RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

K. BASKAR,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

K. PARAMASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

K. SADASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

M. NATESAN,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

R.EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

P. KARUNANITHI,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

K. BASKAR,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

143(3) or under section 147 of the Act, then in such case 147 of the Act, then in such case, no notice under section 147 of the Act no notice under section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could

CHEYUR RAMAKRISHNAN,CHENNAI vs. ITO, BUSINESS WARD - 2(3), CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.334/Chny/2024. (िनधा"रणवष" / Assessment Year: 2007-2008) Cheyur Ramakrishnan Rajkumar, Vs. The Income Tax Officer, No.7/4, Meenakshi P.S Business Ward Ii(3) Sivasamy Road, Chennai. Mylapore, Chennai 600 004. [Pan: Accpr 4434P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. R. Subramanian, C.A., ""यथ" क" ओर से /Respondent By : Shri. Arv Srinivasan, Irs, Addl.Cit. सुनवाई क" तार"ख/Date Of Hearing : 19.06.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

reassessment is bad in law. 12. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the sale of agricultural land is exempt. 13. For that the Commissioner of Income Tax (Appeals) erred in confirming the action of the Assessing Officer in considering the sale of agricultural land as income from capital gain. 14. For that the Commissioner

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

143(3)", "Section 11", "Section 11(2)", "Section 11(4A)", "Section 2(15)", "Section 139(5)", "Section 153", "Section 12A" ], "issues": "The primary issues were whether the reassessment

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 proceedings are not valid since the Assessing Officer is barred in initiating the proceedings under section 148 when the time for issuance of notice under section 143

NETHERLANDS OPERATING COMPANY B.V.,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, INT. TAXATION 2(1), CHENNAI, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1198/Chny/2023 िनधा"रणवष"/Assessment Year: 2010-11 V. Netherlands Operating Company B.V. The Acit, Rmz Millenia (Phase-1), International Taxation -2(1), Business Park, 4Th Floor, Campus 1C, Chennai. 11, Dr. M.G.R. Road, Kandanchavadi, Perungudi, Chennai-600 096. [Pan: Aabcl 0573 D] (अपीलाथ"/Appellant) (""यथ"/Respondent)

143 is not a charging section and thus cannot be said to be substantive. It is a procedural section. (x) Without prejudice to the above, Non-compliance with the procedural law is merely a procedural irregularity, which can be cured unlike the defects of inherent lack of jurisdiction in an authority to pass an order which of course will

ACIT , CENTRAL CIRCLE - 3 (3), CHENNAI vs. M/S LAND MARVEL HOMES , CHENNAI

In the result, appeal filed by the Revenue is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1055/Chny/2022 िनधा"रणवष" / Assessment Year: 2012-13 M/S. Land Marvel Homes, The Acit, V. 45-47, Old No. 22-23, Central Circle -3(3), 3Rd Floor, 1St Main Road, Chennai. Gandhi Nagar, Adyar, Chennai – 600 020. [Pan:Aabfl-4387-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. V. Nandakumar, Cit ""यथ"क"ओरसे/Respondent By : Shri. T. Banusekar, Advocate & Shri. Yeshwanth Kumar, Ca सुनवाई क" तारीख/Date Of Hearing : 06.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.07.2024 आदेश /O R D E R

143(2) is liable to be issued and the assessment completed on or before 31.3.2001. This was not done in the present case. Subsequently, a notice under section 148 has been issued on 9.12.2002 under section 148 of the Income Tax Act taking advantage of the now extended limitation of four years to re-assess income on the basis