ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

127 - Order\nC.No.440/PCIT/MDU-1/2020-21/\nING\nDate:03.12.2020\nकोष मूली द\nRENT\nNOTIFICATION NO. 11/2020-21\nTAX DEPA\nThe CBDT vide order u/s 119 of the I.T.Act 1961 in F.No. 187/3/202-ITA-I\ndated 13/08/2020 and subsequent letter in F.No. 187/3/2020-ITA-I dated 18/09/2020\nhas directed all cases u/s 153A/153C and 133A cases having impounded materials,\nhitherto assessed in assessment circles/ wards will henceforth

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)

127 of the Act dated 01.03.2021. It is an admitted fact that, the AO has recorded his satisfaction note on 12.03.2021 and thereafter initiated proceedings u/s.153C of the Act albeit for AYs 2013-14 to 2018-19 by issuing notice u/s.153C of the Act dated 12.03.2021. For the relevant AY 2019-20, the AO is noted to have issued notice

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

127 of the Act dated\n01.03.2021. It is an admitted fact that, the AO has recorded his\nsatisfaction note on 12.03.2021 and thereafter initiated proceedings\nu/s.153C of the Act albeit for AYs 2013-14 to 2018-19 by issuing notice\nu/s.153C of the Act dated 12.03.2021. For the relevant AY 2019-20, the\nAO is noted to have issued notice

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

reassessment in consequence of the impugned notice would be in consequence of, or to give effect to, any findings of the Tribunal in Boudier Christian's case. A direction or finding as contemplated by section 153(3)(ii) must be a finding necessary for the disposal of a particular case, that is to say, in respect of the particular assessee

DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE-10, CHENNAI vs. ARUNCHALAM VEERAIAH, CHENNAI

In the result, the revenue's appeal is dismissed and allow the cross objection\nof the assessee

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Jagadish\N\Nआयकर अपील सं./ Ita No.2320/Chny/2024\N& C.O.No.78/Chny/2024\N(In Ita No.2320/Chny/2024)\N(निर्धारणवर्ष / Assessment Year: 2011-2012)\N\Nthe Deputy Commissioner Of\Nincome Tax,\Ncorporate Circle 10,\Nchennai\N(Appellant)\Nvs. Arunchalam Veeraiah,\Nno.34, 14B, Beach Home Avenue,\Nbesant Nagar,\Nchennai 600 090.\N[Pan No.Aaipa 9044Q]\N(Respondent/Cross Objector)\N\Nassessee By\N: Shri S. Sridhar, Advocate\Nrevenue By\N: Shri. P.K. Senthil Kumar, Addl. Cit.\N\Nसुनवाई की तारीख/Date Of Hearing\N: 30.01.2025\Nघोषणा की तारीख / Date Of Pronouncement : 14.02.2025\N\Nआदेश / Order\N\Nmanu Kumar Giri ()\N\Nthe Appeal Of The Revenue & Cross Objection By The Assessee Are Arising\Nout Of The Order Dated 21.06.2024 Of The Commissioner Of Income Tax (Appeals),\Nnfac, Delhi (In Short The `Ld. Cit(A)"). The Assessment Order U/S 144 R.W.S 147 Of\Nthe Income Tax Act, 1961 (Hereinafter The 'Act'), Was Passed Vide Order Dated\N19.12.2019.\N\N2.\Nthe Registry Has Noted Delay Of 14 Days In Filing The Appeal By The Revenue.\Nconsidering Reasons Stated In The Affidavit By The Revenue, We Condone The Delay\Nand Admit The Appeal For Adjudication.\N\N3.\Ngrounds Of Appeal Filed By The Revenue Are As Under:\N\N\"1. The Order Of The Cit (A) Is Contrary To The Facts & Circumstances Of The Case\Nand Provisions Of Income Tax Act 1961.\N2. The Id. Cit (A) Erred To Hold That The Notice U/S 148 Was Sent For The Service\Nafter 10 Months Delay & Holding The Assessment Order Dated 19.12.2019 As Time\Nbarred.\N2.

2 above. Section 153 of the\nI.T.Act 1961 tates that \"No Order of assessment or reassessment or\nrecomputation shall be made u/s.147 after the expiry of nine months from the\nend of the financial year in which the notice uls.148 was served\" In the instant\ncase, even though the notice was issued on 28.03.2018 the notice could be\nserved only

K.SUGANTHI,CHENNAI vs. ACIT CIRCLE 1, SALEM

In the result, the appeal filed by the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 127. As a consequence, the reassessment order passed u/s.143(3) r.w.s.147 is without jurisdiction, bad in law and illegal. 2.2 When the appellant’s address as per PAN is in Salem and when the appellant’s jurisdictional Assessing Officer is ACIT, Circle 1, Salem, the notice u/s.148 dated 31.03.2017 issued by the ACIT, Non-Corporate Circle 10(1), Chennai

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE,TRICHY vs. MARAGATHAMANI SHANMUGAM, KARUR

In the result, all the three appeals of the Revenue are dismissed

127 and 213, 214, 215 / Chny/2023 dated 03.04.2024\niii) DCIT Central Circle-2(4) Chennai vs Vaithialingam in ITA No.\n604,605,606/chny/2023 dated03.04.2024\niv) DCIT Central Circle-2(4) Chennai vs Vivek papisetty in ITA No. 211, 212\nand 405/Chny/2023 dated 02.04.2024\nv) DCIT Central Circle-2(4) Chennai vs P Ram Mohan Rao in ITA No.\n223

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. LIFE LINE AUTO FINANCE, KARUR

127 and 213, 214, 215 /\nChny/2023 dated 03.04.2024\niii) DCIT Central Circle-2(4) Chennai vs Vaithialingam in ITA No.\n604,605,606/chny/2023 dated03.04.2024\n:-9-:\nITA. No:1630/Chny/2025\niv) DCI Central Circle-2(4) Chennai vs Vivek Papisetty in I No.\n211, 212 and 405/Chny/2023 dated 02.04.2024\nv) DCI Central Circle-2(4) Chennai vs P Ram Mohan

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, TRICHY, INCOME TAX OFFICE, TRICHY vs. KARUPPANNA GOUNDER PALANIAPPA GOUNDER MARIAPPAN, KARUR

In the result, all the three appeals of the Revenue are dismissed

127 and 213, 214, 215 / Chny/2023 dated 03.04.2024\niii) DCIT Central Circle-2(4) Chennai vs Vaithialingam in ITA No.\n604,605,606/chny/2023 dated03.04.2024\niv) DCIT Central Circle-2(4) Chennai vs Vivek papisetty in ITA No. 211, 212\nand 405/Chny/2023 dated 02.04.2024\nv) DCIT Central Circle-2(4) Chennai vs P Ram Mohan Rao in ITA No.\n223

DCIT, CENTRAL CIRCLE-2.4, CHENNAI vs. SHRI P. RAMA MOHAN RAO, CHENNAI

Accordingly, cross- objections for AYs 2015-16 and 2016-17 stands dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jmand Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.223/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.224/Chny/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.225/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Dcit Shri P. Rama Mohan Rao बनाम Central Circle-2(4) No.17/184, Y Block, First Street, 6Th Main Road, Anna Nagar, Chennai. / Vs. Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpr-2074-N (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. Cross Objection No.10/Chny/2023 (In Ita No.223/Chny/2023) (िनधा"रण वष" / Assessment Year: 2015-16) & 5. Cross Objection No.11/Chny/2023 (In Ita No.224/Chny/2023) (िनधा"रण वष" / Assessment Year: 2016-17) & 6. Cross Objection No.12/Chny/2023 (In Ita No.225/Chny/2023) (िनधा"रण वष" / Assessment Year: 2017-18 बनाम/ Dcit Shri P. Rama Mohan Rao No.17/184, Y Block, First Street, Central Circle-1(4)

2 days of recording thereof. Such retracted statement, on standalone basis, could not justify impugned additions in the hands of the assessee. Another fact is that the assessee was also subjected to search action wherein the department is unable to recover any incriminating material which would establish that the assessee was in receipt of such unaccounted money as alleged

DCIT, CENTRAL CIRCLE-2.4, CHENNAI vs. SHRI P. RAMA MOHAN RAO, CHENNAI

Accordingly, cross- objections for AYs 2015-16 and 2016-17 stands dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jmand Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.223/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.224/Chny/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.225/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Dcit Shri P. Rama Mohan Rao बनाम Central Circle-2(4) No.17/184, Y Block, First Street, 6Th Main Road, Anna Nagar, Chennai. / Vs. Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpr-2074-N (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. Cross Objection No.10/Chny/2023 (In Ita No.223/Chny/2023) (िनधा"रण वष" / Assessment Year: 2015-16) & 5. Cross Objection No.11/Chny/2023 (In Ita No.224/Chny/2023) (िनधा"रण वष" / Assessment Year: 2016-17) & 6. Cross Objection No.12/Chny/2023 (In Ita No.225/Chny/2023) (िनधा"रण वष" / Assessment Year: 2017-18 बनाम/ Dcit Shri P. Rama Mohan Rao No.17/184, Y Block, First Street, Central Circle-1(4)

2 days of recording thereof. Such retracted statement, on standalone basis, could not justify impugned additions in the hands of the assessee. Another fact is that the assessee was also subjected to search action wherein the department is unable to recover any incriminating material which would establish that the assessee was in receipt of such unaccounted money as alleged

DCIT, CENTRAL CIRCLE-2.4, CHENNAI vs. SHRI P. RAMA MOHAN RAO, CHENNAI

Accordingly, cross- objections for AYs 2015-16 and 2016-17 stands dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jmand Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपीलसं./ Ita No.223/Chny/2023 (िनधा"रणवष" / Assessment Year: 2015-16) & 2. आयकरअपीलसं./ Ita No.224/Chny/2023 (िनधा"रणवष" / Assessment Year: 2016-17) & 3. आयकरअपीलसं./ Ita No.225/Chny/2023 (िनधा"रणवष" / Assessment Year: 2017-18) Dcit Shri P. Rama Mohan Rao बनाम Central Circle-2(4) No.17/184, Y Block, First Street, 6Th Main Road, Anna Nagar, Chennai. / Vs. Chennai-600 040. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafpr-2074-N (अपीलाथ"/Appellant) : (!"थ" / Respondent) & 4. Cross Objection No.10/Chny/2023 (In Ita No.223/Chny/2023) (िनधा"रण वष" / Assessment Year: 2015-16) & 5. Cross Objection No.11/Chny/2023 (In Ita No.224/Chny/2023) (िनधा"रण वष" / Assessment Year: 2016-17) & 6. Cross Objection No.12/Chny/2023 (In Ita No.225/Chny/2023) (िनधा"रण वष" / Assessment Year: 2017-18 बनाम/ Dcit Shri P. Rama Mohan Rao No.17/184, Y Block, First Street, Central Circle-1(4)

2 days of recording thereof. Such retracted statement, on standalone basis, could not justify impugned additions in the hands of the assessee. Another fact is that the assessee was also subjected to search action wherein the department is unable to recover any incriminating material which would establish that the assessee was in receipt of such unaccounted money as alleged

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY MOOLIMANGALAM VAISHNAVA PRIYA, CHENNAI

In the result, all the three appeals of the Revenue are dismissed

127 and 213, 214, 215 / Chny/2023 dated 03.04.2024\niii) DCIT Central Circle-2(4) Chennai vs Vaithialingam in ITA No.\n604,605,606/chny/2023 dated03.04.2024\niv) DCIT Central Circle-2(4) Chennai vs Vivek papisetty in ITA No. 211, 212\nand 405/Chny/2023 dated 02.04.2024\nv) DCIT Central Circle-2(4) Chennai vs P Ram Mohan Rao in ITA No.\n223