MERCY EDUCATION TRUST,CHENNAI vs. ITO, NCW-19(6), CHENNAI

In the result, the appeal filed by the assessee is partly-allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2231/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mercy Education Trust, The Income Tax Officer, No.66, Sree Gokulam Towers, Vs. Non-Corporate Ward 19(6), Arcot Road, Chennai. Kodambakkam, Chennai – 600 024. Pan: Aactm 6190M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Rajakumar, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 29.01.2026

section 151 of the Act, therefore, the penalty proceedings initiated u/s 271D of the Act do not survive. In view of the above discussion, the penalty proceedings initiated by the Assessing Officer and sustained by the Ld. CIT(A) / NFAC are not in accordance with law and are liable to be quashed. We, therefore, hold that the penalty levied

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. CHITRAVEL VETRIMARAN, CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

reassess the total income of six assessment years\nimmediately preceding the assessment year relevant to the previous year in which\nsuch search is conducted and therefore the satisfaction which is recorded in the\nsatisfaction note is enough, is erroneous. Therefore, the notice cannot be upheld and\nsuch stand of the revenue cannot be accepted. The reasons, therefore

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. CHITRAVEL VETRIMARAN, CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

reassess the total income of six assessment years\nimmediately preceding the assessment year relevant to the previous year in which\nsuch search is conducted and therefore the satisfaction which is recorded in the\nsatisfaction note is enough, is erroneous. Therefore, the notice cannot be upheld and\nsuch stand of the revenue cannot be accepted. The reasons, therefore