ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. THIRUTHURAIPOONDI TIRUVENKADAM VIVEKANANDAM DHINAKARAN, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. Nos.1422 & 1423/Chny/2023 िनधा"रण वष"/Assessment Years: 1995-96 & 1996-97 The Assistant Commissioner Of Vs. Thiruthuraipoondi Tiruvenkadam Income Tax, Central Circle 2(2), Vivekanandam Dhinakaran, Investigation Building, 5, Iv Street, Venkateswara Nagar, Chennai – 34. Karpagam Gardens, Adyar, Chennai 600 020. [Pan:Abkpd2771Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 25.03.2024 घोषणा की तारीख /Date Of Pronouncement : 05.04.2024 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 06.10.2023 Relevant To The Assessment Years 1995-96 & 1996-97. 2. Brief Facts Of The Case Are That The Assessee, Shri Ttv Dhinakaran Has Filed His Return Of Income For The Assessment Years 1995 96 & 2

reassessment order passed under section 143(3) r.w.s. 147 of the Act dated 31.12.2019 by observing as under: 6.4.6 It may be appreciated that the Hon'ble ITAT has made a clear findings "that provisions of section 153

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

S. ARAVIND,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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

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

153 referred to as the relevant assessment year) : assessment year) : Provided that where an assessment under sub Provided that where an assessment under sub-section (3) of section (3) of section 143 or this section has been made section 143 or this section has been made for the relevant for the relevant assessment year, assessment year, no action shall

SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-1, ERODE

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.1955 & 1956/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15) Sri Maharaja Refineries, # 128, Bhavani Road, Erode-638 004. Vs The Assistant Commissioner Of Income-Tax, Circle-1, Erode. (प्रत्यर्थी/Respondent) Pan: Aaffs-8491-N (अपीलार्थी/Appellant) अपीलार्थीकीओरसे / Appellant By : Mr. S.Sridhar, Advocate (Erode) प्रत्यर्थीकीओरसे/Respondent By : Mr. R.Clement Ramesh Kumar, Cit & Ms.Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख / Date Of Pronouncement : 07.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)] Both Dated 07.06.2024 For

153 (3) Notwithstanding anything contained in sub-sections (1) [, (1A)] and (2), an order of fresh assessment or fresh order under section 92CA, as the case may be, in pursuance of an order under [section 250 or] section 254 or section 263 or section 264, setting aside or cancelling an assessment, or an order under section 92CA, as the case

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. SITARAM JEWELLERS, MADURAI

In the result, both the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

3) of Section 153 would not at all come into picture. 32. At this juncture, it would be apposite to extract the provisions of Section 153C of the Act, which reads as follows: 153C.Assessment of income of any other person.— (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. SITARAM JEWELLERS, MADURAI

In the result, both the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

3) of Section 153 would not at all come into picture. 32. At this juncture, it would be apposite to extract the provisions of Section 153C of the Act, which reads as follows: 153C.Assessment of income of any other person.— (1) Notwithstanding anything contained in section 139, section 147, section 148, section 149, section 151 and section 153, where