ASSISTANT COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE-10, CHENNAI vs. SJ SURYAH, CHENNAI

In the result, appeal filed by the assessee is allowed and appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.806/Chny/2023 िनधा"रण वष"/Assessment Year: 2002-03 V. Shri S.J.Suryah, The Asst. Commissioner- No.35-1D, Of Income Tax, 114, Neelakanta Mehta Street, Central Circle-2(4), T. Nagar, Chennai-600 017. Chennai. [Pan: Alyps 3012 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment or recomputation under Section 147, the Assessing Officer shall serve on the assessee a notice requiring him to furnish within such period, as may be specified in the notice, a return of his income......as if such return were a return required to be furnished under Section 139", Similarly, the language use in Section 156 which is reproduced

D.SENTHIL KUMAR,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is allowed in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am

274(1) is reproduced as under: "No order imposing penalty under this chapter shall be made unless the assessee has been heard or has been given a reasonable opportunity of being heard ..” This language use, when in comparison with Section 143(2), which is also is reproduced as under: "Where a return has been furnished under Section

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

274 should specifically state the grounds mentioned in section 271(T)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form, where all the grounds mentioned in section 271 are mentioned, would not satisfy requirement of law. The assessee should know the grounds which he has to meet specifically. Otherwise

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

274 should specifically state the grounds mentioned in section 271(T)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. Sending printed form, where all the grounds mentioned in section 271 are mentioned, would not satisfy requirement of law. The assessee should know the grounds which he has to meet specifically. Otherwise

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

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, 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, 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, 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, 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, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, appeal filed by the Revenue is dismissed and the\nCross-Objection filed by the assessee is allowed

reassessment or recomputation under this Act\nshall be passed by an Assessing Officer below the rank of Joint\nCommissioner, in respect of an assessment year to which clause (i) or\nclause (ii) or clause (iii) or clause (iv) of Explanation 2 to section 148\napply except with the prior approval of the Additional Commissioner or\nAdditional Director or Joint Commissioner

KARUR SREE RAMA TRADING PVT.LTD.,KARUR vs. ITO, CIRCLE-191), TRICHY

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.3841/Chny/2025 िनधा"रण वष"/Assessment Year: 2012-13 Karur Sree Rama Trading Pvt. Ltd., Vs. The Income Tax Officer, S.F. No. 2262, Pari Nagar, Chinna Circle 1(1), Andan Koil Road, Karur 639 001. Trichy. [Pan:Aabfs8790C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 18.02.2026 घोषणा की तारीख /Date Of Pronouncement : 26.02.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.10.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2012-13 Passed Under Section 147/271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

reassessment is void and therefore, the penalty based on it is also invalid. Further, the ld. AR submits that as per section 271(1)(c) of the Act, the Assessing Officer requires to record proper satisfaction during the assessment and argued that a vague or mechanical initiation without proper satisfaction render the penalty invalid. He drew our attention

M/S ENRIA ENTERPRISES PVT. LTD,CHENNAI vs. DCIT. CENTRAL CIRCLE - 3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

reassessed or recomputed in a preceding order. 7.6.3 The above section divides the cases into two categories, 1. Where No Return of Income has been filed and Income has been assessed for the first time. Clause (a) & (b) of 270A (10) are wrt computation of tax payable in those cases, 2. In all other cases, tax payable

M/S ENRICE ENTERPRISES PVT. LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

reassessed or recomputed in a preceding order. 7.6.3 The above section divides the cases into two categories, 1. Where No Return of Income has been filed and Income has been assessed for the first time. Clause (a) & (b) of 270A (10) are wrt computation of tax payable in those cases, 2. In all other cases, tax payable

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

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

SREE NAVALADIYAN FINANCE,SALEM vs. DCIT,CENTRAL CIRCLE, SALEM

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

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

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded

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

section 147 of the Act. Finally, the AO in the reassessment proceedings assessed the returned income filed in response to notice u/s.148 of the Act at Rs.40,55,440/-. This addition was accepted by assessee as it is because it was returned income. The AO vide this assessment order initiated penalty proceedings u/s.271(1)© of the Act and recorded