MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are\nallowed

reassessment and its conditions are completely\ndifferent and distinct for the conditions prescribed by the law laid\ndown by the Hon'ble Supreme Court in the case of in the case of\nPCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra).\nTherefore, in light of the undisputed facts that for the assessment\nyears 2014-15 to 2017-18 assessments remain

NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

34. Section 148 clearly talks of issue of notice by A.O. Meaning thereby, A.O. having jurisdiction over Assessee. In fact, it is his satisfaction which is to be recorded for justifying reopening of assessment / reassessment

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

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

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

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

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

SAPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

SUPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

THANARAJ SUMATHI,MAYILADUTHURAI vs. ITO, WARD-1,, KUMBAKONAM

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

CHAHIDA BEGAM,PUDUCHERRY vs. INCOME TAX OFFICER, WARD 3, PUDUCHERRY RANGE, INCOME TAX OFFICE, PUDUCHERRY

In the result, appeal filed by the assessee is allowed

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

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

LOGANATHAN DHANDAPANI,CHENNAI vs. ACIT, NCC-3(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

FURSHANA GARMENTS,CHENNAI vs. ITO, NCW-11(3), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

34 As regards ITBA step-by-step Document No.2 regarding issuance of notice under Section 148 of the Act, relied upon by Revenue, an internal document cannot depart from the explicit statutory provisions of, or supersede the Scheme framed by the Government under Section 151A of the Act which Scheme is also placed before both the Houses of Parliament

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

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

34. The ld. DR argued that the sale of books and uniforms are not incidental permissible under section 11(4A) of the Act. She submits that the provisions under section 11(4A) of the Act allow business activities incidental to charitable activities to separate account. The Assessing Officer’s finding is correct that no dominant educational activity found

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

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

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

In the result, all the three appeals of the assessee stand allowed

Bench: Shri George George K & Shri S.R. Raghunatha

reassessment. The phrase "to the extent provided in Section 144B of the Act' would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions

ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

reassessment shall be completed in\naccordance with the provisions of this section as it stood immediately before its substitution\nby the Finance Act, 2016 (28 of 2016).]\nExplanation 1.-For the purposes of this section, in computing the period of limitation-\n(i) the time taken in reopening the whole or any part of the proceeding or in giving