DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

2), the issues qua which reassessment proceedings were initiated for non- deduction of TDS, were examined and considered by the Ld. AO. Thus it is crystal clear that full application of mind was made to the facts of the case surrounding determination of taxable income of the assessee. In view of the elaborate enquiries and discussions made in the assessment

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

2), the issues qua which reassessment proceedings were initiated for non- deduction of TDS, were examined and considered by the Ld. AO. Thus it is crystal clear that full application of mind was made to the facts of the case surrounding determination of taxable income of the assessee. In view of the elaborate enquiries and discussions made in the assessment

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

2), the issues qua which reassessment proceedings were initiated for non- deduction of TDS, were examined and considered by the Ld. AO. Thus it is crystal clear that full application of mind was made to the facts of the case surrounding determination of taxable income of the assessee. In view of the elaborate enquiries and discussions made in the assessment

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

2), the\nissues qua which reassessment proceedings were initiated for non-\ndeduction of TDS, were examined and considered by the Ld. AO. Thus it\nis crystal clear that full application of mind was made to the facts of the\ncase surrounding determination of taxable income of the assessee. In\nview of the elaborate enquiries and discussions made in the assessment

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

INDIA JAPAN LIGHTING PRIVATE LIMITED,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 4, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1427/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 V. M/S. India Japan Lighting Pvt. Ltd., The Pcit-4, No.1, Tiruvallur High Road, Chennai. Puduchatram B.O., Thirumazhisai, Tiruvallur-600 124. [Pan: Aaaci 2673 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

145,96,00,419/- (ii) Plant and machinery (@40%) Rs. 3,40,55,405/- and (iii) Plant and machinery (@15%) Rs. 75,49,73,854/-. In this regards provide following details/evidences:- a. Corresponding copies of accounts b. Copies of purchase bills and corresponding documentary evidence showing date of installation w.r.t additions of Rs. 10,00,000/- and above pertaining

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. BEACH MINERAALS COMPANY, TIRUNELVELI

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 145(3) of the Act. Accordingly, the books of accounts of the Appellant Firm for the FY(s) Accordingly, the books of accounts of the Appellant Firm for the FY(s) Accordingly, the books of accounts of the Appellant Firm for the FY(s) 2014-15 and 2015 15 and 2015-16 are hereby rejected. Thus, having rejected

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. BEACH MINERAALS COMPANY, TIRUNELVELI

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 145(3) of the Act. Accordingly, the books of accounts of the Appellant Firm for the FY(s) Accordingly, the books of accounts of the Appellant Firm for the FY(s) Accordingly, the books of accounts of the Appellant Firm for the FY(s) 2014-15 and 2015 15 and 2015-16 are hereby rejected. Thus, having rejected

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153C.\nThe power to undertake such an assessment would stand confined to\nthose years to which the material may relate or is likely to influence.\nAbsent any material that may either cast a doubt on the estimation of\ntotal income for a particular year or years, the AO would not be justified\n:: 41 ::\nITA Nos.1254, 1255, 1258, 1260/Chny/2025

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153C.\nThe power to undertake such an assessment would stand confined to\nthose years to which the material may relate or is likely to influence.\nAbsent any material that may either cast a doubt on the estimation of\ntotal income for a particular year or years, the AO would not be justified\n:: 41 ::\nITA Nos.1254, 1255, 1258, 1260/Chny/2025

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

reassessment, if any, relating to any\n assessment year falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance