MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, CHENNAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

KAG INDIA PRIVATE LIMITED,CHENNAI vs. PCIT CENTRAL CIRCLE -2, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1366/Chny/2024 िनधा"रणवष" / Assessment Year: 2020-21 The Pcit (Central), M/S. Kag India Pvt Ltd., V. Chennai -2. No. 264/15-1, Sathiyanathan Complex, Velachery Road, East Tambaram, Chennai – 600 059. [Pan: Aadck-5381-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Y. Sridhar, Fca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तार"ख/Date Of Hearing : 21.11.2024 घोषणा क" तार"ख/Date Of Pronouncement : 11.12.2024 आदेश /O R D E R

reassessed has the effect of reducing the loss or converting such loss into income.” Having considered the facts, in this case, it is undisputed that assessee’s case would not fall in any of the sub clause (b) to (g) of sub-section (2) of Section 270A of the Act, and the only clause which remains is clause

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

50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section

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

50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section

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

50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section

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 or recomputation under section 147. Under sub~section (1) to section 148, the assessing officer shall issue notice to the assessee requiring him/her to furnish a return of income in respect of which he/she is assessable for the relevant assessment year; and under sub-section (2) to section 148, the assessing officer shall before issuing any notice under this

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

50 I.T.A. Nos.1667 to 1670/Chny/24 notice dated 23.09.2019 issued under section 148 of the Act is not maintainable and the reassessment

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassess the income of the other person in accordance with the provisions of section Subramaniam Kathiresan :: 15 :: 153A, if, that Assessing officer is satisfied that the books of account or documents or assets seized or requisitioned have a bearing on the determination of the total income of such other person”. [Emphasis given by us]. Further, it is to be noted

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

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

reassess the income of the person to whom such assets/books belong in accordance with Section 153A of the Act. 23. In the present case, the Assessee had claimed that the assessments for the concerned assessment years were not pending on the date of recording of satisfaction by the AO and, therefore, would not abate by virtue of the second proviso

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

reassess the income of the person to whom such assets/books belong in accordance with Section 153A of the Act. 23. In the present case, the Assessee had claimed that the assessments for the concerned assessment years were not pending on the date of recording of satisfaction by the AO and, therefore, would not abate by virtue of the second proviso

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

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 | The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit Assessee By : Mr. N. Arjun Raj, Advocate सुनवाईकीतारीख/Date Of Hearing : 08.10.2025 घोषणाकीतारीख / Date Of Pronouncement : 21.11.2025

reassessment in respect of a relevant assessment year unless the conditions as stipulated in the fourth proviso are satisfied. It is seen that, the expression "relevant assessment year" is defined under Explanation 1 to sub-section (i) of Section 153A of the Act to mean a year that falls beyond the period of six assessment years preceding the assessment year

POWER SECURITY CORP. PVT. LTD.,CHENNAI vs. ITO, CORP. WARD-5(2), CHENNAI

The appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2943/Chny/2025 िनधा$रण वष$ /Assessment Year: 2013-14

section 149, since the alleged escaped income was less than 50 lakhs, and therefore the reassessment proceedings were void ab initio

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

In the result, all the three appeals of the assessee stand allowed

Bench: Shri George George K & Shri S.R. Raghunatha

reassessment. The phrase "to the extent provided in Section 144B of the Act' would mean that the restriction provided in Section 144B of the Act, such as keeping the International Tax Jurisdiction or Central Circle Jurisdiction out of the ambit of Section 144B of the Act would also apply under the Scheme. Further the exceptions