INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

Section 11 of the Act.\n13. The Respondent craves leave to file additional grounds/arguments at the\ntime of hearing.\nGround No.1 is general in nature, which doesn't require any\nadjudication, so, dismissed.\nFirst, we will take up Ground Nos.2.1 to 2.4, wherein the Revenue\nhas mainly challenged the action of the Ld.CIT(A) holding that in the facts\nand

M/S.ENRICA 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

13. It is an admitted legal position that before initiating penalty, the assessee must be apprised of the precise charge brought against the assessee. The assessee must be told distinctly whether he has held guilty of having concealed the particulars of income or furnished inaccurate particulars of income. Section 274(1) provides for reasonable opportunity to be given

M/S ENRICA 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

13. It is an admitted legal position that before initiating penalty, the assessee must be apprised of the precise charge brought against the assessee. The assessee must be told distinctly whether he has held guilty of having concealed the particulars of income or furnished inaccurate particulars of income. Section 274(1) provides for reasonable opportunity to be given

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

reassessment\nor\nrecomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 11 ::\n8. Reading

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

reassessment or\nrecomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 11 ::\n8. Reading

SOUTHERN AGRIFURANE INDUSTRIES PVT.. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

reassessment or\nrecomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\"\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 11 ::\n8. Reading

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

reassessment or\nrecomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\"\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 11 ::\n8. Reading

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

13 SCC 369, the Supreme\nCourt overruled its decision in Dilip N. Shroff (supra). Thereafter, in CIT\nv. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322\n(SC) the Court clarified that Dilip N. Shroff (supra) stood overruled only\nto the extent that it imposed the requirement of mens rea in Section\n271(1)(c); however, no fault

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

13 SCC 369, the Supreme\nCourt overruled its decision in Dilip N. Shroff (supra). Thereafter, in CIT\nv. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322\n(SC) the Court clarified that Dilip N. Shroff (supra) stood overruled only\nto the extent that it imposed the requirement of mens rea in Section\n271(1)(c); however, no fault

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

13 SCC 369, the Supreme\nCourt overruled its decision in Dilip N. Shroff (supra). Thereafter, in CIT\nv. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322\n(SC) the Court clarified that Dilip N. Shroff (supra) stood overruled only\nto the extent that it imposed the requirement of mens rea in Section\n271(1)(c); however, no fault

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

13 SCC 369, the Supreme\nCourt overruled its decision in Dilip N. Shroff (supra). Thereafter, in CIT\nv. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322\n(SC) the Court clarified that Dilip N. Shroff (supra) stood overruled only\nto the extent that it imposed the requirement of mens rea in Section\n271(1)(c); however, no fault

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

13 SCC 369, the Supreme\nCourt overruled its decision in Dilip N. Shroff (supra). Thereafter, in CIT\nv. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322\n(SC) the Court clarified that Dilip N. Shroff (supra) stood overruled only\nto the extent that it imposed the requirement of mens rea in Section\n271(1)(c); however, no fault

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

13 SCC 369, the Supreme\nCourt overruled its decision in Dilip N. Shroff (supra). Thereafter, in CIT\nv. Reliance Petroproducts (P.) Ltd. [2010] 322 ITR 158/189 Taxman 322\n(SC) the Court clarified that Dilip N. Shroff (supra) stood overruled only\nto the extent that it imposed the requirement of mens rea in Section\n271(1)(c); however, no fault

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JSR INFRA DEVELOPERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub within the period of six assessment years referred to in sub- -section (1) is pending on the date of initiation of the search u/s. 132 of the Act shal pending on the date of initiation of the search

ADIT, CHENNAI vs. S A A ISPAHANI TRUST, CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunatha

section 13(1)(c). However, such a factual determination has admittedly not been carried out for A.Ys. 2001-02 and 2003-04. 30. Much reliance has been placed by the assessee on the reassessment

INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

In the result, appeals filed by the Revenue are dismissed\nand Cross Objections filed by the assessee are partly allowed

Section 11 of the Act.\n13. The Respondent craves leave to file additional grounds/arguments at the\ntime of hearing.\n5.\nGround No.1 is general in nature, which doesn't require any\nadjudication, so, dismissed.\n6.\nFirst, we will take up Ground Nos.2.1 to 2.4, wherein the Revenue\nhas mainly challenged the action of the Ld.CIT(A) holding that

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

reassessment or\nrecomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\"\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 11 ::\n8. Reading

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

reassessment\nrecomputation, as the case may be.]\n(2) The provisions of sub-section (1) as to the issue of notice shall be\nsubject to the provisions of section 151.\n\nor\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 11 ::\n8. Reading