NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

reassessment of the return of income of the appellant, within the time frame stipulated under the Act. In this case, the limitation period of six years for reopening the assessment for the year 2011~12 under section 147 of the Act, came to an end on 31.03.2018. In such circumstances, there is no requirement for this court to go into

SHEETAL V. BHAT,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

reassessment processing initiated by the Assessing Officer is not justified. 6. In the case on our hand, the facts are entirely different. In this case, after processing under Section 143(1) of the Act, the Assessing Officer received a report from the Deputy Director of Income Tax (Investigation)-II, Mumbai regarding bogus purchase of diamonds from M/s Daksh Diamonds, Mumbai

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

reassessment proceedings under Section 143(3) read with Section 264, the AO accepted the appellant’s explanations regarding cash sales and dropped the corresponding addition of ₹5,76,74,074/-. Arusuvai Food Processors Pvt. Ltd. :: 4 :: 6. Regarding trade advances, the assessee submitted confirmations, ledger accounts, and details of advances received from 36 parties during FY 2016–17. Notices under

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

133(6) to Tamil Nadu Mercantile Bank, Aranthangi Branch, seeking the bank statements of the deceased for the relevant year. On examination of the bank statements, the Assessing Officer found that cash deposits aggregating to Rs.4,14,52,028/- had been made. A show cause notice dated 20.03.2024 was therefore issued proposing to treat the entire cash deposits as unexplained

DHANUSHKODI HARIDEERTHAM,PUDUKOTTAI vs. ITO, INTL TAXNL WARD 2(1), CHENNAI

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

reassessment proceedings as per amended provisions of section 147 of the Act and completed the assessment under section 147 r.w.s.144C(13) of the Act and the same stands confirmed. Thus, Grounds No. 3 to 8 raised by the assessee are dismissed. 12. Ground 9 raised by the assessee in challenging the action of the Assessing Officer in making addition

MOHIT CHANDAK,CHENNAI vs. DCIT CENTRAL CIRCLE 3(3), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ Ita Nos.191 & 194/Chny/2025 िनधा=रण वष= /Assessment Years: 2017-18 & 2016-17

reassessment and those of the assessees on the other. Those directions, according to Mr. Vohra, were predicated on the Supreme Court seeking to obviate the specter of being deluged with more than 9000 appeals that would have come to be instituted before it assailing judgments and orders rendered by various High Courts. It was in order to avoid the aforesaid

MOHIT CHANDAK,CHENNAI vs. DCIT CENTRAL CIRCLE 3(3), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ Ita Nos.191 & 194/Chny/2025 िनधा=रण वष= /Assessment Years: 2017-18 & 2016-17

reassessment and those of the assessees on the other. Those directions, according to Mr. Vohra, were predicated on the Supreme Court seeking to obviate the specter of being deluged with more than 9000 appeals that would have come to be instituted before it assailing judgments and orders rendered by various High Courts. It was in order to avoid the aforesaid

ACIT, CENTRAL CIRCLE-3(2), CHENNAI vs. STN PROPERTIES PRIVATE LIMITED, CHENNAI

133, where the Assessing Officer is satisfied that (a) any money, bullion, Jewellery or other valuable article or thing seized or requisitioned, "belongs to, or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to," a person other than the person referred to in section 153A, then, the books

ACIT, CENTRAL CIRCLE-3(2), CHENNAI vs. STN PROPERTIES PRIVATE LIMITED, CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1647 & 1648/Chny/2024 िनधा"रण वष"/Assessment Year: 2012-13 & & 2014-15 The Assistant Commissioner Of Vs. Stn Properties Private Limited, 6/24, Eb Colony, 1St Main Road, Income Tax, Central Circle 3(2), Adambakkam, Tambaram, Chennai. Chennai 600 088. [Pan:Aakcs6317F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. E. Pavuna Sundari, Cit ""थ" की ओर से/Respondent By : Shri K.G. Raghunath, Advocate सुनवाई की तारीख/ Date Of Hearing : 18.09.2025 घोषणा की तारीख /Date Of Pronouncement : 10.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Both Dated 31.03.2024 Passed By The Ld. Commissioner Of Income Tax(Appeals)–20, Chennai For The Assessment Years 2012-13 & 2014-15. 2. Since Issues Raised In Both The Appeals Of The Revenue Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To Hear The Appeals Together & Pass Consolidated Order For The Sake Of Convenience.

133, where the Assessing Officer is satisfied that (a) any money, bullion, Jewellery or other valuable article or thing seized or requisitioned, "belongs to, or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to," a person other than the person referred to in section 153A, then, the books

DCIT, CHENNAI vs. PVP VENTURES LTD., CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

133 ITR 866. In that case, the assessee was to commence a hotel business and was to start a boarding and lodging house. One of the partners of the firm placed his building at the disposal of the firm as his capital contribution. Expenses amounting to Rs. 45,708 were incurred in installing lights, making the building more ventilated

DCIT, CHENNAI vs. PVP VENTURES LTD., CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

133 ITR 866. In that case, the assessee was to commence a hotel business and was to start a boarding and lodging house. One of the partners of the firm placed his building at the disposal of the firm as his capital contribution. Expenses amounting to Rs. 45,708 were incurred in installing lights, making the building more ventilated

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 147 of the Act was initiated but he was not justified in doing so, when no addition was made in respect of item for which notice of reopening was issued. In the present case, admittedly, ITA Nos.2280-83 /2018 :- 25 -: notice for re-assessment is issued for the purpose of disallowing the expenditure claimed being the payment made

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 147 of the Act was initiated but he was not justified in doing so, when no addition was made in respect of item for which notice of reopening was issued. In the present case, admittedly, ITA Nos.2280-83 /2018 :- 25 -: notice for re-assessment is issued for the purpose of disallowing the expenditure claimed being the payment made

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 147 of the Act was initiated but he was not justified in doing so, when no addition was made in respect of item for which notice of reopening was issued. In the present case, admittedly, ITA Nos.2280-83 /2018 :- 25 -: notice for re-assessment is issued for the purpose of disallowing the expenditure claimed being the payment made

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 147 of the Act was initiated but he was not justified in doing so, when no addition was made in respect of item for which notice of reopening was issued. In the present case, admittedly, ITA Nos.2280-83 /2018 :- 25 -: notice for re-assessment is issued for the purpose of disallowing the expenditure claimed being the payment made

MOSBACHER INDIA LLC,CHENNAI vs. ADDL. DIT, CHENNAI

In the result, the appeal is partly allowed in the terms indicated above

133 DTR 1 (Mum)] and Capsugel Healthcare Ltd Vs ACIT [(2015) 152 ITD 142 (Del)], is that all these precedents pertain to the situations in which applicability of Section 144C was not in slightest doubt and yet the Assessing Officer did not issue the draft assessment order- as is required to under the scheme of Section 144C. That

ACIT, NON-CORPORATE CIRCLE 7(1), CHENNAI, CHENNAI vs. LATE SHRI MAHAVEER BHANDARI, LEGAL HEIR- SMT. LALITHA BHANDARI, CHENNAI

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2785/Chny/2024 िनधा"रण वष"/Assessment Year : 2016-17 The Asst. Commissioner Of Late Shri Mahaveer Bhandari, Income Tax, Rep. By Legal Heir Smt. Lalitha Non-Corporate Circle 7(1), Vs. Bhandari, Chennai. 9, Athipattan Street, Mount Road, Chennai – 600 002. Pan: Aadpb 877A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Anitha, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri Ajith Kumar Chordia, Ca (Through Virtual Mode) सुनवाई क" तारीख/Date Of Hearing : 18.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 15.10.2025

133(6) was issued to EMIL to produce the valuation report to justify the revision of the asset value to Rs.76.79 crs. EMIL produced a valuation report of American Appraisal India Pvt. Ltd., a division of DUFF & PHELPS (D&P) submitted by Vinay Gupta. The appellant objected to the proposal of determining the Full Value of transaction

G.SHANMUGANATHAN,COIMBATORE vs. DCIT, COIMBATORE

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 2273/Chny/2015 िनधा"रण वष"/Assessment Year:2007-08 Shri G. Shanmuganathan, The Deputy Commissioner Of C/O S. Ramachandran, B. Com, Fca, Vs. Income Tax, Chartered Accountant, “Sethuram” Central Circle I, No. 15, Sundaresa Iyer Layout, Trichy Coimbatore. Road, Coimbatore 641 018. [Pan:Aqeps4036J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Ramachandran, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 22.06.2022 घोषणा की तारीख /Date Of Pronouncement : 15.07.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 15.10.2015 Relevant To The Assessment Year 2007-08. 2. Facts Are, In Brief, The Assessee Is A Partner In Firms Doing Export Business As Well As In Real Estate & Also Director In Textile Mills & Plantation Companies. There Was A Survey Conducted Under Section 133A Of The Income Tax Act, 1961 [“Act” In Short] In The Business

reassessment proceedings, the Assessing Officer noticed that the cost of purchase for the portion of the land belonging to the assessee was taken only at ₹.24,37,400/-, whereas, the total purchase price of 50.26 acres comes to ₹.2,99,91,600/- and the share of cost for 16.075 acres (including the Martin Land) as per the impounded document

GNANASEKARAN,CUDDALORE vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

Appeal of the assessee is partly allowed

Bench: Shri Mahavir Singh & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1807 & 1808/Chny/2024 िनधा"रण वष"/Assessment Years :2015-16 & 2016-17 Shri Gnanasekaran, The Assistant Commissioner 21, Thirowpathi Amman Koil Street , Vs. Of Income Tax, Cuddalore-607 002. Central Circle -1(1) Pan: Acvpg-5138-J Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment under section 153A on the amount by which the tax on the total income determined on the basis of such re-assessment or re-computation exceeds the tax on the total [income determined under sub-section (1) of section 143 or on the basis of the earlier assessment aforesaid.” 7. Even, the provisions of section 153A, when the procedure