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 25.02.2019, wherein, Shri V. Rajendran, Chairman of the assessee Trust stated on oath that the Trust’s activities were limited to the sale of books, notebooks and uniforms run by DAV School Trust. The said information reveals that

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order 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 Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

5. Ground No. 2 (2.1 to 2.5) raised by the assessee in challenging the action of the Id. CIT(A) in not considering the submissions of the assessee in respect of validity of reassessment order passed under section 147 r.w.s. 144B of the Income Tax Act, 2961 ["Act” in short] in the facts and circumstances of the case

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

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

5-2001 proposing to ITA Nos.2578 to 2580/chny/2017 :- 38 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells reassess petitioner-assessee at higher rate in view of the presumptive rate prescribed under section 44AD has been sustained. In the case of Dr. Sahib Ram Giri v. ITO, (2008) 301 ITR 294 (Raj), the reassessment proceedings were initiated after recording reasons in writing

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

5-2001 proposing to ITA Nos.2578 to 2580/chny/2017 :- 38 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells reassess petitioner-assessee at higher rate in view of the presumptive rate prescribed under section 44AD has been sustained. In the case of Dr. Sahib Ram Giri v. ITO, (2008) 301 ITR 294 (Raj), the reassessment proceedings were initiated after recording reasons in writing

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

5-2001 proposing to ITA Nos.2578 to 2580/chny/2017 :- 38 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells reassess petitioner-assessee at higher rate in view of the presumptive rate prescribed under section 44AD has been sustained. In the case of Dr. Sahib Ram Giri v. ITO, (2008) 301 ITR 294 (Raj), the reassessment proceedings were initiated after recording reasons in writing

SAKTHI POULTRY FARM,SALEM vs. ITO, SALEM

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

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

133A of the Act on 18.02.2005 from Shri S. Periasamy, Managing Partner of the assessee firm while finalizing the assessment under section 143(3) of the Act, thereby income escaped assessment was not brought to tax by the Assessing Officer, which lead to reopening of assessment under section 147 of the Act. 5 I.T.A. Nos.1284 & 1285/M/17 5.1 With regard

SAKTHI POULTRY FARM,SALEM vs. ITO, SALEM

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

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

133A of the Act on 18.02.2005 from Shri S. Periasamy, Managing Partner of the assessee firm while finalizing the assessment under section 143(3) of the Act, thereby income escaped assessment was not brought to tax by the Assessing Officer, which lead to reopening of assessment under section 147 of the Act. 5 I.T.A. Nos.1284 & 1285/M/17 5.1 With regard

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

5. The Ld. CIT(A) has relied on the decision of the Hon'ble Tribunal, Chenna in the case of Arunachalam Srinivasan in ITA No. 1527/Chny/2023 dated 31/05/2024 for AY 2014-15 to hold the satisfaction bad. However, the decision of the Hon 'ble Tribunal has not been accepted and further appeal to the Hon'ble High Court Madras

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

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

5 -: proceedings can be initiated in terms of Section 153C of the Act. Thus, the impugned notice came to be issued by the 2nd respondent, illegally and in contrary to Sub Section (3) of Section 153C of the Act. 31. On the other hand, it was contended by the respondents that the first proviso to Section 153C

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

5 -: proceedings can be initiated in terms of Section 153C of the Act. Thus, the impugned notice came to be issued by the 2nd respondent, illegally and in contrary to Sub Section (3) of Section 153C of the Act. 31. On the other hand, it was contended by the respondents that the first proviso to Section 153C

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

5 -: proceedings can be initiated in terms of Section 153C of the Act. Thus, the impugned notice came to be issued by the 2nd respondent, illegally and in contrary to Sub Section (3) of Section 153C of the Act. 31. On the other hand, it was contended by the respondents that the first proviso to Section 153C

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

5 -: proceedings can be initiated in terms of Section 153C of the Act. Thus, the impugned notice came to be issued by the 2nd respondent, illegally and in contrary to Sub Section (3) of Section 153C of the Act. 31. On the other hand, it was contended by the respondents that the first proviso to Section 153C

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

5 -: proceedings can be initiated in terms of Section 153C of the Act. Thus, the impugned notice came to be issued by the 2nd respondent, illegally and in contrary to Sub Section (3) of Section 153C of the Act. 31. On the other hand, it was contended by the respondents that the first proviso to Section 153C

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

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