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, 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

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

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

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

9)(c) of the Act nor has given any direction indicating initiation of penalty for underreporting of income/misreporting of income u/s.270A of the Act. Therefore, the foundational jurisdictional requirement for imposing penalty u/s.270A of the Act is bad in law and drew our attention to Section 270A(1) which reads as under: Section 270A “(1)The Assessing Officer, Commissioner (Appeals

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

9)(e) of the Act on the entire sum of Rs.7,41,89,422/- for the assessment year 2021-22”. We need to first ascertain whether the direction given by the ld.PCIT is legally :-8-: ITA. No:1366/Chny/2024 valid or not. For doing so, it would be gainful to reproduce section 270A of the Act, which reads as under: 270A

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

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

9). ITA No.1337, 1340 & 1343/Chny/2023 :- 5 -: 10.0 We have heard rival submission in the light of facts of the case and material brought on records. It is an undisputed fact of this case that the penalty u/s 270A has been levied on an amount of income which was not disclosed by the assesse and which had come to the notice

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

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

9) of 1922 Act to include a HUF and a local authority. Unless a firm\ncan be considered as a 'person', section 17(1) of the 1922 Act cannot govern\nthe assessment of the assessee-firm. In the 1961 Act the expression 'person' is\ndefined differently. It is a matter for consideration whether the definition\ncontained in section

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) of section 143 or section 147, as the case may be, has been paid within the period specified in such notice of demand

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

270A are initiated for under reporting of Income which was in consequence of mis-reporting of income.” 3. On further appeal, the CIT(A) confirmed the addition made by the A.O. It is relevant to note here that the assessee has raised the legal contentions with regard to addition made by the A.O before the CIT(A) and that

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

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

270A of the Act, as inserted by Finance Act, 2016 w.e.f. 01.04.2017. ITA Nos.1154 to 1157/Chny/2023 4. Brief facts of the case are that the assessee is engaged in the business of money lending. A survey u/s.133A of the Act was conducted on the business premises of the assessee on 19.02.2020. During the course of survey, the AO found that

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

270A of the Act, as inserted by Finance Act, 2016 w.e.f. 01.04.2017. ITA Nos.1154 to 1157/Chny/2023 4. Brief facts of the case are that the assessee is engaged in the business of money lending. A survey u/s.133A of the Act was conducted on the business premises of the assessee on 19.02.2020. During the course of survey, the AO found that

SREENAVALADIAN FINANCE,SALEM vs. DCIT,CENTRALCIRCLE, SALEM

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

270A of the Act, as inserted by Finance Act, 2016 w.e.f. 01.04.2017. ITA Nos.1154 to 1157/Chny/2023 4. Brief facts of the case are that the assessee is engaged in the business of money lending. A survey u/s.133A of the Act was conducted on the business premises of the assessee on 19.02.2020. During the course of survey, the AO found that