SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-1, ERODE

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.1955 & 1956/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15) Sri Maharaja Refineries, # 128, Bhavani Road, Erode-638 004. Vs The Assistant Commissioner Of Income-Tax, Circle-1, Erode. (प्रत्यर्थी/Respondent) Pan: Aaffs-8491-N (अपीलार्थी/Appellant) अपीलार्थीकीओरसे / Appellant By : Mr. S.Sridhar, Advocate (Erode) प्रत्यर्थीकीओरसे/Respondent By : Mr. R.Clement Ramesh Kumar, Cit & Ms.Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख / Date Of Pronouncement : 07.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)] Both Dated 07.06.2024 For

250 or section 254 or section 260 or section 262 or section 263, or section 264 is to be given by the Assessing Officer or the Transfer Pricing Officer, as the case may be, wholly or partly. otherwise than by making a fresh assessment or reassessment

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Years are 2014-15 to 2018-19. 2. The common issue is raised in these appeals, hence, they were heard together and are being disposed off by this consolidated order. Identical grounds are raised except for variation in figures. ITA Nos.548 to 552//CHNY/2024 The ground

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, CHENNAI

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Years are 2014-15 to 2018-19. 2. The common issue is raised in these appeals, hence, they were heard together and are being disposed off by this consolidated order. Identical grounds are raised except for variation in figures. ITA Nos.548 to 552//CHNY/2024 The ground

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Years are 2014-15 to 2018-19. 2. The common issue is raised in these appeals, hence, they were heard together and are being disposed off by this consolidated order. Identical grounds are raised except for variation in figures. ITA Nos.548 to 552//CHNY/2024 The ground

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Years are 2014-15 to 2018-19. 2. The common issue is raised in these appeals, hence, they were heard together and are being disposed off by this consolidated order. Identical grounds are raised except for variation in figures. ITA Nos.548 to 552//CHNY/2024 The ground

THE MADRAS SEVA SADAN,CHENNAI vs. ACIT, EXEMPTION,, CHENNAI

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1246/Chny/2025 Assessment Years: 2022-23 The Madras Seva Sadan, The Assistant Commissioner Of No.7, Shenstone Park, Income Tax (Exemption), Harrington Road, Chetpet, Chennai. Chennai-600 031. [Pan: Aaatt2871J] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri R.Venkatanarayanan, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 07.08.2025 घोषणा की तारीख /Date Of Pronouncement : 08.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

250 or section 254 or section 260 or section 262 or section 263 or section 264, wholly or partly, otherwise than by making a fresh assessment or reassessment

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

reassessment or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

reassessment or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

reassessment or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

reassessment or re-computation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment aforesaid. (4) Where, as a result of an order under section 154 or section 155 or section 250

ACIT CIRCLE 1 , TIRUNELVELI vs. V.SIVASUBRAMANIAN , TIRUNELVELI

In the result, all the appeals of the Revenue stand dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1939, 1940, 1941 & 1942/Chny/2017 "नधा"रण वष" / Assessment Years : 2005-06, 2008-09, 2009-10 & 2010-11 The Deputy Commissioner Of Shri V. Sivasubramanian, Income Tax, Circle -1, V. Prop. Santhi Sweets, Nellai City Centre, Rahmath Nagar, Tirunelveli Junction Tirunelveli. Pan : Adlps 1831 P (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment as referred to in sub- section (1), as the case may be. (4) Where, as a result of an order under section 154 or section 155 or section 250

ACIT CIRCLE 1 , TIRUNELVELI vs. V.SIVASUBRAMANIAN , TIRUNELVELI

In the result, all the appeals of the Revenue stand dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1939, 1940, 1941 & 1942/Chny/2017 "नधा"रण वष" / Assessment Years : 2005-06, 2008-09, 2009-10 & 2010-11 The Deputy Commissioner Of Shri V. Sivasubramanian, Income Tax, Circle -1, V. Prop. Santhi Sweets, Nellai City Centre, Rahmath Nagar, Tirunelveli Junction Tirunelveli. Pan : Adlps 1831 P (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment as referred to in sub- section (1), as the case may be. (4) Where, as a result of an order under section 154 or section 155 or section 250

ACIT CIRCLE 1 , TIRUNELVELI vs. V.SIVASUBRAMANIAN , TIRUNELVELI

In the result, all the appeals of the Revenue stand dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1939, 1940, 1941 & 1942/Chny/2017 "नधा"रण वष" / Assessment Years : 2005-06, 2008-09, 2009-10 & 2010-11 The Deputy Commissioner Of Shri V. Sivasubramanian, Income Tax, Circle -1, V. Prop. Santhi Sweets, Nellai City Centre, Rahmath Nagar, Tirunelveli Junction Tirunelveli. Pan : Adlps 1831 P (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment or recomputation exceeds the tax on the total income determined under sub-section (1) of section 143 or on the basis of the regular assessment as referred to in sub- section (1), as the case may be. (4) Where, as a result of an order under section 154 or section 155 or section 250

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

250 of the Income Tax Act, 1961 (hereinafter referred to as Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘). 2. Before we advert to the grounds t Before we advert to the grounds taken in these appeals, it would aken in these appeals, it would first be relevant to cull out the basic facts o first be relevant

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

250 of the Income Tax Act, 1961 (hereinafter referred to as Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘). 2. Before we advert to the grounds t Before we advert to the grounds taken in these appeals, it would aken in these appeals, it would first be relevant to cull out the basic facts o first be relevant

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

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

section 142(1) the AR had submitted Income Computation statement. Profit & Loss Account for the AY 2017-18, Balance Sheet as on 31.03 2017, details of assets etc. The AO has not made any addition on the above issue and claim of the assessee was accepted by AO. During reassessment proceedings, the AO noticed from Profit & Loss Account

POSHAK INDUSTRIES,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee is partly allowed for 8

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

250 of the Income Tax Act, 1961 (herein after referred to as ‘the Act’). The assessee has raised the following grounds:- 2. 1. The order of the Commissioner of Income Tax (Appeals) is opposed to law and contrary to the facts of the case. 2. The Commissioner of Income Tax (Appeals) grossly erred in remanding the matter back

DEPUTY COMMISSIONER OF INCOME TAX, SALEM vs. GOVINDA RAJULU SRINIVASAN, SALEM

In the result, appeal of the Revenue is dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1250/Chny/2025 Assessment Years: 2017-18 Deputy Commissioner Of Income Govinda Rajulu Srinivasan, Tax No.21, Chinna Ezhuthukkara Street, Circle-1, Shevapet, Salem, Salem Tamil Nadu-636 002. [Pan: Avmps5356G] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.Bhupendran, Advocate, प्रत्यर्थी की ओर से /Revenue By : Ms.C.Yamuna, Cit. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 09.10.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

250 / 2024-25 / 1074914100(1) dated 24.03.2025 of the Learned Commissioner of Income Tax [herein after “CIT(A), National Faceless Appeal Center[NFAC], Delhi, for the assessment year 2017-18. The reference to the word “Act” in this order hereinafter shall mean the Income Tax Act, 1961 as amended from time to time. 2.0 The Appellant Revenue has raised following

POWER SECURITY CORP. PVT. LTD.,CHENNAI vs. ITO, CORP. WARD-5(2), CHENNAI

The appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2943/Chny/2025 िनधा$रण वष$ /Assessment Year: 2013-14

section 149, since the alleged escaped income was less than 50 lakhs, and therefore the reassessment proceedings were void ab initio. 3. The authorities below erred in ignoring the binding judgment of the Hon'ble Supreme Court in Union of India v. Rajeev Bansal [2024] 167 taxmann.com 70 (SC), which clearly lays down that reopening beyond three years is impermissible