURAM

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Mahavir Singh

271, 271A and 272A - Commissioners (Appeals) to have the same powers as Appellate Assistant Commissioners in regard to imposition of penalty. Section 245 - Commissioners (Appeals) authorised to set off refund against tax remaining payable. Section 245A - Inclusion of Commissioner (Appeals) as an income-tax authority for purposes of Chapter XIXA relating to settlement of cases. Sections 247 to 251 - Provisions

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

P. KARUNANITHI,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

K. SADASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

K. BASKAR,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

R.EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

M. NATESAN,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

264 ITR 566) completed u/s 143(3) cannot be reopened mer completed u/s 143(3) cannot be reopened merely upon change of opinion change of opinion with reference to facts already available with the AO at the time of regular with reference to facts already available with the AO at the time of regular with reference to facts already available