M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

253, wherein it has been clearly held that where vagueness and ambiguity in the notice can demonstrate non-application of mind by the authority and/or ultimate prejudice to the right of opportunity of hearing contemplated u/s.274 of the Act. 14. In this legal back ground, if you examine the facts of the present case, there is no dispute with regard

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

253, wherein it has been clearly held that where vagueness and ambiguity in the notice can demonstrate non-application of mind by the authority and/or ultimate prejudice to the right of opportunity of hearing contemplated u/s.274 of the Act. 14. In this legal back ground, if you examine the facts of the present case, there is no dispute with regard

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

3) of the Act, the AO has disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section

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

253/-. 2.2 Having regard to the holding of the A0 that the provisions for loss on forex fluctuations claimed for of Rs.40,98,03,268/- in this case for A.Y 2009-10, is a contingent liability and that it is not an expenditure having been laid out or expended", the ld. CIT(A) is not justified in giving relief

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

253/-. 2.2 Having regard to the holding of the A0 that the provisions for loss on forex fluctuations claimed for of Rs.40,98,03,268/- in this case for A.Y 2009-10, is a contingent liability and that it is not an expenditure having been laid out or expended", the ld. CIT(A) is not justified in giving relief

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

3) of the Act, the AO has disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section

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

3) of the Act, the AO has disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section

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

3) of the Act, the AO has disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section

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

3) of the Act, the AO has disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section

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

3) of the Act, the AO has disallowed the\nexpenses debited on account of purchases made from vendors and he had\nnot brought on record any material to establish that such expenses had\nresulted in the acquisition of any asset by the assessee. We therefore are\nof the considered view that, the condition stipulated in the fourth proviso\nto Section

DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE, MADURAI vs. M/S RAMCO SYSTEMS LIMITED, RAJAPALAYAM

In the result, appeal filed by the Revenue is dismissed

reassessment or by way of rectification of\nmistake. In a case of this nature the Revenue is not without\nremedy. Section 263 of the Act empowers the Commissioner to\nreview an order which is prejudicial to the Revenue.\nIn Bawa Abhai Singh's case [2002] 253 ITR 83 (Delhi), a\nDivision Bench of this court of which

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

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY MOOLIMANGALAM VAISHNAVA PRIYA, CHENNAI

In the result, all the three appeals of the Revenue are dismissed

reassess the total income of six years immediately preceding the\n assessment year relevant to the previous year in which the search was\nconducted and for the relevant assessment year or years. Explanation 1\nbelow section 153A of the Act defines the expression relevant assessment.\nIn order to make an assessment for assessment year which falls beyond six\n assessment

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE,TRICHY vs. MARAGATHAMANI SHANMUGAM, KARUR

In the result, all the three appeals of the Revenue are dismissed

reassess the total income of six years immediately preceding the\n assessment year relevant to the previous year in which the search was\nconducted and for the relevant assessment year or years. Explanation 1\nbelow section 153A of the Act defines the expression relevant assessment.\nIn order to make an assessment for assessment year which falls beyond six\n assessment

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, TRICHY, INCOME TAX OFFICE, TRICHY vs. KARUPPANNA GOUNDER PALANIAPPA GOUNDER MARIAPPAN, KARUR

In the result, all the three appeals of the Revenue are dismissed

3).\nThe rule of law on this subject has, in our opinion, been fairly and rightly\nstated by the Lahore High Court in the case of Seth Gurmukh Singh (supra)\".\n6.2.15 As evident from the decisions cited above, though it is true that the\nprovisions of Evidence Act do not apply with the same rigor to the Income\nTax proceedings

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. LIFE LINE AUTO FINANCE, KARUR

3). The rule of law on this\nsubject has, in our opinion, been fairly and rightly stated by\n:-8-:\nITA. No:1630/Chny/2025\nthe Lahore High Court in the case of Seth Gurmukh Singh\n(supra).\n6.5.13 As evident from the decisions cited above, though it is true that\nthe provisions of Evidence Act do not apply with the same

THE GATE OF HOPE CHARITABLE TRUST,,CHENNAI vs. ITO(E), WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment order framed pursuant to reopening itself. 3. We first take up the appeal in We first take up the appeal in ITA No. 1372/Chny/2024 ITA No. 1372/Chny/2024 for AY 2010-11. The brief facts are that, the assessee is a Charitable Trust and is 11. The brief facts are that, the assessee is a Charitable Trust

THE GATE OF HOPE CHARITABLE TRUST,CHENNAI vs. ITO (EXEMPTIONS) WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment order framed pursuant to reopening itself. 3. We first take up the appeal in We first take up the appeal in ITA No. 1372/Chny/2024 ITA No. 1372/Chny/2024 for AY 2010-11. The brief facts are that, the assessee is a Charitable Trust and is 11. The brief facts are that, the assessee is a Charitable Trust