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 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\nof the Act. In the decided case, the search was conducted on 11.10.2023\nand the seized material

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 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\nof the Act. In the decided case, the search was conducted on 11.10.2023\nand the seized material

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

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\nof the Act. In the decided case, the search was conducted on 11.10.2023\nand the seized material

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

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\nof the Act. In the decided case, the search was conducted on 11.10.2023\nand the seized material

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

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\nof the Act. In the decided case, the search was conducted on 11.10.2023\nand the seized material

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

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\nof the Act. In the decided case, the search was conducted on 11.10.2023\nand the seized material

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 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

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 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

JESUDASON BIJI ,CHENNAI vs. OFFICE OF INCOME TAX OFFICER INT. TAXN WARD1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

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

24 :: Explanation.—For the purposes of clause (b) of this subsection, “asset” shall include immovable property, being land or building or both, shares and securities, loans and advances, deposits in bank account. (2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151.’ 12. From a bare reading

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

In the result, appeal filed by the assessee is partly allowed

reassessment proceedings initiated based on this invalid notice were quashed.", "result": "Partly Allowed", "sections": [ "147", "144", "148A(b)", "148A(d)", "148", "133(6)", "69A", "142(1)", "144B", "151A", "151", "132", "132A", "149(1)", "48", "2(24

ST. JOHN FREIGHT SYSTEMS PVT. LTD.,,TUTUCORIN vs. DCIT, CC-1,, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

24 :: same could be carried forward and set off against future income only if the assessee has filed his return within the due date prescribed under section 139(1). It is exactly like the provisions of law stated in section 80AC. Inspite of that, the Tribunal in the above stated case of Faisal Abbas (supra) has held that the assessee

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

24 :: same could be carried forward and set off against future income only if the assessee has filed his return within the due date prescribed under section 139(1). It is exactly like the provisions of law stated in section 80AC. Inspite of that, the Tribunal in the above stated case of Faisal Abbas (supra) has held that the assessee

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

24 :: same could be carried forward and set off against future income only if the assessee has filed his return within the due date prescribed under section 139(1). It is exactly like the provisions of law stated in section 80AC. Inspite of that, the Tribunal in the above stated case of Faisal Abbas (supra) has held that the assessee

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

24 :: same could be carried forward and set off against future income only if the assessee has filed his return within the due date prescribed under section 139(1). It is exactly like the provisions of law stated in section 80AC. Inspite of that, the Tribunal in the above stated case of Faisal Abbas (supra) has held that the assessee

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

Section 153C(1) that the\nParliamentary intent to enact the proviso was to cater not merely to\nthe question of abatement but also with regard to the date from\nwhich the six year period was to be reckoned, in respect of which the\nreturns were to be filed by the third party (whose premises are not\nsearched and in respect

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

Section 153C(1) that the\nParliamentary intent to enact the proviso was to cater not merely to\nthe question of abatement but also with regard to the date from\nwhich the six year period was to be reckoned, in respect of which the\nreturns were to be filed by the third party (whose premises are not\nsearched and in respect

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri