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

1)(b) read with Section 153A of the Act. We thus\ncountenance the following findings rendered by the Ld. CIT(A) holding the\nAO's action of initiation of reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries

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

1)(b) read with Section 153A of the Act. We thus\ncountenance the following findings rendered by the Ld. CIT(A) holding the\nAO's action of initiation of reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries

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

1)(b) read with Section 153A of the Act. We thus\ncountenance the following findings rendered by the Ld. CIT(A) holding the\nAO's action of initiation of reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries

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

1)(b) read with Section 153A of the Act. We thus\ncountenance the following findings rendered by the Ld. CIT(A) holding the\nAO's action of initiation of reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries

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

41,057/-. The return of income filed u/s 153C of the Act was also accompanied with the report of income filed u/s 153C of the Act was also accompanied with the report of income filed u/s 153C of the Act was also accompanied with the report of chartered accountant in Form 10CCB, as of chartered accountant in Form 10CCB

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

1)(b) read with Section 153A of the Act. We thus\ncountenance the following findings rendered by the Ld. CIT(A) holding the\nAO's action of initiation of reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries

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

1)(b) read with Section 153A of the Act. We thus\ncountenance the following findings rendered by the Ld. CIT(A) holding the\nAO's action of initiation of reassessment proceedings u/s 148 of the Act\nITA Nos.1163, 1256, 1257 & 1259/Chny/2025 &\nITA Nos.1231, 1232, 1234 & 1236/Chny/2025\n(AYs 2013-14 to 2016-17)\nM/s. Southern Agrifurane Industries

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

reassessment to the six assessment years will be examined with reference to such d examined with reference to such date." 9. It is evident on a plain interpretation of section 153C(1) that the 9. It is evident on a plain interpretation of section 153C(1) that the 9. It is evident on a plain interpretation of section 153C(1

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

reassessment to the six assessment years will be examined with reference to such d examined with reference to such date." 9. It is evident on a plain interpretation of section 153C(1) that the 9. It is evident on a plain interpretation of section 153C(1) that the 9. It is evident on a plain interpretation of section 153C(1

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

reassessment to the six assessment years will be\nexamined with reference to such date.\"\n9. It is evident on a plain interpretation of section 153C(1) that the\nParliamentary intent to enact the proviso was to cater not merely to\nthe question of abatement but also with regard to the date from\nwhich the six year period

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

reassessment to the six assessment years will be\nexamined with reference to such date.\"\n9. It is evident on a plain interpretation of section 153C(1) that the\nParliamentary intent to enact the proviso was to cater not merely to\nthe question of abatement but also with regard to the date from\nwhich the six year period

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment proceedings U/s 153A or 147 were initiated on the assessee, the assessee is not entitled to claim the deduction which was not claimed earlier while filing the return u/s 139(1), this view is well supported by the judgments in the case of Sun Engineering Works (P) Ltd., Goetze (India) Ltd., K.P. Varghese and other cases, referred to supra

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment proceedings U/s 153A or 147 were initiated on the assessee, the assessee is not entitled to claim the deduction which was not claimed earlier while filing the return u/s 139(1), this view is well supported by the judgments in the case of Sun Engineering Works (P) Ltd., Goetze (India) Ltd., K.P. Varghese and other cases, referred to supra

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment proceedings U/s 153A or 147 were initiated on the assessee, the assessee is not entitled to claim the deduction which was not claimed earlier while filing the return u/s 139(1), this view is well supported by the judgments in the case of Sun Engineering Works (P) Ltd., Goetze (India) Ltd., K.P. Varghese and other cases, referred to supra

ST. JOHN FREIGHT SYSTEMS PVT. LTD.,,TUTUCORIN vs. DCIT, CC-1,, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment proceedings U/s 153A or 147 were initiated on the assessee, the assessee is not entitled to claim the deduction which was not claimed earlier while filing the return u/s 139(1), this view is well supported by the judgments in the case of Sun Engineering Works (P) Ltd., Goetze (India) Ltd., K.P. Varghese and other cases, referred to supra

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), CHENNAI, CHENNAI vs. BONDALAPATI SHIVAJI RAO, CHENNAI

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

reassessment to the six assessment years will be examined with reference to such date." 9. It is evident on a plain interpretation of section 153C(1) that the Parliamentary intent to enact the proviso was to cater not merely to the question of abatement but also with regard to the date from which the six year period

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

reassess such income and also any other income chargeable to tax ncome and also any other income chargeable to tax ncome and also any other income chargeable to tax which has escaped assessment and which comes to his notice which has escaped assessment and which comes to his notice which has escaped assessment and which comes to his notice subsequently

P. KARUNANITHI,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

reassess such income and also any other income chargeable to tax ncome and also any other income chargeable to tax ncome and also any other income chargeable to tax which has escaped assessment and which comes to his notice which has escaped assessment and which comes to his notice which has escaped assessment and which comes to his notice subsequently