KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

reassessment proceedings 3 Notice under section 148 of the Act dated March 31, 2022, 132 issued by the Ld. AO 4 ROI filed on April 28, 2022, in response to notice under section 133 148 of the Act 5 Submission dated June 20, 2022, filed with the Ld. AO in 206 response to the notice under section

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

5 ::\nbeyond the time limit specified under the provisions of clause (b) of sub-\nsection (1) of this section or section 153A or section 153C, as the case\nmay be, as they stood immediately before the commencement of the\nFinance Act, 2021. Therefore, for the AY 2013-14, since the notice under\nsection 148 of the Income

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

5 ::\nbeyond the time limit specified under the provisions of clause (b) of sub-\nsection (1) of this section or section 153A or section 153C, as the case\nmay be, as they stood immediately before the commencement of the\nFinance Act, 2021. Therefore, for the AY 2013-14, since the notice under\nsection 148 of the Income

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

5 ::\nbeyond the time limit specified under the provisions of clause (b) of sub-\nsection (1) of this section or section 153A or section 153C, as the case\nmay be, as they stood immediately before the commencement of the\nFinance Act, 2021. Therefore, for the AY 2013-14, since the notice under\nsection 148 of the Income

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

5 ::\nbeyond the time limit specified under the provisions of clause (b) of sub-\nsection (1) of this section or section 153A or section 153C, as the case\nmay be, as they stood immediately before the commencement of the\nFinance Act, 2021. Therefore, for the AY 2013-14, since the notice under\nsection 148 of the Income

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

5 ::\nbeyond the time limit specified under the provisions of clause (b) of sub-\nsection (1) of this section or section 153A or section 153C, as the case\nmay be, as they stood immediately before the commencement of the\nFinance Act, 2021. Therefore, for the AY 2013-14, since the notice under\nsection 148 of the Income

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

5 ::\nbeyond the time limit specified under the provisions of clause (b) of sub-\nsection (1) of this section or section 153A or section 153C, as the case\nmay be, as they stood immediately before the commencement of the\nFinance Act, 2021. Therefore, for the AY 2013-14, since the notice under\nsection 148 of the Income

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

5 DTR 0202, wherein the Hon'ble\nITAT stressed the importance of gathering corroborative evidence in\nsupport of the contents of a document, particularly when the document is\nbereft of necessary details and is not complete in all respects, by stating\nas under:\n\"For the sake of argument if we accept the submission of the\nlearned Departmental Representative that

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

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

5 maragathamani, Smt Ram Vaisanavapriya, Smt R\nvasanthi, Shri M Rasappa Gounder, Shrimp Ramesh, Shri K\nVadivel, Shri Paneerselvam, Shri P Karppannan, Shri V\nSakthivel, Shri K Karappannan, Shri R Ramasamy and Smt P\nParmeswari.\nThe investment in cash in M/s Lifeline Auto Finance is as under,\nS.No. Name\nAmount\n1.\nEV Kumaran\n2 Crores\n2.\nKP Mariappan\n2 Crores

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

5 maragathamani, Smt Ram Vaisanavapriya, Smt R\nvasanthi, Shri M Rasappa Gounder, Shrimp Ramesh, Shri K\nVadivel, Shri Paneerselvam, Shri P Karppannan, Shri V\nSakthivel, Shri K Karappannan, Shri R Ramasamy and Smt P\nParmeswari.\nThe investment in cash in M/s Lifeline Auto Finance is as under,\nS.No. Name\nAmount\n1.\nEV Kumaran\n2 Crores\n2.\nKP Mariappan\n2 Crores

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

5 maragathamani, Smt Ram Vaisanavapriya, Smt R\nvasanthi, Shri M Rasappa Gounder, Shrimp Ramesh, Shri K\nVadivel, Shri Paneerselvam, Shri P Karppannan, Shri V\nSakthivel, Shri K Karappannan, Shri R Ramasamy and Smt P\nParmeswari.\nThe investment in cash in M/s Lifeline Auto Finance is as under,\nS.No.\nName\nAmount\n1.\nEV Kumaran\n2 Crores\n2.\nKP Mariappan\n2 Crores

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

reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment\nyear or years. Explanation 1 below section 153A of the Act defines the\nexpression relevant assessment. In order to make an assessment for\n assessment year which falls beyond six assessment years

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

reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment\nyear or years. Explanation 1 below section 153A of the Act defines the\nexpression relevant assessment. In order to make an assessment for\n assessment year which falls beyond six assessment years

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, the assessee succeeds on the legal ground

253/- towards unexplained money u/s.69A\nr.w.s 115BBE of the Act.\n7. That the Ld.CIT(A) failed to appreciate that the Assessing Officer erred in\nmaking an addition of Rs.50,00,000/- on account of unexplained investments\nu/s.69 r.w.s 115BBE of the Act.\n8. That the Ld.CIT(A) failed to appreciate that the Assessing Officer erred in\nmaking an addition

MR.ABDUL MUNAF IRFANUDEEN,CHENNAI vs. DCIT, CC-1(4), CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1514/Chny/2024 (िनधा*रणवष* / Assessment Year: 2021-22) Mr. Abdul Munaf Irfanudeen Pcit (Central) बनाम/ 42, Maraikayar Street, Ii Floor, Chennai-1. Near Annai Ayesha Mahal, Vs. Chennai-600 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aawpi-0038-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. Lavanya (Ca) - Ld. Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) -Ld. Dr

253(1) of the Act- an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment: or is effective from 01.04.2022 i.e. AY 2022-23 onwards and therefore, the same is not applicable to AY 2021-22. 1.3 The assessee has filed an additional ground of appeal on which read as under: - 7. For that

D.SENTHIL KUMAR,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is allowed in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

reassessment or recomputation under Section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return o{his income or the income of any other person in respect of which he is assessable under this Act during the previous year corresponding to the relevant