DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MRF LIMITED, CHENNAI

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

35(2AB) as per the Form 3CL issued by the DSIR without considering the fact that the addition was made based on findings of the survey u/s 133A in the case of the Assessee. 4. The Ld. CIT(A) erred in relying on the judgment of Hon'ble ITAT in assessee's own case of the Asst Year

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

INDUSTRIAL MINERAL CO, 100%EOU,TUTICORIN vs. ACIT,CENTRAL CIRCLE-1, MADURAI, MADURAI

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

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

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

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

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

M/S. ARCHANA FEMALE CHILD TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

Section 147 as above, it clearly implies that what is stressed therein is the assessment / reassessment of escaped Income which the AR himself has not disputed to have not taken place till date in the instant impugned case by way of a proper assessment order assessing / reassessing escaped income chargeable to tax which is best illustrated by the inescapable fact

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

35 Further, in our view, there is no question of concurrent jurisdiction of the JAO and the FAO for issuance of notice under Section 148 of ITA Nos.1165 & 1166/Chny/2025 (AYs 2015-16 & 2016-17) Mr. Manickam Chettiar Velmurugan :: 10 :: the Act or even for passing assessment or reassessment