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

reassessment under Section 143(3) read with Section 264 of the Act on 31.03.2022, determining the total assessed income at ₹1,70,77,591/- as against the returned income of ₹61,371/-. And as noted supra, the ibid assessment order didn’t contain any finding or direction regarding the initiation of penalty proceedings in respect of the additions made, which

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

reassessment, if any, relating to any\n assessment year falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

reassessment, if any, relating to any\n assessment year falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

reassessment, if any, relating to any\n assessment year falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

reassessment, if any, relating to any\n assessment year falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

reassessment, if any, relating to any\n assessment year falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

reassessment, if any, relating to any assessment\nyear falling within the period of six assessment years referred\nto in this sub-section pending on the date of initiation of the search under\nSection 132 or making of requisition under Section 132A, as the case may\nbe, shall abate.\" Therefore, Section 153A is in the nature of a second\nchance given

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. SITARAM JEWELLERS, MADURAI

In the result, both the appeals of the revenue are dismissed

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

270A(9) is initiated separately for under reporting of income in consequence to misreporting of income.” Thus made an addition of Rs.16,22,950/- for the A.Y. 2020-21 and Rs.48,26,392/- for the A.Y. 2021-22. 12. The Assessing Officer also noted that the certain expenditures have been made by the assessee are to be treated as unexplained

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. SITARAM JEWELLERS, MADURAI

In the result, both the appeals of the revenue are dismissed

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

270A(9) is initiated separately for under reporting of income in consequence to misreporting of income.” Thus made an addition of Rs.16,22,950/- for the A.Y. 2020-21 and Rs.48,26,392/- for the A.Y. 2021-22. 12. The Assessing Officer also noted that the certain expenditures have been made by the assessee are to be treated as unexplained

KAG INDIA PRIVATE LIMITED,CHENNAI vs. PCIT CENTRAL CIRCLE -2, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1366/Chny/2024 िनधा"रणवष" / Assessment Year: 2020-21 The Pcit (Central), M/S. Kag India Pvt Ltd., V. Chennai -2. No. 264/15-1, Sathiyanathan Complex, Velachery Road, East Tambaram, Chennai – 600 059. [Pan: Aadck-5381-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Y. Sridhar, Fca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तार"ख/Date Of Hearing : 21.11.2024 घोषणा क" तार"ख/Date Of Pronouncement : 11.12.2024 आदेश /O R D E R

reassessed has the effect of reducing the loss or converting such loss into income.” Having considered the facts, in this case, it is undisputed that assessee’s case would not fall in any of the sub clause (b) to (g) of sub-section (2) of Section 270A of the Act, and the only clause which remains is clause

M/S. AVM PRODUCTIONS,CHENNAI vs. ACIT, NON CORPORATE CIRCLE-20(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Ms. Padmavathy. S

reassessed immediately before such assessment. (3) The amount of under reported income shall be- (i) in a case where income has been assessed for the first time- a) if return has been furnished, the difference between the amount of income assessed and the amount of income determined under clause (a) of sub-section(1) of section 143. Therefore

SRI KRISHA TRADERS,SIVAGANGAI vs. DCIT, NON CORPORATE CIRCLE-1,, MADURAI

In the result, the appeal of the assessee is allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2223/Chny/2025 िनधा%रण वष% /Assessment Year: 2017-18

section 40A(3) and also not covered under the rule 6DD, the expenditure to the extent of Rs. 3,08,45,000/- is disallowed and added to the returned Sri Krishna Traders :- 4 -: income. Penalty u/s 270A are initiated for under reporting of Income which was in consequence of mis-reporting of income.” 3. On further appeal

CHENNIAPPAN RAMADURAI,ERODE vs. DCIT, CENTRAL CIRCLE-2, COIMBATORE

In the result the appeal is dismissed

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1337/Chny/2023 & Ita Nos.1340/Chny/2023 निर्धारण वर्ा /Assessment Years: 2018-19 & Ay-2019-20 Shri Chenniappan Ramadurai, Dy. Commissioner Of Income Tax, No.56, Nms Compound, Erode, Central Circle-2, Coimbatore. Tamil Nadu-638001. [Pan: Aelpr2706M] & Ita Nos.1343/Chny/2023 For Ay 2019-20 Smt. Ramadurai Amutha, No.56, Nms Compound, Erode, Dy. Commissioner Of Income Tax, Tamil Nadu-638001. Central Circle-2, Coimbatore. [Pan: Afvpa4816L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.S.Sridhar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri Arv Srinivasan, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 30.05.2024 घोषणा की तारीख /Date Of Pronouncement : 12.06.2024

3) The amount of under-reported income shall be,— (i) in a case where income has been assessed for the first time,— (a) if return has been furnished, the difference between the amount of income assessed and the amount of income determined under clause (a) of sub-section (1) of section 143; (b) in a case where no return

M/S. CITADINES OMR APARTHOTEL PRIVATE LIMITED,CHENNAI vs. ITO CORP WARD 1(3), CHENNAI

In the result, the appeal of the assessee is allowed and the stay application of the assessee is dismissed as infructuous

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.303/Chny/2026 & Sa No.29/Chny/2026 (Arising Out Of Ita No.303/Chny/2026) िनधा$रण वष$ /Assessment Year: 2018-19 M/S. Citadines Omr Aparthotel Pvt. The Income Tax Officer, Ltd., Vs. Corporate Ward-1(3), No.94, Somerset Greenways, Chennai. Sathyadev Avenue, Raja Annamalaipuram, Chennai – 600 028. Pan: Aadcr 5653C

270A and initiation of proceedings under section 276C of section 276CC, if he fulfils the following conditions, namely:— (a) the tax and interest payable as per the order of assessment or reassessment under sub-section (3

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

sections": [ "143(3)", "132", "131", "154", "115BBE", "270A", "271(1)(c)", "271AAC", "68", "69", "69A", "69B", "69C", "69D", "246A", "250", "274", "275", "139", "132(4A)", "292C" ], "issues": "Whether the deletions made by the CIT(A) regarding the jewellery addition were justified, and whether the reassessment

SUNITHA,COIMBATORE vs. PCIT -1, COIM,BATORE

In the result, appeal filed by the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2013/Chny/2024 (िनधा"रणवष" / Assessment Year: 2018-2019) Sunitha, Vs. The Principal Commissioner Of No.30, Sivaji Colony, Income Tax -1, Thadagam Road, Coimbatore Edayarpalayam, Coimbatore 641 025. [Pan: Bhqps 4789G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N.V. Balaji, Advocate ""यथ" क" ओर से /Respondent By : Shri R. Clement Ramesh Kumar, Irs, Cit. सुनवाई क" तार"ख/Date Of Hearing : 26.11.2024 घोषणा क" तार"ख /Date Of Pronouncement : 10.12.2024 आदेश / O R D E R Per Manu Kumar Giri ()

reassessment u/s.143(3) r.w.s. 144B of the Act vide order dated 20.04.2021 as under:- 1. The case was selected for Complete Scrutiny assessment under the E- assessment Scheme, 2019 on the following issues:- S. No Issues 1. Source of Loan Advanced The assessee has e-filed its Return of Income in Form-3 on 28.02.2019 declaring total income at Rs.43

SREE NAVALADIYAN FINANCE,NAMAKKAL vs. DCIT, CENT CIRCLE, SALEM

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

3. The only common issue in these four appeals of assessee is as regards to the order of CIT(A) confirming the action of AO in levying penalty u/s.271(1)(c) r.w.s 274 of the Act. The issue raised as regards to jurisdiction in these four appeals is that the AO has initiated under which limb or charge for which

SREE NAVALADIAN FINANCE,NAMAKKAL vs. ITO, SALEM

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

3. The only common issue in these four appeals of assessee is as regards to the order of CIT(A) confirming the action of AO in levying penalty u/s.271(1)(c) r.w.s 274 of the Act. The issue raised as regards to jurisdiction in these four appeals is that the AO has initiated under which limb or charge for which