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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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

1) of the Act. The Court held that, a reassessment action would thus\nhave to not only satisfy the time frames constructed in terms of Section\n149, but in a relevant case concerned with a search, also those which\nwould be applicable by virtue of the provisions of Section 153A and 153C

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

reassessment to the six assessment years will be\nexamined with reference to such date.\"\n9. It is evident on a plain interpretation of section 153C(1

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

1) of the Act. The Court held that, a reassessment action would thus\nhave to not only satisfy the time frames constructed in terms of Section\n149, but in a relevant case concerned with a search, also those which\nwould be applicable by virtue of the provisions of Section 153A and 153C

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

reassessment to the six assessment years will be\nexamined with reference to such date.\"\n9. It is evident on a plain interpretation of section 153C(1

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

reassessment to the six assessment years will be examined with reference to such d examined with reference to such date." 9. It is evident on a plain interpretation of section 153C(1

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

1) of the Act. The Court held that, a reassessment action would thus\nhave to not only satisfy the time frames constructed in terms of Section\n149, but in a relevant case concerned with a search, also those which\nwould be applicable by virtue of the provisions of Section 153A and 153C

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

1) of the Act. The Court held that, a reassessment action would thus\nhave to not only satisfy the time frames constructed in terms of Section\n149, but in a relevant case concerned with a search, also those which\nwould be applicable by virtue of the provisions of Section 153A and 153C

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

reassessment to the six assessment years will be examined with reference to such d examined with reference to such date." 9. It is evident on a plain interpretation of section 153C(1

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

1) of the Act. The Court held that, a reassessment action would thus\nhave to not only satisfy the time frames constructed in terms of Section\n149, but in a relevant case concerned with a search, also those which\nwould be applicable by virtue of the provisions of Section 153A and 153C

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

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub within the period of six assessment years referred to in sub- -section (1) is pending on the date of initiation of the search u/s. 132 of the Act shal pending on the date of initiation of the search

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), CHENNAI, CHENNAI vs. BONDALAPATI SHIVAJI RAO, CHENNAI

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

reassessment, as the case may be, would have to be undertaken in accordance with the provisions of section 153A. In terms of Finance Act, 2005, inter-alia the first proviso came to be inserted in section 153C(1

BONDALAPATI SHIVAJI RAO,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), CHENNAI, CHENNAI

In the result, appeal filed by the assessee stands allowed and\nappeal filed by the Revenue is dismissed

reassessment, as\nthe case may be, would have to be undertaken in accordance with the\nprovisions of section 153A. In terms of Finance Act, 2005, inter-alia the\nfirst proviso came to be inserted in section 153C(1

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

reassessment to the six assessment years will be\nexamined with reference to such date.\"\n9. It is evident on a plain interpretation of section 153C(1

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

reassessment to the six assessment years will be\nexamined with reference to such date.\"\n9. It is evident on a plain interpretation of section 153C(1

ABC GOLD PALACE,TIRUVARUR vs. ITO, CENTRAL CIRCLE-3(3), CHENNAI

In the result, the appeals filed by the assessee are\npartly-allowed

1) would show that\nthe assessment or reassessment, if any, relating to any assessment year\nfalling within the period of six assessment years and for the relevant\n assessment year or years referred to in this sub-section, 153C

ABC GOLD PALACE,TIRUVARUR vs. ITO, CENTRAL CIRCLE-3(3), CHENNAI

In the result, the appeals filed by the assessee are\npartly-allowed

1) would show that\nthe assessment or reassessment, if any, relating to any assessment year\nfalling within the period of six assessment years and for the relevant\n assessment year or years referred to in this sub-section, 153C

ABC GOLD PALACE,TIRUVARUR vs. ITO, CENTRAL CIRCLE-3(3), CHENNAI

In the result, the appeals filed by the assessee are\npartly-allowed

1) would show that\nthe assessment or reassessment, if any, relating to any assessment year\nfalling within the period of six assessment years and for the relevant\n assessment year or years referred to in this sub-section, 153C