ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

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 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

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JSR INFRA DEVELOPERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

36 taxmann.com 523, wherein the Hon'ble High Court has held that it is not open for the assessee to seek deduction or claim expenditure which has is not open for the assessee to seek deduction or claim expenditure which has is not open for the assessee to seek deduction or claim expenditure which has not been claimed

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment

DEPUTY COMMISSIONER INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

reassessment proceedings for those\nyears were pending.\nDuring the assessment proceedings, the assessee originally claimed\ndeduction of Rs.21,03,27,765/-u/s.36(1)(viia), computed at 7.5%\nof total income plus 10% of aggregate average rural advances, as per\nthe statutory formula. The AO observed that the actual provision\ncreated in the books of account for bad and doubtful debts

DEPUTY COMMISSIONER OF INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

reassessment proceedings for those\nyears were pending.\nDuring the assessment proceedings, the assessee originally claimed\ndeduction of Rs.21,03,27,765/-u/s.36(1)(viia), computed at 7.5%\nof total income plus 10% of aggregate average rural advances, as per\nthe statutory formula. The AO observed that the actual provision\ncreated in the books of account for bad and doubtful debts

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