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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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\nassessee are dismissed

35 ::\nintroduced by Finance Act, 2021. The timelines for reopening the\nassessment of AYs 2014-15 to 2016-17 impugned before us, being prior\nto AY 2021-22, is required to be tested on the tenets of the first proviso\nto Section 149(1)(b) of the new regime, at the stage of issuance of notice\nunder section

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\nassessee are dismissed

35 ::\nintroduced by Finance Act, 2021. The timelines for reopening the\nassessment of AYs 2014-15 to 2016-17 impugned before us, being prior\nto AY 2021-22, is required to be tested on the tenets of the first proviso\nto Section 149(1)(b) of the new regime, at the stage of issuance of notice\nunder section

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

35 ::\nintroduced by Finance Act, 2021. The timelines for reopening the\nassessment of AYs 2014-15 to 2016-17 impugned before us, being prior\nto AY 2021-22, is required to be tested on the tenets of the first proviso\nto Section 149(1)(b) of the new regime, at the stage of issuance of notice\nunder section

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

35 ::\nintroduced by Finance Act, 2021. The timelines for reopening the\nassessment of AYs 2014-15 to 2016-17 impugned before us, being prior\nto AY 2021-22, is required to be tested on the tenets of the first proviso\nto Section 149(1)(b) of the new regime, at the stage of issuance of notice\nunder section

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

35 ::\nintroduced by Finance Act, 2021. The timelines for reopening the\nassessment of AYs 2014-15 to 2016-17 impugned before us, being prior\nto AY 2021-22, is required to be tested on the tenets of the first proviso\nto Section 149(1)(b) of the new regime, at the stage of issuance of notice\nunder section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

35 ::\nintroduced by Finance Act, 2021. The timelines for reopening the\nassessment of AYs 2014-15 to 2016-17 impugned before us, being prior\nto AY 2021-22, is required to be tested on the tenets of the first proviso\nto Section 149(1)(b) of the new regime, at the stage of issuance of notice\nunder section

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

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

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

35. In view of the aforesaid discussions, it is by now very clear that the\nprocedure to be followed by the respondent-Department upon treating the\nnotices issued for reassessment being under section 148A, the subsequent\nproceedings was mandatorily required to be undertaken under the\nsubstituted provisions as laid down under the Finance Act, 2021. In the\nabsence of which

S. ARAVIND,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

K. PARAMASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

K. BASKAR,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri