D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

reassessment based on fresh tangible material obtained during survey under section 133A of the Act on 10 I.T.A. Nos.1667 to 1670/Chny/24

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

133A. (b) His next submission was that in any event, during the survey, no incriminating material was found which may have led the revenue to exercise power under section 153C read with section 153A. 4. He contended that even when assessment is made on the basis of a search under section 132 or a requisition made under section 132A

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

133A. (b) His next submission was that in any event, during the survey, no incriminating material was found which may have led the revenue to exercise power under section 153C read with section 153A. 4. He contended that even when assessment is made on the basis of a search under section 132 or a requisition made under section 132A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassess the total income of such other person, (the assessee in this case) in the manner provided in section 153A of the Act. Further amendment was brought in by Finance Act, 2017, wherein the scope of assessment u/s.153A/153C of the Act has been enlarged to seventh (7th) to tenth (10th) year, on satisfaction of another condition-precedent

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

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

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

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 133A(3)(iii) of the Act clarifies beyond doubt that the material collected and the statement recorded during, the survey is not a conclusive piece of evidence by itself. 15. In any event, it is settled law that though an admission is extremely important piece of evidence, it cannot be said to be conclusive and it is open

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 133A(3)(iii) of the Act clarifies beyond doubt that the material collected and the statement recorded during, the survey is not a conclusive piece of evidence by itself. 15. In any event, it is settled law that though an admission is extremely important piece of evidence, it cannot be said to be conclusive and it is open

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment based on fresh\ntangible material obtained during survey under section 133A of the Act on\n25.02.2019, wherein, Shri V. Rajendran

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment based on fresh\ntangible material obtained during survey under section 133A of the Act on\n25.02.2019, wherein, Shri V. Rajendran

DEPUTY COMMISSIONER OF INCOME TAX, SALEM vs. GOVINDA RAJULU SRINIVASAN, SALEM

In the result, appeal of the Revenue is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1250/Chny/2025 Assessment Years: 2017-18 Deputy Commissioner Of Income Govinda Rajulu Srinivasan, Tax No.21, Chinna Ezhuthukkara Street, Circle-1, Shevapet, Salem, Salem Tamil Nadu-636 002. [Pan: Avmps5356G] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.Bhupendran, Advocate, प्रत्यर्थी की ओर से /Revenue By : Ms.C.Yamuna, Cit. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 09.10.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

reassessment or recomputation under section 147, and subject to the provisions of section 148A. the Assessing Officer shall serve on the assessee a notice, along with a copy of the order passed, if required, under clause (d) of section 148A, requiring him to furnish within such period, as may be specified in such notice, a return of his income

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

133A,\nit may, in any proceeding under this Act, be presumed – (ii) that the\ncontents of such books of account and other documents are true.\n3. The Ld.CIT(A) erred in giving relief to the assessee by observing that\nmaterial found in a third party premise was not in the handwriting of the\nassessee thereby ignoring section

SUNDARASAMY KOHILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore

EVERYEADY SPINNING MILLS PRIVATE LIMITED,TRIUPUR vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore

ARUNRAJ,ERODE vs. ACIT, CENTRAL CIRC 3, CBE, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore

SEETHADEVI,ERODE vs. ACIT, CENTRAL CIRCLE-3, , COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore

KJS JEWELLERS PRIVATE LIMITED,SALEM vs. ACIT CENTRAL CRICLE SALEM, SALEM

In the result, all the appeals of the assessee for AY 2017-18 to AY

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3334, 3335, 3336, 3337 & 3338/Chny/2025 िनधा$रण वष$ /Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21 & 2021-22

reassessment, if any, relating to any assessment year falling within the period of six assessment years and for the relevant assessment year or years referred to in this sub-section, 153C(1) pending on the date of initiation of the search under Section 132 or making of requisition under Section 132A, as the case may be, shall abate. Therefore