ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

reassessment, as the case may be, under the said 4[sub-sections (1), (1A), (2),\n(3) and (3A)], shall be extended by twelve months.\n(5) Where effect to an order under section 250 or section 254 or section 260 or section\n262 or section 263 or section 264

ARUSUVAI FOOD PROCESSORS PVT. LTD.,SALEM vs. DCIT, CIRCLE-1(1), SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 264, the Assessing Officer completed the reassessment under Section 143(3) read with Section 264 of the Act on 31.03.2022, determining

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

reassessment made thereon is not maintainable when there is time to complete scrutiny assessment under section 143(3) of the Act by issuing a notice under section 143(2) of the Act in response to the revised return of income filed under section 139(5) of the Act. He drew our attention to the decision of the Hon’ble Jurisdictional

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 :

section 264, wholly or partly, otherwise than by making a fresh assessment or reassessment, the assessee shall be entitled to receive

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment made thereon is not maintainable when there is\ntime to complete scrutiny assessment under section 143(3) of the Act by\nissuing a notice under section 143(2) of the Act in response to the revised\nreturn of income filed under section 139(5) of the Act. He drew our\nattention to the decision of the Hon'ble Jurisdictional

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment made thereon is not maintainable when there is\ntime to complete scrutiny assessment under section 143(3) of the Act by\nissuing a notice under section 143(2) of the Act in response to the revised\nreturn of income filed under section 139(5) of the Act. He drew our\nattention to the decision of the Hon'ble Jurisdictional

DCIT CENTRAL CIRCLE-3(1), CHENNAI vs. SANTHA BUILD TECH INIDA PRIVATE LIMITED, EKKATUTHANGAL

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment proceedings were reopened by issuance of notice u/s.148 of the Act dated 04.09.2019. Admittedly, the reopening is beyond 4 years and assessee’s case squarely falls under the proviso to section 147 of the Act. It is also seen that the reopening is done only on the basis that the assessee has not deducted TDS on interest payment made

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

264 ITR 566 (SC) :-24-: ITA. Nos:2613,2732,2820, 2835&2836/Chny/2024 - The Hon’ble Supreme Court in the case of LakhmaniMewal Das (103 ITR 437) The Hon’ble Supreme Court in the case of Sheo Nath Singh - v. Appellate Asstt. CIT [1971] 82 ITR 147 • Lack of analysis during assessment cannot justify reassessment under Section

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. M/S CHOLAMANDALAM INVESTMENT & FINANCE COMPANY LTD, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

264 ITR 566 (SC) :-24-: ITA. Nos:2613,2732,2820, 2835&2836/Chny/2024 - The Hon’ble Supreme Court in the case of LakhmaniMewal Das (103 ITR 437) The Hon’ble Supreme Court in the case of Sheo Nath Singh - v. Appellate Asstt. CIT [1971] 82 ITR 147 • Lack of analysis during assessment cannot justify reassessment under Section

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

264 ITR 566 (SC), wherein the Hon’ble Supreme Court has held as under: Section 148, read with sections 147 and 153, of the Income-tax Act, 1961 - Income escaping assessment - Issue of notice for - Assessment years 1988-89 to 1990-91 - Petitioner-foreign company was engaged in business of oil exploration and providing expertise and assistance in said field

NAGARAJAN JAYA,KANCHEEPURAM vs. ITO, WARD-1,, KANCHIPURAM

In the result the appeal of the Assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunatha

264 of the Act. There cannot be an estoppel against the legal issue and the revenue authorities cannot put artificial fetters to legal issues being challenged in the subsequent appellate proceedings which culminated from the reassessment order. We are also aware that validity of jurisdiction can be challenged in the collateral proceedings. The Ld.AR had relied on the following decision

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act and hence, there is no scope for reassessment. The CIT(A) noted that this fact in para 6.5 & 6.6 as under:- 6.5. In the instant appellant's case there was no omission on the part of the appellant to disclose any material facts necessary relating to the details/evidence called for vide notice