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

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

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

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

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

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

6 -: reassessment proceedings initiated by issuance of notice under section 148A(b) in consequence to decision of Supreme Court in Union of India v. Ashish Agarwal [2022] 138 taxmann.com 64/286 Taxman 183/444 ITR 1 could be justified”? 7. For the adjudication of the legal issue, we have to see the legal pronouncements of the Hon’ble High Courts

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

6 -: reassessment proceedings initiated by issuance of notice under section 148A(b) in consequence to decision of Supreme Court in Union of India v. Ashish Agarwal [2022] 138 taxmann.com 64/286 Taxman 183/444 ITR 1 could be justified”? 7. For the adjudication of the legal issue, we have to see the legal pronouncements of the Hon’ble High Courts

D. SAIVENUGOPAL,CHENNAI vs. DCIT CORPORATE CIRCLE 6(1), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.107/Chny/2021 & 2417/Chny/2019 िनधा"रण वष"/Assessment Year: 2011-12 Shri D. Saivenugopal, Vs. The Deputy Commissioner Of Old No. 5, New No. 11, Sami Chetty Income Tax, Street, Pudupet, Chennai 600 002. Corporate Circle 6(1), Chennai 34. [Pan:Betps6046G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundaram, Ca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 15.03.2023 घोषणा की तारीख /Date Of Pronouncement : 24.03.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 27.06.2022 Relevant To The Assessment Year 2011-12 Passed Against Quantum Additions As Well As Rejection Of Rectification Petition Under Section 154 Of The Income Tax Act, 1961 [“Act” In Short].

reassessment 4 I.T.A. Nos.107/Chny/21 & 2417/Chny/19 proceedings under section 147 of the Act. 3.3 On the other hand, the ld. DR strongly supported the order passed by the ld. CIT(A) on this issue. 3.4 We have heard both the sides, perused the materials available on record and gone through the orders of authorities below. In this case, the return filed

SHRI D. SAIVENUGOPAL,,CHENNAI vs. DCIT, CORPORATE CIRCLE - 6 (1),, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.107/Chny/2021 & 2417/Chny/2019 िनधा"रण वष"/Assessment Year: 2011-12 Shri D. Saivenugopal, Vs. The Deputy Commissioner Of Old No. 5, New No. 11, Sami Chetty Income Tax, Street, Pudupet, Chennai 600 002. Corporate Circle 6(1), Chennai 34. [Pan:Betps6046G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundaram, Ca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 15.03.2023 घोषणा की तारीख /Date Of Pronouncement : 24.03.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 27.06.2022 Relevant To The Assessment Year 2011-12 Passed Against Quantum Additions As Well As Rejection Of Rectification Petition Under Section 154 Of The Income Tax Act, 1961 [“Act” In Short].

reassessment 4 I.T.A. Nos.107/Chny/21 & 2417/Chny/19 proceedings under section 147 of the Act. 3.3 On the other hand, the ld. DR strongly supported the order passed by the ld. CIT(A) on this issue. 3.4 We have heard both the sides, perused the materials available on record and gone through the orders of authorities below. In this case, the return filed

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)

6 -: Provisions made reducing amounts from contract receipts received from Indrani Patnaik 44,70,158 (Mahaparat site) Subcontract payments in Sirajuddin mines out of scope of work order disallowed. 9,19,55,168 Being aggrieved by the above additions, the assessee-company 7. preferred an appeal before ld. CIT(A) challenging the very validity of initiation of reassessment proceedings

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)

6 -: Provisions made reducing amounts from contract receipts received from Indrani Patnaik 44,70,158 (Mahaparat site) Subcontract payments in Sirajuddin mines out of scope of work order disallowed. 9,19,55,168 Being aggrieved by the above additions, the assessee-company 7. preferred an appeal before ld. CIT(A) challenging the very validity of initiation of reassessment proceedings

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)

6 -: Provisions made reducing amounts from contract receipts received from Indrani Patnaik 44,70,158 (Mahaparat site) Subcontract payments in Sirajuddin mines out of scope of work order disallowed. 9,19,55,168 Being aggrieved by the above additions, the assessee-company 7. preferred an appeal before ld. CIT(A) challenging the very validity of initiation of reassessment proceedings

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)

6 -: Provisions made reducing amounts from contract receipts received from Indrani Patnaik 44,70,158 (Mahaparat site) Subcontract payments in Sirajuddin mines out of scope of work order disallowed. 9,19,55,168 Being aggrieved by the above additions, the assessee-company 7. preferred an appeal before ld. CIT(A) challenging the very validity of initiation of reassessment proceedings

M. AGATHIYAN,THIRUVARUR vs. ITO, WARD-1,, TIRUVARUR

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.2521/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 Muthuvel Agathiyan, Vs. The Income Tax Officer, 18, Keela Fourth Street, Mannargudi Ward 1, Post, Mannargudi, Thiruvarur 614 001. Thiruvarur. [Pan:Aihpa1940J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Kaarthick, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 17.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. When The Appeal Was Taken Up For Hearing, The Ld. Ar Shri S. Kaarthick, Advocate Drew Our Attention To Ground No. K Raised In The Grounds Of Appeal & Submits That The Assessee Challenged

133(6) of the Act to the assessee to furnish the explanation regarding cash deposits. Since there was no response from the assessee, the Jurisdictional Assessing Officer issued notice under section 148 of the Act dated 30.03.2024. However, there was no response from the assessee. We note that in the assessment order, there is no mention about passing of order

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

6. Unaccounted Expenditure to Mr. Gopi of Rs.33,00,000/- in hands of appellant. Consequently, Grounds of appeal of appellant relating to the issues are Allowed. 7.21 Addition towards cash deposit: 7.21.1 The AO has noticed that there are cash deposits to the extent of Rs.11,47,500/- in Bank account of appellant (M/s. STN Properties Pvt Ltd) company during

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

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