DEPUTY COMMISSIONER OF INCOME-TAX, MADURAI vs. M/S INDUSTRIAL MINERAL CO., 100% EOU, TUTICORIN

In the result, the assessee’s appeal ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.390/Chny/2023 (िनधा(रण वष( / Assessment Year: 2012-13) M/S. Industrial Mineral Co. 100% Eou Acit बनाम/ 1/1C, Harbour Express Highway, Central Circle-(1), Vs. Thermal Nagar So, Tuticorin-628 006. Madurai "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaafi-9714-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपील सं./ Ita No.529/Chny/2023 (िनधा(रण वष( / Assessment Year: 2012-13) Acit M/S. Industrial Mineral Co. 100% Eou बनाम/ Central Circle-(1), 1/1C, Harbour Express Highway, Vs. Madurai Thermal Nagar So, Tuticorin 628006 "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaafi-9714-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri N. Arjun Raj (Advocate) – Ld.Ar ""थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 26-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-05-2025 आदेश / O R D E R

reassess the total income of each of the six assessment years immediately preceding the year in which search action u/s.132 of the Act was initiated or requisition u/s.132A was made. The Ld.CIT(A) failed to appreciate that total income of the assessee cannot be brought to tax if the scope of Section 153A is limited to only undisclosed income

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassess the total income of six (6) years immediately preceding the assessment year relevant to the previous year in which the search was conducted. And that from 01.04.2017, the power to assess/reassess the income was expanded from six (6) to ten (10) years and termed it as the relevant assessment year or years. [refer to Explanation-1 below Section 153A

RANGAMANI KRISHNAN,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result all the five appeals filed by the assessee for the A

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

reassessed. The ld.AR invited our attention to page No.20 of the First appellate authorities order wherein the satisfaction for invoking jurisdiction has been reproduced. 12. The ld.AR submitted that the jurisdictional requirement of the satisfaction note is that; a. It must be in writing, dated, and signed by the Assessing Officer. b. Must be recorded before issuing notice u/s.153C

RANGAMANI KRISHNAN,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result all the five appeals filed by the assessee for the A

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

reassessed. The ld.AR invited our attention to page No.20 of the First appellate authorities order wherein the satisfaction for invoking jurisdiction has been reproduced. 12. The ld.AR submitted that the jurisdictional requirement of the satisfaction note is that; a. It must be in writing, dated, and signed by the Assessing Officer. b. Must be recorded before issuing notice u/s.153C

RANGAMANI KRISHNAN,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result all the five appeals filed by the assessee for the A

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

reassessed. The ld.AR invited our attention to page No.20 of the First appellate authorities order wherein the satisfaction for invoking jurisdiction has been reproduced. 12. The ld.AR submitted that the jurisdictional requirement of the satisfaction note is that; a. It must be in writing, dated, and signed by the Assessing Officer. b. Must be recorded before issuing notice u/s.153C

RANGAMANI KRISHNAN,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result all the five appeals filed by the assessee for the A

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

reassessed. The ld.AR invited our attention to page No.20 of the First appellate authorities order wherein the satisfaction for invoking jurisdiction has been reproduced. 12. The ld.AR submitted that the jurisdictional requirement of the satisfaction note is that; a. It must be in writing, dated, and signed by the Assessing Officer. b. Must be recorded before issuing notice u/s.153C

RANGAMANI KRISHNAN,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(3), CHENNAI

In the result all the five appeals filed by the assessee for the A

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकर अपीलसं./Ita Nos.: 453, 454, 455, 456 & 457/Chny/2025 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17, 2017-18, 2018-19 & 2019-20 & Sa Nos.41, 42, 43, 44 & 45/Chny/2025 [In Ita Nos. 453, 454, 455, 456 & 457/Chny/2025]

reassessed. The ld.AR invited our attention to page No.20 of the First appellate authorities order wherein the satisfaction for invoking jurisdiction has been reproduced. 12. The ld.AR submitted that the jurisdictional requirement of the satisfaction note is that; a. It must be in writing, dated, and signed by the Assessing Officer. b. Must be recorded before issuing notice u/s.153C

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

reassess the total income of such other person, (the assessee in this case )in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee are the same, he/AO of assessee can issue notice u/s 153C of the Act only after

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

reassess the total income of such other person, (the assessee in this case )in the manner provided in section 153A of the Act. So in this case before us, since the AO of the searched person as well as that of the other/third party/assessee are the same, he/AO of assessee can issue notice u/s 153C of the Act only after

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, TRICHY, INCOME TAX OFFICE, TRICHY vs. KARUPPANNA GOUNDER PALANIAPPA GOUNDER MARIAPPAN, KARUR

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1628/Chny/2025 Acit, Central Circle -2, Trichy. निर्धारण वर्ष / Assessment Year: 2013-14 (अपीलार्थी/Appellant) Maragathamani Shanmugam, Vs. 54A, Muthu Nagar, Sengunthapuram, Karur – 639 002. [Pan:Abkps-2816-H] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.:1629/Chny/2025 Acit, Central Circle -2, Trichy. निर्धारण वर्ष / Assessment Year: 2013-14 (अपीलार्थी/Appellant) Ramasamy Moolimangalam Vs. Vaishnava Priya, 33, B7 Adhisri Apartments, Kothari Road, Nungambakkam, Chennai - 600 034. [Pan:Adwpv-0050-A] (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.:1631/Chny/2025 Acit, Central Circle -1, Trichy. निर्धारण वर्ष / Assessment Year: 2013-14 (अपीलार्थी/Appellant) Karuppanna Gounder Palaniappa Vs. Gounder Mariappan, No.1, 80 Feet Road, Sengunthapuram, Karur – 639 002. [Pan:Agppm-2363-M] (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. Shiva Srinivas, C.I.T. प्रत्यर्थी की ओर से/Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 11.11.2025 घोषणा की तारीख/Date Of Pronouncement : 20.01.2026 :-2-:

292C of the Act will not apply to the facts and circumstances to the case of the appellant. The AO while making the addition has relied upon the statement recorded from Shri. K.S. Ravindran and the evidences collected as discussed supra. 6.2.8 Now the issue before the undersigned is whether the appellant has actually made any deposit amounting Rs.2 Crores

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- Industries Pvt Ltd Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

reassessments and each scheme has its distinct set of conditions and stipulations that must be strictly adhered to. The sub-heading of Section 153A of the Act is "Assessment in case of Search or requisition" which is a special provision for assessment in case of an assessee against whom search u/s.132 or requisition under section 132A

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

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

reassessments and each scheme has its distinct set of conditions and stipulations that must be strictly adhered to. The sub-heading of Section 153A of the Act is "Assessment in case of Search or requisition" which is a special provision for assessment in case of an assessee against whom search u/s. 132 or requisition under section 132A

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

reassess\ncompleted assessments. The same position would prevail in context of\nSection 153C of the Act as well. Here too, the AO is mandated to firstly\nidentify the AYs' to which the material gathered in the course of the\nsearch may relate to and consequently those assessments would face the\nspecter of Section 153C of the Act. The additions here

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

reassess\ncompleted assessments. The same position would prevail in context of\nSection 153C of the Act as well. Here too, the AO is mandated to firstly\nidentify the AYs' to which the material gathered in the course of the\nsearch may relate to and consequently those assessments would face the\nspecter of Section 153C of the Act. The additions here

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

reassess\ncompleted assessments. The same position would prevail in context of\nSection 153C of the Act as well. Here too, the AO is mandated to firstly\nidentify the AYs' to which the material gathered in the course of the\nsearch may relate to and consequently those assessments would face the\nspecter of Section 153C of the Act. The additions here

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

reassess\ncompleted assessments. The same position would prevail in context of\nSection 153C of the Act as well. Here too, the AO is mandated to firstly\nidentify the AYs' to which the material gathered in the course of the\nsearch may relate to and consequently those assessments would face the\nspecter of Section 153C of the Act. The additions here

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JAGANNATHAN SEKAT, CHENNAI

In the result, appeal filed by the In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 132(4) assessee. He further invited our attention to provisions of Section 132(4) assessee. He further invited our attention to provisions of Section 132(4) of the Act and argued that, the authorized officer was empowered to of the Act and argued that, the authorized officer was empowered to of the Act and argued that, the authorized officer