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

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

reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether

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 proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18\nNow the issue before the under signed is whether

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 proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether

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 proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether

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 proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether

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

reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\n:: 39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether

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

reassess the total income of six years\n:-15-:\nITA. No:1630/Chny/2025\nimmediately preceding the assessment year relevant to the previous year\nin which the search was conducted and for the relevant assessment year\nor 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

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal f

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment order. We find that, before the Ld. CIT(A), the assessee pointed out that, it had later on pointed out that, it had later on received the Form 3CL and had received the Form 3CL and had accordingly filed rectification application u/s 154 of the Act for allowing accordingly filed rectification application u/s 154 of the Act for allowing

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

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

DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

260A of the Act, as a matter of routine." ITA Nos.1266 & 1267/Chny/2025 (AYs 2014-15 & 2016-17) Ramasamy Sivaprakasam :: 11 :: 11. In the present case also, if the impugned purchases are disallowed, it would result in an abnormal gross profit rate of 41.55% and a distorted net profit rate of 25.45% in a regular textile export business. In our considered

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

260A of the Act, as a matter of routine." ITA Nos.1266 & 1267/Chny/2025 (AYs 2014-15 & 2016-17) Ramasamy Sivaprakasam :: 11 :: 11. In the present case also, if the impugned purchases are disallowed, it would result in an abnormal gross profit rate of 41.55% and a distorted net profit rate of 25.45% in a regular textile export business. In our considered

RADIANCE REALTY DEVELOPERS INDIA LIMITED,CHENNAI vs. DCIT CENTRAL CIRCLE 2(1), CHENNAI

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

260A of the Act, as a matter of routine.\"\n\n8.8 We also gainfully refer to the decision of the Hon'ble Calcutta High\nCourt in the case of PCIT v. Sikaria Infra Projects (P.) Ltd. (165\ntaxmann.com 48). In the decided case, the assessee was also a\ncontractor engaged in development of infrastructure. The AO is noted to\nhave

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

260A of the Act, as a matter of routine.\"\n\n8.8\nWe also gainfully refer to the decision of the Hon'ble Calcutta High\nCourt in the case of PCIT v. Sikaria Infra Projects (P.) Ltd. (165\ntaxmann.com 48). In the decided case, the assessee was also a\ncontractor engaged in development of infrastructure. The AO is noted to\nhave

RADIANCE REALTY DEVELOPERS INDIA LIMITED,CHENNAI vs. DCIT CENTRAL CIRCLE 2(1), CHENNAI

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

260A of the Act, as a matter of routine.\"\n\n8.8 We also gainfully refer to the decision of the Hon'ble Calcutta High\nCourt in the case of PCIT v. Sikaria Infra Projects (P.) Ltd. (165\ntaxmann.com 48). In the decided case, the assessee was also a\ncontractor engaged in development of infrastructure. The AO is noted to\nhave

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/A

260A of the Act, as a matter of routine.\"\n\n8.8\nWe also gainfully refer to the decision of the Hon'ble Calcutta High\nCourt in the case of PCIT v. Sikaria Infra Projects (P.) Ltd. (165\ntaxmann.com 48). In the decided case, the assessee was also a\ncontractor engaged in development of infrastructure. The AO is noted to\nhave