ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

section 147 clearly depicts that the Assessing Officer has power to make addition, where he arrived to a conclusion that income has escaped assessment which came to his notice during the course of proceedings of reassessment u/s 148. Our view is fortified by the decision in Majinder Singh Kang vs CIT (2012) 25 taxman.com 124/344

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

section 147 clearly depicts that the Assessing Officer has power to make addition, where he arrived to a conclusion that income has escaped assessment which came to his notice during the course of proceedings of reassessment u/s 148. Our view is fortified by the decision in Majinder Singh Kang vs CIT (2012) 25 taxman.com 124/344

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

section 147 clearly depicts that the Assessing Officer has power to make addition, where he arrived to a conclusion that income has escaped assessment which came to his notice during the course of proceedings of reassessment u/s 148. Our view is fortified by the decision in Majinder Singh Kang vs CIT (2012) 25 taxman.com 124/344

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

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

ACIT, NON-CORPORATE CIRCLE 7(1), CHENNAI, CHENNAI vs. LATE SHRI MAHAVEER BHANDARI, LEGAL HEIR- SMT. LALITHA BHANDARI, CHENNAI

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2785/Chny/2024 िनधा"रण वष"/Assessment Year : 2016-17 The Asst. Commissioner Of Late Shri Mahaveer Bhandari, Income Tax, Rep. By Legal Heir Smt. Lalitha Non-Corporate Circle 7(1), Vs. Bhandari, Chennai. 9, Athipattan Street, Mount Road, Chennai – 600 002. Pan: Aadpb 877A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Anitha, Addl.Cit ""यथ" क" ओर से/Respondent By : Shri Ajith Kumar Chordia, Ca (Through Virtual Mode) सुनवाई क" तारीख/Date Of Hearing : 18.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 15.10.2025

196/- being difference on account of LTCG and amount of Rs. 99,39,998/- u/s.28(va) of the Income Tax Act, 1961 to the total income of the appellant. Being aggrieved by the same the assessee preferred the instant appeal. The AO stated that the case was selected for scrutiny under CASS on the issue that whether Sales turnover/receipts

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)

196) wherein, in similar circumstances, held that the reassessment notice dated 29th June, 2021 which was issued within the extended period of limitation was not time barred. f) Copies of the Board's Instruction No.1 of 2022 dated 11-5-2022 and Hon'ble High Court of Delhi decision in the case of Touchstone Holdings

SIVASUNDAR SELVAKUMARI,CHENNAI vs. ITO, NCW-1(6), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

reassessment proceedings in view of the judgment of the Hon’ble Supreme Court in Comunidado of Chicalim Vs. ITO (247 ITR 271). 13. On merits, it was contended that section 64(1)(iv) of the Act clearly provides that income arising from assets transferred without consideration to spouse shall be included in the hands of the transferor. The property having

K.V.VIJAYARAGHAVAN,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.456/Chny/2014 िनधा"रण वष"/Assessment Year:2005-06 Shri K.V. Vijayaraghavan, The Deputy Commissioner Of C/O. Shri T.N. Seetharaman, Vs. Income Tax, Advocate, # 384 (Old No. 196), Company Circle I(1), Lloyds Road, Chennai 600 086. Chennai. [Pan:Aclpv6440Q] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.N. Seetharaman, Advocate ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.09.2018 घोषणा की तारीख /Date Of Pronouncement : 29.10.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) I, Chennai Dated 22.11.2013 Relevant To The Assessment Year 2005-06. The Only Effective Ground Raised In The Appeal Of The Assessee Is That The Ld. Cit(A) Has Erred In Confirming The Addition Of ₹.7,34,750/- Made As “Unexplained Investment” Under Section 69 Of The Income Tax Act, 1961 [“Act” In Short].

196), Company Circle I(1), Lloyds Road, Chennai 600 086. Chennai. [PAN:ACLPV6440Q] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri T.N. Seetharaman, Advocate ""थ" की ओर से/Respondent by : Shri R. Clement Ramesh Kumar, Addl. CIT सुनवाई की तारीख/ Date of hearing : 06.09.2018 घोषणा की तारीख /Date of Pronouncement : 29.10.2018 आदेश

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 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 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

VA TECH WABAG LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee as well as Revenue are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 1377/Chny/2016 िनधा"रण वष"/Assessment Year: 2006-07 M/S. Va Tech Wabag Limited, The Assistant Commissioner Of No. 17, “Wabag House”, 200 Feet Vs. Income Tax, Thoraipakkam – Pallavaram Main Company Circle Iii(4), Road, Sunnambu Kolathur, Chennai. Chennai 600 117. [Pan:Aabcv0225G] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 1517/Chny/2016 िनधा"रण वष"/Assessment Year: 2006-07 The Assistant Commissioner Of Vs. M/S. Va Tech Wabag Limited, Income Tax, No. 17, “Wabag House”, 200 Feet Company Circle Iii(4), Thoraipakkam – Pallavaram Main Chennai Road, Sunnambu Kolathur, Chennai 600 117. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : S/Shri R, Venkatraman, Lakshmi Sriram & B. Sivaraman, Advocates ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.10.2021 घोषणा की तारीख /Date Of Pronouncement : 02.12.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) - 11, Chennai Dated 29.02.2016 Relevant To The Assessment Year 2006-07. 2

196 to 201 of 2019 dated 07.03.2019 on further appeal, thereby the issue of eligibility of 80IA relief attained finality. It was further contended that no reason was stated by the Assessing Officer while issuing notice under section 148 of the Act and thus, the reassessment

ACIT, CHENNAI vs. V A TECH WABAG LIMITED, CHENNAI

In the result, both the appeals filed by the assessee as well as Revenue are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 1377/Chny/2016 िनधा"रण वष"/Assessment Year: 2006-07 M/S. Va Tech Wabag Limited, The Assistant Commissioner Of No. 17, “Wabag House”, 200 Feet Vs. Income Tax, Thoraipakkam – Pallavaram Main Company Circle Iii(4), Road, Sunnambu Kolathur, Chennai. Chennai 600 117. [Pan:Aabcv0225G] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 1517/Chny/2016 िनधा"रण वष"/Assessment Year: 2006-07 The Assistant Commissioner Of Vs. M/S. Va Tech Wabag Limited, Income Tax, No. 17, “Wabag House”, 200 Feet Company Circle Iii(4), Thoraipakkam – Pallavaram Main Chennai Road, Sunnambu Kolathur, Chennai 600 117. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : S/Shri R, Venkatraman, Lakshmi Sriram & B. Sivaraman, Advocates ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.10.2021 घोषणा की तारीख /Date Of Pronouncement : 02.12.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) - 11, Chennai Dated 29.02.2016 Relevant To The Assessment Year 2006-07. 2

196 to 201 of 2019 dated 07.03.2019 on further appeal, thereby the issue of eligibility of 80IA relief attained finality. It was further contended that no reason was stated by the Assessing Officer while issuing notice under section 148 of the Act and thus, the reassessment