DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MUKUNDA LAND DEVELOPERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 2(22)(e) of the Act. In the light of the above, we are of the opinion that the reassessment

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MEADOW INFRASTRUCTURE PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 2(22)(e) of the Act. In the light of the above, we are of the opinion that the reassessment

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S.MAC QUALITY BUILDERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 2(22)(e) of the Act. In the light of the above, we are of the opinion that the reassessment

EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri George Mathan & Shri Ramit Kochar

22)(e) of the 1961 Act during the course of original assessment framed by it and hence there is no question of any change of opinion by the AO while reopening concluded assessment by invoking provisions of Section 147 of the 1961 Act 6.3 The second Explanation to Section 147 of the 1961 Act clearly stipulates vide clause

PALLAVA RESORTS PVT. LTD.,,CHENNAI vs. ITO, CORPORATE WARD - 5 (1),, CHENNAI

In the result, the appeal of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A No.:700/Chny/2020 िनधा"रण वष"/ Assessment Year 2011 – 2012

Section 2(22)(e) of the Act. In the light of the above, we are of the opinion that the reassessment

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

ACIT, CHENNAI vs. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

e- mail. 8. Shri Percy J. Pardiwala, the Ld. Sr. counsel for the assessee, further submitted that normally the assessee-company deals with re-insurance company outside the country directly. However, in order to distribute the risk to various companies and the assessee may not have the entire list of re-insurance companies across the globe, the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. REJI ABRAHAM, CHENNAI

In the result, CO of the assessee vide CO-53/Chny/2024 is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita-1762 / Chny/2024, Assessment Years-2011-12 आयकर अपील सं./Co-53 / Chny/2024, Assessment Years-2011-12 Assistant Commissioner Of Income Reji Abraham, Tax, Corp-Circle-1(1) No.113, Janapriya Crest, Chennai. Pantheon Road, Egmore, Chennai – 600 008. [Pan: Adqpr6864A] आयकर अपील सं./Co-53 / Chny/2024, Assessment Years-2011-12 Reji Abraham, Assistant Commissioner Of Income No.113, Janapriya Crest, Tax, Corp-Circle-1(1) Pantheon Road, Chennai. Egmore, Chennai – 600 008. [Pan: Adqpr6864A] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr. N.Arjun Raj, Advocate. प्रत्यर्थी की ओर से /Revenue By : Mr.Nathala Ravi Babu, Cit सुनवाई की तारीख/Date Of Hearing : 28.02.2025 घोषणा की तारीख /Date Of Pronouncement : 23.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M : The Below Mentioned Appeals Have Been Filed By The Revenue For Ay-2011-12 & Ay-2011-12 Contesting The Order Of Ld. First Appellate Authority Indicated Column-E, Herein Below:-

section 2(22)(e) in this case. We are therefore of the considered view that the order of Ld.First Appellate Authority is based upon correct understanding of the facts of the case and does require any intervention at this stage. Accordingly, we confirm the same and dismiss all the grounds of appeal raised by the assessee on this aspect

THIRUVARUR LIONS EYE HOSPITAL TRUST,THIRUVARUR vs. INCOME TAX OFFICER, THIRUVARUR

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

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.: 2531 & 2535/Chny/2025 िनधा"रण वष"/Assessment Years: 2016-17 & 2018-19 M/S. Thiruvarur Lions Eye The Income Tax Officer, Hospital Trust, Vs. Thiruvarur 157, Vandampalai, Kangalanchery Post, Thiruvarur – 610 101. Pan: Aaatt 0632P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri D. Ambarish, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.11.2025

reassessment proceedings. Hence, the failure to file the return within the prescribed time constitutes a clear contravention of section 139(4C), thereby attracting the penal provisions of section 272A(2)(e). B. Absence of Reasonable Cause Under Section 273B 11. The Ld. DR submits that penalty under section 272A(2)(e) is leviable at ₹100 per day of default, unless