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35 results for “reassessment”+ Section 36(1)(viia)clear

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Key Topics

Section 143(3)58Section 14753Section 14847Section 36(1)(viia)42Deduction26Section 26322Reassessment22Reopening of Assessment22Addition to Income21Section 143(2)

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

ITA 2700/CHNY/2025[2015-16]Status: DisposedITAT Chennai28 Jan 2026AY 2015-16
Section 14ASection 36(1)(viia)

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

ITA 2699/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Jan 2026AY 2013-14
Section 14ASection 36(1)(viia)

Showing 1–20 of 35 · Page 1 of 2

18
Disallowance18
Section 143(1)16

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

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

ITA 981/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 855/CHNY/2020[2011-12]Status: DisposedITAT Chennai18 Oct 2023AY 2011-12

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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-II,, CUDDALORE

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

ITA 857/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 858/CHNY/2020[2009-10]Status: DisposedITAT Chennai18 Oct 2023AY 2009-10

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 2645/CHNY/2019[2016-17]Status: DisposedITAT Chennai18 Oct 2023AY 2016-17

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 854/CHNY/2020[2010-11]Status: DisposedITAT Chennai18 Oct 2023AY 2010-11

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 856/CHNY/2020[202-13]Status: DisposedITAT Chennai18 Oct 2023

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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 DHARMAPURI DISTRICT CENTRAL CO-OP. BANK LTD.,DHARMAPURI vs. JCIT, SALEM

The appeal stand partly allowed for statistcial purposes to the extent indicated in the order

ITA 1188/CHNY/2016[2008-09]Status: DisposedITAT Chennai13 Jul 2022AY 2008-09

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./ Ita No.1188/Chny/2016 (िनधा1रण वष1 / Assessment Year: 2008-09) The Dharmapuri District Central Jcit बनाम/ Co-Operative Bank Ltd. Range-Iii No.81/10H, Bye Pass Road, Salem. Vs. Dharmapuri – 636 701 "थायी लेखा सं./जीआइ आर सं./Pan/Gir No. Aaaat-3148-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओरसे/ Assessee By : Shri T. Vasudevan (Advocate) – Ld. Ar ""थ" की ओरसे/Revenue By : Shri Arv Sreenivasan (Addl.Cit) – Ld. Dr सुनवाई की तारीख/ : 19-04-2022 Date Of Hearing घोषणा की तारीख / : 13-07.2022 Date Of Pronouncement

For Appellant: Shri T. Vasudevan (Advocate) – Ld. ARFor Respondent: Shri ARV Sreenivasan (Addl.CIT) – Ld. DR
Section 143(3)Section 147Section 234BSection 36Section 36(1)(viia)

section 36(1)(viia) of the Act had to be restricted to that amount only. Since the language of the statute is clear and is not capable of any other interpretation, we are satisfied that no substantial question of law arises in this appeal for consideration by this court. 10. The appeal is, accordingly, dismissed. No costs. 8. Similar

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1803/CHNY/2014[2009-10]Status: DisposedITAT Chennai28 Dec 2016AY 2009-10

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1801/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

CITY UNION BANK LIMITED,KUMBAKONAM vs. JCIT, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 2034/CHNY/2014[2007-08]Status: DisposedITAT Chennai28 Dec 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1671/CHNY/2014[2007-08]Status: DisposedITAT Chennai28 Dec 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1802/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 1804/CHNY/2014[2010-11]Status: DisposedITAT Chennai28 Dec 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

CITY UNION BANK LIMITED,KUMBAKONAM vs. JCIT, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

ITA 2035/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed

TAMILNADU STATE APEX CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

The appeal of the assessee is partly allowed for statistical purpose

ITA 2177/CHNY/2014[2007-2008]Status: DisposedITAT Chennai06 Apr 2016AY 2007-2008

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri. R. Viswanathan, C.AFor Respondent: Shri R. Mohan, CIT, DR
Section 142(1)Section 143(1)Section 143(3)Section 148Section 36Section 36(1)(viia)

section 36(viia) implies that an expenditure which an Assessee may subtract from Gross Total Income to determine taxable income" 2.3 The Ld CIT(A) failed to appreciate and consider provision already made by the Appellant in the books of account towards for NPA and Bad debt’’. 2.4 The Ld CIT(A) grossly erred in not considering the basis

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), NUNGAMBAKKAM vs. IDFC LIMITED, TEYNAMPET

In the result, both the appeals filed by the Revenue are dismissed

ITA 818/CHNY/2024[2016-17]Status: DisposedITAT Chennai04 Sept 2024AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.818 & 819/Chny/2024 िनधा"रण वष"/Assessment Year: 2016-17 The Assistant Commissioner Of Vs. Idfc Limited, 4Th Floor, Capitale Tower, No. 555, Income Tax, Corporate Circle 1(1), Anna Salai, Thiru Vi Ka Kudiyiruppu, Chennai 600 034. Teynampet, Chennai 600 018. [Pan:Aaaci2663N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V. Nandakumar, Cit ""थ" की ओर से/Respondent By : Shri Ketan Ved, C.A. सुनवाई की तारीख/ Date Of Hearing : 29.08.2024 घोषणा की तारीख /Date Of Pronouncement : 04.09.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Revenue Are Directed Against Separate Orders Dated Both Dated 21.09.2022 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. Since The Issue Raised In Both The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To Hear All These Appeals Together & Pass Consolidated Order For The Sake Of Convenience.

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri Ketan Ved, C.A
Section 143(3)Section 147Section 148Section 14ASection 36(1)(viia)Section 36(1)(viii)

reassessment by making, inter alia, addition on account of enhanced disallowance under section 14A read with Rule 8D, disallowance under section 36(1)(viii), enhanced disallowance under section 36(1)(viia

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), NUNGAMBAKKAM vs. IDFC LIMITED, TEYNAMPET

In the result, both the appeals filed by the Revenue are dismissed

ITA 819/CHNY/2024[2016-17]Status: DisposedITAT Chennai04 Sept 2024AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.818 & 819/Chny/2024 िनधा"रण वष"/Assessment Year: 2016-17 The Assistant Commissioner Of Vs. Idfc Limited, 4Th Floor, Capitale Tower, No. 555, Income Tax, Corporate Circle 1(1), Anna Salai, Thiru Vi Ka Kudiyiruppu, Chennai 600 034. Teynampet, Chennai 600 018. [Pan:Aaaci2663N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V. Nandakumar, Cit ""थ" की ओर से/Respondent By : Shri Ketan Ved, C.A. सुनवाई की तारीख/ Date Of Hearing : 29.08.2024 घोषणा की तारीख /Date Of Pronouncement : 04.09.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Revenue Are Directed Against Separate Orders Dated Both Dated 21.09.2022 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. Since The Issue Raised In Both The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed To Hear All These Appeals Together & Pass Consolidated Order For The Sake Of Convenience.

For Appellant: Shri V. Nandakumar, CITFor Respondent: Shri Ketan Ved, C.A
Section 143(3)Section 147Section 148Section 14ASection 36(1)(viia)Section 36(1)(viii)

reassessment by making, inter alia, addition on account of enhanced disallowance under section 14A read with Rule 8D, disallowance under section 36(1)(viii), enhanced disallowance under section 36(1)(viia