MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

SUPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

SAPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

THANARAJ SUMATHI,MAYILADUTHURAI vs. ITO, WARD-1,, KUMBAKONAM

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that :-14-: ITA. No:2031/Chny/2025 "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases

CHAHIDA BEGAM,PUDUCHERRY vs. INCOME TAX OFFICER, WARD 3, PUDUCHERRY RANGE, INCOME TAX OFFICE, PUDUCHERRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

LOGANATHAN DHANDAPANI,CHENNAI vs. ACIT, NCC-3(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

FURSHANA GARMENTS,CHENNAI vs. ITO, NCW-11(3), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

reassessment then the same would equally apply for issuance of notice under Section 148 of the Act. (iii) The conclusion at the bottom of page 2 in paragraph 3 of the Office Memorandum that "Therefore, as provided in the scheme the notice under section 148 of the Act is issued on automated allocation of cases to the Assessing Officer based

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

reassessment being under section 148A, the subsequent proceedings was mandatorily required to be undertaken under the substituted provisions as laid down under the Finance Act, 2021. In the absence of which, we are constrained to hold that the procedure adopted by the respondent-Department is in contravention to the statute i.e. the Finance Act, 2021, at the first instance. Secondly

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. M/S CHOLAMANDALAM INVESTMENT & FINANCE COMPANY LTD, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

Reassessment • cannot be made Wherein it was held that assessing officer had allowed a deduction after making inquiries and considering the reply of the assessee, then the subsequent withdrawal of the same under Section 148 amounts to change of opinion which is invalid In this connection the Ld.AR placed reliance on below judicial precedents - The Hon’ble Bombay High Court

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

Reassessment • cannot be made Wherein it was held that assessing officer had allowed a deduction after making inquiries and considering the reply of the assessee, then the subsequent withdrawal of the same under Section 148 amounts to change of opinion which is invalid In this connection the Ld.AR placed reliance on below judicial precedents - The Hon’ble Bombay High Court

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

DCIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

DCIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A

DCIT, COIMBATORE vs. M/S. SENTHIL BUILDING MATERIAL MANUFACTURING CO. (P) LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

reassessments finalized for assessment years covered u/s.153A / 153C of the Act stand abated and AO has every right to proceed with the assessment even though there is no incriminating material available with the assessee found seized during the course of search. Hence, he argued that the legal position is very clear in view of the provisions of section 153A