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 149(1)(b) of the\nAct.\n17. Our above view is noted to be supported by the Hon'ble Delhi High\nCourt in the case of KAD Housing Pvt Ltd v. DCIT (supra) wherein it\nwas held that, an action of reassessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Section 149(1)(b) of the\nAct.\n17. Our above view is noted to be supported by the Hon'ble Delhi High\nCourt in the case of KAD Housing Pvt Ltd v. DCIT (supra) wherein it\nwas held that, an action of reassessment

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 149(1)(b) of the\nAct.\n17. Our above view is noted to be supported by the Hon'ble Delhi High\nCourt in the case of KAD Housing Pvt Ltd v. DCIT (supra) wherein it\nwas held that, an action of reassessment

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 149(1)(b) of the\nAct.\n17. Our above view is noted to be supported by the Hon'ble Delhi High\nCourt in the case of KAD Housing Pvt Ltd v. DCIT (supra) wherein it\nwas held that, an action of reassessment

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

b) of sub- section (1) of this section or section 153A or section 153C, as the case section (1) of this section or section 153A or section 153C, as the case section (1) of this section or section 153A or section 153C, as the case may be, as they stood immediately before the co may be, as they stood immediately

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

b) of sub- section (1) of this section or section 153A or section 153C, as the case section (1) of this section or section 153A or section 153C, as the case section (1) of this section or section 153A or section 153C, as the case may be, as they stood immediately before the co may be, as they stood immediately

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 149(1)(b) of the\nAct.\n17. Our above view is noted to be supported by the Hon'ble Delhi High\nCourt in the case of KAD Housing Pvt Ltd v. DCIT (supra) wherein it\nwas held that, an action of reassessment

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JSR INFRA DEVELOPERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

149, 151 and 153. 8.2 Having noticed the above, we may also refer t 8.2 Having noticed the above, we may also refer to the second and the third o the second and the third proviso to section 153A(1). For the sake of convenience, the second and third proviso to section 153A(1). For the sake of convenience

KRISHNAMOORTHY HARIOBHASKAR,TIRUPPUR vs. ITO, WARD-2(1), TIRUPPUR

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.1506/Chny/2023 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri Krishnamoorthy Haribhaskar, The Income Tax Officer, 35/11, Poochakkadu, 2Nd Street, Ward-2(1), Mangalam Road, Tirupur-641 604. Tirupur. [Pan: Abkph 9735 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

b) of sub-section (1) of this Section or Section 153A or Section 153C, as the case may be, as they stood immediately before the commencement of the Finance Act, 2021". 28 Section has to be interpreted so as to give meaning to all the words/phrases used in the Section and it should not be interpreted in such

JESUDASON BIJI ,CHENNAI vs. OFFICE OF INCOME TAX OFFICER INT. TAXN WARD1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

b) subsequently a notice has been served under clause (ii) of sub-section (2) of section 143 after the expiry of twelve months specified in the proviso to clause (ii) of sub-section (2) of section 143, but before the expiry of the time limit for making the assessment, reassessment or recomputation as specified in sub-section (2) of section

THIRUMOORTHY REVATHI,COIMBATORE vs. ITO, NCW-4(4), COIMBATORE

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

Bench: Shri George George Kand Ms Padmavathy Sआयकर अपील सं./Ita No.: 3188/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16

Section 149(1)(b) of the new regime stipulates that the Revenue can issue reassessment notices for past assessment years

HYUNDAI TRANSYS INC,REPUBLIC OF KOREA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.338/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Hyundai Transys Inc, Vs. The Deputy Commissioner Of 105, Sindang Income Tax, 1 Ro Seongyeon, International Tax, Myeon, Corporate Circle 1(1) Seosan, Ccn 356851 Chennai. Korea.

reassessment notices are to be dealt with as under: (i) AY 2013-14, AY 2014-15 and AY 2015-16: Fresh notice under section 148 of the Act can be issued in these cases, with the approval of the specified authority, only if the case falls under clause (b) of sub-section (1) of section 149

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

reassessment notices are to be dealt with as under: (i) AY 2013-14, AY 2014-15 and AY 2015-16: Fresh notice under section 148 of the Act can be issued in these cases, with the approval of the specified authority, only if the case falls under clause (b) of sub-section (1) of section 149

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

reassessment notices are to be dealt with as under: (i) AY 2013-14, AY 2014-15 and AY 2015-16: Fresh notice under section 148 of the Act can be issued in these cases, with the approval of the specified authority, only if the case falls under clause (b) of sub-section (1) of section 149

CLAN LABORATORIES PVT. LTD.,CHENNAI vs. DCIT, CORPORATE WARD-1(2), CHENNAI

In the result the appeal of the assessee is allowed

b) Section 149 of the new regime provides three crucial benefits to the\nassessees : (i) the four-year time limit for all situations has been reduced to\nthree years; (ii) the first proviso to section 149 ensures that re-assessment for\nprevious assessment years cannot be undertaken beyond six years; and (iii)\nthe monetary threshold of Rupees fifty lakhs will

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

VIVEK RAMASWAMY PUTHUCODE,CHENNAI vs. ITO, INTERNATIONAL TAXATION WARD-2(1), CHENNAI

The appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.3731/Chny/2025 िनधा&रण वष& /Assessment Year: 2015-16

b) on 27.03.2022. Subsequently, the AO passed order u/s.148(d) and also issued a notice u/s.148 dated 25.04.2022 reopening the assessment. The assessee in response to notice u/s.148 filed the return admitting a total income of Rs.3,59,420/-. After considering the submissions of the assessee with regard to various details called, the AO concluded the assessment after making addition