M/S. FAIRMACS SHIPPING TRANSPORT CO. PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal is allowed/treated as allowed for

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 40(a)(ia) of the Act is applicable to items of expenditure which are deductible u/s. 30 to 38 of the Act. 7.(i) the reassessment

ITO WARD 3, VELLORE vs. AZIZ LEATHER EXPORTS, AMBUR

In the result, the appeal of Revenue is partly allowed for

Bench: Shri Chandra Poojari

reassessment proceedings, the assessee was given due opportunity to clarify on the aspect of deduction of TDS in respect of payment of job work charges for `24,47,614/-. However, the assessee has not availed such opportunity and could not produce any evidence in this aspect. Therefore, the AO had treated the payment of `24,47,614/- made

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

40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section 147 and, therefore, such initiation was sustained

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

40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section 147 and, therefore, such initiation was sustained

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

40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section 147 and, therefore, such initiation was sustained

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

reassessment order dated 30.09.2021 and the ld. CIT(A) order dated 05.04.2024 denying exemption under sections 11 & 12 of the Act. Further, she prays to dismiss the assessee’s grounds of appeal by treating its activities are commercial and not charitable under section 2(15) of the Act. 40

ACIT, CHENNAI vs. M/S. LEELA DISTILLERIES (P) LTD., PONDICHERRY

In the result, all the appeals of the Revenue are allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3) and there is no pendency of assessment so as to 7 I.T.A. Nos.2714-2716/M/16 abate the assessment. Further, where, there

ACIT, CHENNAI vs. M/S. LEELA DISTILLERIES (P) LTD., PONDICHERRY

In the result, all the appeals of the Revenue are allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3) and there is no pendency of assessment so as to 7 I.T.A. Nos.2714-2716/M/16 abate the assessment. Further, where, there

ACIT, CHENNAI vs. M/S. LEELA DISTILLERIES (P) LTD., PONDICHERRY

In the result, all the appeals of the Revenue are allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3) and there is no pendency of assessment so as to 7 I.T.A. Nos.2714-2716/M/16 abate the assessment. Further, where, there

ACIT, CHENNAI vs. M/S. KAYCEE DISTILLERIES, THIRUSSUR

In the result, the appeals of the Revenue in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3) and there is no pendency of assessment so as to abate the assessment. Further, where, there is no seized material found

ACIT, CHENNAI vs. M/S. KAYCEE DISTILLERIES, THIRUSSUR

In the result, the appeals of the Revenue in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3) and there is no pendency of assessment so as to abate the assessment. Further, where, there is no seized material found

ACIT, CHENNAI vs. M/S. KAYCEE DISTILLERIES, THIRUSSUR

In the result, the appeals of the Revenue in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

40(a)(iii) of the Act. Now, the contention of the ld. Counsel for the assessee is that the assessment for the assessment years 2007-08 and 2008-09 already completed either under section 143(1) or 143(3) and there is no pendency of assessment so as to abate the assessment. Further, where, there is no seized material found

NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

reassessment of the return of income of the appellant, within the time frame stipulated under the Act. In this case, the limitation period of six years for reopening the assessment for the year 2011~12 under section 147 of the Act, came to an end on 31.03.2018. In such circumstances, there is no requirement for this court to go into

ACIT, TIRUNELVELI vs. NEW SANTHA STORES, PALAYAMKOTTAI

In the result, the appeal filed by the Revenue and the cross objection filed by the assessee are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकर अपील सं./Ita No.: 1161/Chny/2017 िनधा"रण वष" / Assessment Year: 2009-10 The Asst. Commissioner Of M/S. New Santha Stores, Income Tax, V. Cement Stockists, No.9, Circle – 1, Market Building, Tiruchendur Road, Tirunelveli Palayankottai, Tirunelveli – 627 002. Pan: Aacfn4870D (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co No.: 74/Chny/2017 (In Ita No.1161/Chny/2017) िनधा"रण वष" / Assessment Year: 2009-10 M/S. New Santha Stores, The Asst. Commissioner Of Income Tax, V. Cement Stockists, No.9, Circle – 1, Market Building, Tiruchendur Tirunelveli Road, Palayankottai, Tirunelveli – 627 002. Pan: Aacfn4870D (अपीलाथ"/Appellant) (""यथ"/Respondent) राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit "नधा"रती क" ओर से/Assessee By : Shri G. Baskar, Advocate सुनवाई क" तार"ख/Date Of Hearing : 17.02.2021 घोषणा क" तार"ख/Date Of Pronouncement : 10.03.2021

40(a)(ia) of the Act on amounts paid and payable and therefore, the AO was incorrect in once again considering the issue in light of provisions of section 194C of the Act. As regards applicability of provisions of section 194I of the Act, the ld.CIT(A) held that during the fresh assessment proceedings, the assessee has filed necessary evidences

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

WHEELS INDIA LIMITED,CHENNAI vs. ACIT LTU 1 CHENNAI, CHENNAI

Appeals stand allowed for statistical purposes

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Sonjoy Sarma

section 147 which are for the benefit of the revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings as his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to 'escaped income

ACIT LTU 2 CHENNAI, CHENNAI vs. WHEELS INDIA LIMITED, CHENNAI

Appeals stand allowed for statistical purposes

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Sonjoy Sarma

section 147 which are for the benefit of the revenue and not an assessee, an assessee cannot be permitted to convert the reassessment proceedings as his appeal or revision, in disguise, and seek relief in respect of items earlier rejected or claim relief in respect of items not claimed in the original assessment proceedings, unless relatable to 'escaped income

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

section 142(1) the AR had submitted Income Computation statement. Profit & Loss Account for the AY 2017-18, Balance Sheet as on 31.03 2017, details of assets etc. The AO has not made any addition on the above issue and claim of the assessee was accepted by AO. During reassessment proceedings, the AO noticed from Profit & Loss Account