THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.).\n\n10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

reassessment, the assessment order is not sustainable and\nrelied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.).\n10. Assessee brought on record copy of computation of income along with\nacknowledgement of return for income, copy of special audit report furnished\nu/s.142(2A) and reply filed by the assessee to the special audit report, available

INDIAN OVERSEAS BANK,CHENNAI vs. DCIT, LTU-2,, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 1570 & 1571/Chny/2024 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Indian Overseas Bank, The Principal Commissioner Of 763, Anna Salai, V. Income Tax, Anna Road, Chennai -4, Chennai – 600 002. Chennai -600 034. [Pan: Aaaci-1223-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. C. Naresh, Ca : Shri. Nilay Baran Som, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 25.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 18.12.2024 आदेश /O R D E R Per S. R. Raghunatha:

section 263 and revising the order of AO passed u/s.143(3) r.w.s 147 dated 30/3/2022 without coming to conclusion the order was erroneous but merely directing the AO to re-examine various issues. 2. On the facts and in the circumstances of the case and in law the Ld.PCIT erred in passing the order u/s.263 without taking into consideration

INDIAN OVERSEAS BANK,CHENNAI vs. ACIT, LTU-2,, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 1570 & 1571/Chny/2024 िनधा"रण वष" / Assessment Years: 2016-17 & 2017-18 Indian Overseas Bank, The Principal Commissioner Of 763, Anna Salai, V. Income Tax, Anna Road, Chennai -4, Chennai – 600 002. Chennai -600 034. [Pan: Aaaci-1223-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. C. Naresh, Ca : Shri. Nilay Baran Som, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 25.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 18.12.2024 आदेश /O R D E R Per S. R. Raghunatha:

section 263 and revising the order of AO passed u/s.143(3) r.w.s 147 dated 30/3/2022 without coming to conclusion the order was erroneous but merely directing the AO to re-examine various issues. 2. On the facts and in the circumstances of the case and in law the Ld.PCIT erred in passing the order u/s.263 without taking into consideration

D.SENTHIL KUMAR,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is allowed in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

reassessment or recomputation under Section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return o{his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant

COASTAL ENERGY PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, both the appeals filed by the assessee as well as Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1337/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 M/S. Coastal Energy Pvt. Ltd., Vs. The Deputy Commissioner Of No. 4, Buharia Towers, 5Th Floor, Income Tax, Moores Road, Chennai 600 006. Corporate Circle 1(2), Chennai. [Pan:Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1354/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. M/S. Coastal Energy Pvt. Ltd., No. 4, Buharia Towers, 5Th Floor, Income Tax, Central Circle 1(1), Moores Road, Chennai 600 006. Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Department By : Shri R. Mohan Reddy, Cit सुनवाई की तारीख/ Date Of Hearing : 26.06.2023 घोषणा की तारीख /Date Of Pronouncement : 06.09.2023 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax

reassessment proceedings, the loss claimed by the assessee on foreign exchange 4 I.T.A. Nos.1354 & 1337/Chny/18 fluctuation to the extent of ₹.41,31,84,609/- and the loss claimed on account of restatement of the payables to the extent of ₹.40,98,03,268/- was disallowed and accordingly, the Assessing Officer has completed the assessment under section 143(3) r.w.s

DCIT CENTRAL CIRCLE 1(1), CHENNAI vs. COASTAL ENERGY PVT LTD., CHENNAI

In the result, both the appeals filed by the assessee as well as Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1337/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 M/S. Coastal Energy Pvt. Ltd., Vs. The Deputy Commissioner Of No. 4, Buharia Towers, 5Th Floor, Income Tax, Moores Road, Chennai 600 006. Corporate Circle 1(2), Chennai. [Pan:Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1354/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. M/S. Coastal Energy Pvt. Ltd., No. 4, Buharia Towers, 5Th Floor, Income Tax, Central Circle 1(1), Moores Road, Chennai 600 006. Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Department By : Shri R. Mohan Reddy, Cit सुनवाई की तारीख/ Date Of Hearing : 26.06.2023 घोषणा की तारीख /Date Of Pronouncement : 06.09.2023 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax

reassessment proceedings, the loss claimed by the assessee on foreign exchange 4 I.T.A. Nos.1354 & 1337/Chny/18 fluctuation to the extent of ₹.41,31,84,609/- and the loss claimed on account of restatement of the payables to the extent of ₹.40,98,03,268/- was disallowed and accordingly, the Assessing Officer has completed the assessment under section 143(3) r.w.s

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

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

158 taxmann.com 395 ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 15 :: − Saveetha Institute of Medical & Technical Sciences vs. ACIT [2012] 25 taxmann.com 138 − ITO vs. Ramachandra Setty & Sons [2024] 163 taxmann.com 666. 12. The Ld. AR then also took us through the statement(s) of Shri Bhawarlal Jain and Shri Shanmugavelu, which formed

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

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

158 taxmann.com 395 ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 15 :: − Saveetha Institute of Medical & Technical Sciences vs. ACIT [2012] 25 taxmann.com 138 − ITO vs. Ramachandra Setty & Sons [2024] 163 taxmann.com 666. 12. The Ld. AR then also took us through the statement(s) of Shri Bhawarlal Jain and Shri Shanmugavelu, which formed

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

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

158 taxmann.com 395 ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 15 :: − Saveetha Institute of Medical & Technical Sciences vs. ACIT [2012] 25 taxmann.com 138 − ITO vs. Ramachandra Setty & Sons [2024] 163 taxmann.com 666. 12. The Ld. AR then also took us through the statement(s) of Shri Bhawarlal Jain and Shri Shanmugavelu, which formed

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

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

158 taxmann.com 395 ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 15 :: − Saveetha Institute of Medical & Technical Sciences vs. ACIT [2012] 25 taxmann.com 138 − ITO vs. Ramachandra Setty & Sons [2024] 163 taxmann.com 666. 12. The Ld. AR then also took us through the statement(s) of Shri Bhawarlal Jain and Shri Shanmugavelu, which formed

MASILAMANI NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, appeals filed by the assessee(s) are allowed

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

reassessment are to be examined on a 'stand-alone' basis. Neither anything can be added to the reasons so recorded nor anything be deleted from the reasons so recorded. The Hon'ble Bombay High Court in the case of Hindustan Lever Ltd. v. R.B. Wadkar [2004] 137 Taxman 479/268 ITR 332 inter alia, held "it is needless to mention that

MAHASAKTHI BIO ENERCON PVT. LTD.,COIMBATORE vs. ACIT, CENTRAL CIRCLE-1,, COIMBATORE

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:467/Chny/2025 िनधा"रण वष" / Assessment Year: 2013-14 Mahasakthi Bio Enercon Private Assistant Commissioner Of Limited, Vs. Income Tax, No.64, Dr. Nanjappa Road, Central Circle -1, Coimbatore – 641 018. Coimbatore. [Pan:Aabci-0022-N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. T. Banusekar, Advocate ""थ" की ओर से/Respondent By : Ms. E. Pavuna Sundari, C.I.T.

section 148 of the Act, 1961 were without jurisdiction.” 6. The ld.AR argued that from the plain reading of the discussion rendered by the Hon’ble Allahabad High Court it is clear that if the notice issued u/s.148 of the Act is issued without obtaining prior approval from the prescribed authority then the impugned notice issued by the Assessing officer

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

158 taxmann.com 395\nSaveetha Institute of Medical & Technical Sciences vs. ACIT [2012]\n25 taxmann.com 138\nITO vs. Ramachandra Setty & Sons [2024] 163 taxmann.com 666.\n12. The Ld. AR then also took us through the statement(s) of Shri\nBhawarlal Jain and Shri Shanmugavelu, which formed the AO's premise\nfor alleging that the advances given by M/s Binny Limited