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 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

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

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

ii) if it is barred at the time when the notice is sought to be\nissued because of the \"time limits specified under the provisions of \"148,\n153A, 153C of the old regime. Hence, in terms of the proviso, the powers\nof AO is curtailed to issue notice under Section 148 of the new regime

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

ii) if it is barred at the time when the notice is sought to be\nissued because of the \"time limits specified under the provisions of\"148,\n153A, 153C of the old regime. Hence, in terms of the proviso, the powers\nof AO is curtailed to issue notice under Section 148 of the new regime

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

M/S JAYA EDUCATIONAL TRUST,THIRUVALLUR vs. DCIT, CC1(2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

ii) of the Act, if any part of income or any property of the trust is used or 27 I.TA. Nos. 2915, 3114 & 3115/Chny/2019 916/Chny/2020 applied directly or indirectly for the benefit of any persons referred to in sub- section (3) of section 13 of the Act, then the trust will lose the benefit of exemption provided u/s.11

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

ii) of the Act, if any part of income or any property of the trust is used or 27 I.TA. Nos. 2915, 3114 & 3115/Chny/2019 916/Chny/2020 applied directly or indirectly for the benefit of any persons referred to in sub- section (3) of section 13 of the Act, then the trust will lose the benefit of exemption provided u/s.11

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

ii) of the Act, if any part of income or any property of the trust is used or 27 I.TA. Nos. 2915, 3114 & 3115/Chny/2019 916/Chny/2020 applied directly or indirectly for the benefit of any persons referred to in sub- section (3) of section 13 of the Act, then the trust will lose the benefit of exemption provided u/s.11

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

ii) of the Act, if any part of income or any property of the trust is used or 27 I.TA. Nos. 2915, 3114 & 3115/Chny/2019 916/Chny/2020 applied directly or indirectly for the benefit of any persons referred to in sub- section (3) of section 13 of the Act, then the trust will lose the benefit of exemption provided u/s.11

PONDICHERRY AGRO FOODS PVT. LTD.,CHENNAI vs. ITO, CORPORARE WARD-5(2),, CHENNAI

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

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1753/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 Pondicherry Agro Foods P Ltd., The Income Tax Officer, No.1B, 1St Floor, Arihant Jashn, Vs. Corporate Ward -5(2), Rukmani Lakshmipathy Salai, Chennai. 38 (Old 121), Egmore, Chennai – 600 008. Pan: Aaacp 4418N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Anandd Babunath, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit

35(1) (ii) of the Act is not tenable and erroneously upheld the addition as per the assessment order completed u/s. 143(3) r.w.s 147 of the IT Act, 1961 dated 20.12.2016. 5. That the Ld. AO further reiterated the sworn statement of the director of the Herbicure Healthcare Bio-Herbal Research Foundation (HHBHRF) which was never confronted

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

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 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