ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

reassessment proceedings ITA Nos.2578 to 2580/chny/2017 :- 35 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells under section 147. In the case of CIT v. Hukam Singh, (2005) 276

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 order passed under section 147 r.w.s. 144B of the Act, in the facts and circumstances of the case. 21 I.T.A. Nos.1667 to 1670/Chny/24 22. The ld. AR Shri G. Baskar, Advocate adopted the same arguments advanced in earlier assessment year 2014-15 in respect of “change of opinion”. He relied on the decision of Hon’ble High Court

MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

reassessment. Since the\nreassessment had been set aside, the order of the Tribunal cancelling the penalty\nlevied under section 271(1) (c) of the Act was also legal. \" (p. 787)\n7. Addl. CIT v. Badri Prasad Kashi Prasad [1993] 200 ITR 206 (All.) \"Held, that the\nlevy of penalty was based on the addition to income made by the Income

JAY FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

276 (Del. H.C.) " Commissioner of Income-tax Vs. S.R. Construction reported in 257 ITR 502 (Mad.H.C.) 8. On the other hand, the DR relied upon the order of the CIT(A) and also the following case laws: " Dr.Raghuvendra Singh Vs. Commissioner of Income Tax reported in [2014] 49 taxmann.com 504 (Punjab & Haryana) Wherein, it was held that where the cost

JAY FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

276 (Del. H.C.) " Commissioner of Income-tax Vs. S.R. Construction reported in 257 ITR 502 (Mad.H.C.) 8. On the other hand, the DR relied upon the order of the CIT(A) and also the following case laws: " Dr.Raghuvendra Singh Vs. Commissioner of Income Tax reported in [2014] 49 taxmann.com 504 (Punjab & Haryana) Wherein, it was held that where the cost

M/S. J FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

276 (Del. H.C.) " Commissioner of Income-tax Vs. S.R. Construction reported in 257 ITR 502 (Mad.H.C.) 8. On the other hand, the DR relied upon the order of the CIT(A) and also the following case laws: " Dr.Raghuvendra Singh Vs. Commissioner of Income Tax reported in [2014] 49 taxmann.com 504 (Punjab & Haryana) Wherein, it was held that where the cost

JAY FARM HOUSE,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

276 (Del. H.C.) " Commissioner of Income-tax Vs. S.R. Construction reported in 257 ITR 502 (Mad.H.C.) 8. On the other hand, the DR relied upon the order of the CIT(A) and also the following case laws: " Dr.Raghuvendra Singh Vs. Commissioner of Income Tax reported in [2014] 49 taxmann.com 504 (Punjab & Haryana) Wherein, it was held that where the cost

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

reassessment under Section 147 r.w.s. 144 vide\nhis order dated 30.03.2024 for AY:2017-18. In first appeal, the learned\nCIT(A), upheld the addition of the entire alleged suppressed turnover and\nheld the Section 115BBE of the Act is not applicable. Having aggrieved\nby the order of the learned CIT(A)-18, the assessee is before us AYs\n2017

ANTHONYMUTHU UDAYAR XAVIER,SIVAGANGA vs. ITO, WARD-1,, KARAIKUDI

In the result, the appeal of the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:1943/Chny/2024 धििाारणवर्ा / Assessment Year:2014-15 Anthonymuthu Udayar Xavier, Income Tax Officer, 78 Mgr Salai, Vs. Ward-1 Soodamanipuram, Karaikudi. Karaikudi, Sivaganga – 630 002. Tamil Nadu. [Pan:Aaapx-3145-R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Addl. Cit. सुिवाईकीतारीख/Date Of Hearing : 14.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025 आदेश /O R D E R

276 ought to be lodged and continued. The said circular and clarification have been brought after the statutory scheme of Section 245H(1) and the appended proviso. In this situation, it is imperative for us to understand the binding nature of the departmental circular, Prosecution Manual, 2009, and CBDT's clarification. 25. Reflecting on the said issue, in Ranadey Micronutrients

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 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 under Section 147 r.w.s. 144 vide his order dated 30.03.2024 for AY:2017-18. In first appeal, the learned CIT(A), upheld the addition of the entire alleged suppressed turnover and held the Section 115BBE of the Act is not applicable. Having aggrieved by the order of the learned CIT(A)-18, the assessee is before

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

reassessment under Section 147 r.w.s. 144 vide\nhis order dated 30.03.2024 for AY:2017-18. In first appeal, the learned\nCIT(A), upheld the addition of the entire alleged suppressed turnover and\nheld the Section 115BBE of the Act is not applicable. Having aggrieved\nby the order of the learned CIT(A)-18, the assessee is before us AYs\n2017

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 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 under Section 147 r.w.s. 144 vide his order dated 30.03.2024 for AY:2017-18. In first appeal, the learned CIT(A), upheld the addition of the entire alleged suppressed turnover and held the Section 115BBE of the Act is not applicable. Having aggrieved by the order of the learned CIT(A)-18, the assessee is before

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, , CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 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 under Section 147 r.w.s. 144 vide his order dated 30.03.2024 for AY:2017-18. In first appeal, the learned CIT(A), upheld the addition of the entire alleged suppressed turnover and held the Section 115BBE of the Act is not applicable. Having aggrieved by the order of the learned CIT(A)-18, the assessee is before

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 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 under Section 147 r.w.s. 144 vide his order dated 30.03.2024 for AY:2017-18. In first appeal, the learned CIT(A), upheld the addition of the entire alleged suppressed turnover and held the Section 115BBE of the Act is not applicable. Having aggrieved by the order of the learned CIT(A)-18, the assessee is before

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment are to be examined on a 'stand-alone' basis. Neither anything can be added to the reasons so recorded nor anything be deleted from the reasons so recorded. The Hon'ble Bombay High Court in the case of Hindustan Lever Ltd. v. R.B. Wadkar [2004] 137 Taxman 479/268 ITR 332 inter alia, held "it is needless to mention that

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment are to be examined on a 'stand-alone' basis. Neither anything can be added to the reasons so recorded nor anything be deleted from the reasons so recorded. The Hon'ble Bombay High Court in the case of Hindustan Lever Ltd. v. R.B. Wadkar [2004] 137 Taxman 479/268 ITR 332 inter alia, held "it is needless to mention that

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment are to be examined on a 'stand-alone' basis. Neither anything can be added to the reasons so recorded nor anything be deleted from the reasons so recorded. The Hon'ble Bombay High Court in the case of Hindustan Lever Ltd. v. R.B. Wadkar [2004] 137 Taxman 479/268 ITR 332 inter alia, held "it is needless to mention that

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment are to be examined on a 'stand-alone' basis. Neither anything can be added to the reasons so recorded nor anything be deleted from the reasons so recorded. The Hon'ble Bombay High Court in the case of Hindustan Lever Ltd. v. R.B. Wadkar [2004] 137 Taxman 479/268 ITR 332 inter alia, held "it is needless to mention that