JESUDASON BIJI ,CHENNAI vs. OFFICE OF INCOME TAX OFFICER INT. TAXN WARD1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

reassessment notices ITA No.567 /Chny/2024 for AY 2014-15 & SP No.24/Chny/2024 for AY 2014-15 Shri Jesudason Biji :: 16 :: has also observed that if the law permits the revenue to take further steps in the matter they shall be at liberty to do so. 6. Having taken note of the substituted sections 147-151 of the Act by the Finance

VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment order was passed without application of mind. The Ld. CIT, der was passed without application of mind. The Ld. CIT, der was passed without application of mind. The Ld. CIT, DR therefore urged us not to interfere with the order of the Ld. Pr.CIT. DR therefore urged us not to interfere with the order of the Ld. Pr.CIT

VANAVIL ESTATE,CHENNAI vs. PCIT(CENTRAL), CHENNAI

In the result, the appeal for both AYs 2017

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment order was passed without application of mind. The Ld. CIT, der was passed without application of mind. The Ld. CIT, der was passed without application of mind. The Ld. CIT, DR therefore urged us not to interfere with the order of the Ld. Pr.CIT. DR therefore urged us not to interfere with the order of the Ld. Pr.CIT

HITESH KUMAR PRITHVIRAJ KAWAD,CHENNAI vs. DCIT,NON-CORPORTEN CIRCLE-4(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

section 54F of the Act, on the following grounds: “1. The NFAC violated the core principles of reassessment by no disposing

KIRTHISIMHAN WIJEYANAYAKE,COIMBATORE vs. ACIT NON CORPORATE CIRCLE 2, COIMBATORE

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

reassessment proceedings and deduction u/s 54. The correct provision under which the deduction would be available to the assessee is Sec.54F and not Sec.54 since the assessee has parted with land and invested the same in residential properties. Therefore, the claim of the assessee would be ascertained at the threshold of provisions of Sec.54F. 6. We find that the original

GOLDEN VATS PRIVATE LIMITED,CHENNAI vs. ACIT, CENTRAL CIRCLE 3(2), CHENNAI

In the result, the appeal filed by the assessee is allowed and the order passed by the Commissioner dated 14

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.416/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) M/S. Golden Vats Private Limited Acit बनाम New No.272, 3Rd Floor, Central Circle-3(2), Avvai Shanmugam Salai, Chennai. / Vs. Gopalapuram , Chennai-600 086. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccg-9782-G (अपीलाथ"/Appellant) : (!"थ" / Respondent)

reassessment u/s 147. The assessee also assailed the proceedings on 6 the ground that sanction issued u/s 151 was given in a mechanical and casual manner. The assessee has also challenged the legality of proceedings u/s 153C. Since the larger issues including legal issues are already pending before first appellate authority, the order passed by Ld. AO, in our considered

VG RAJAMANI AGENCIES PVT. LTD.,COIMBATORE vs. PCIT-1, COIMBATORE

In the result, the appeal filed by the assessee is allowed and the order passed by the Commissioner dated 14

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.812/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) M/S. V.G. Rajamani Agencies Pvt. Ltd. Pcit-1 बनाम/ Vs. 66, Subbiah Mudaliar Street, Coimbatore. Thomas Street, Coimbatore-641 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcv-1589-R (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri S. Sridhar (Advocate) Erode - Ld.Ar !"थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 09-01-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

reassessment proceedings before first appellate authority which was pending for adjudication at the time of revision of the order. In such a case, the ratio of decision of Hon’ble Madras High Court in the case of Smt. Renuka Philip vs. ITO (409 ITR 567) would apply wherein it was held as under: - 22. The above explanation makes it clear

ADHI KUMARA GURU,CHENNAI vs. DCIT, NCC-22(1), CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaमाननीय "ी मनु कुमार िग"र, "ाियक सद" एवं माननीय "ी अिमताभ शु"ा, लेखा सद" के सम"

54F. These aspects could very well have been, and in substance were, examined during could very well have been, and in substance were, examined during could very well have been, and in substance were, examined during the earlier reassessment proceedings. No new tangible material the earlier reassessment proceedings. No new tangible material the earlier reassessment proceedings. No new tangible material

R.RAJAGOPAL TONDAIMAN,TRICHY vs. DCIT CENTRAL CIRCLE-1, TRICHY

In the result, the appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.525/Chny/2020 िनधा"रण वष"/Assessment Year: 2010-11 Sri R. Rajagopal Tondaiman, Vs. The Deputy Commissioner Of Old No. 4-D, New No. 22, Collector Income Tax, Office Road, Trichy 620 001. Central Circle 1, Trichy. [Pan:Afbpr0712E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Viswanathan, Ca ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 15.09.2022 घोषणा की तारीख /Date Of Pronouncement : 12.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Trichy, Dated 30.12.2019 Relevant To The Assessment Year 2010-11. 2. Facts Are, In Brief, That The Assessee Is A Hereditary Of Raja Of Pudukottai & Stated That He Is Assessed To Tax In The Status Of Huf & Individual. The Property At Cenotaph Road, Chennai Was Given To M/S. Doshi Housing Ltd. On A Development Agreement Entered Into On 30.01.2006 Through A Power Of Attorney. The Assessing Officer Has 2

54F of the Act. On appeal, the ld. CIT(A) confirmed the assessment order passed by the Assessing Officer. 3. On being aggrieved, the assessee is in appeal before the Tribunal. The ld. Counsel for the assessee has submitted that the reopening of assessment is beyond four years, reasons are not based on any evidence or any tangible materials

SAINULAPTHEEN KATHEEJA UMMA,KANYAKUKUMARI vs. ITO, WARD-2, , NAGERCOIL

In the result, the appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.264/Chny/2022 िनधा"रण वष"/Assessment Year: 2015-16 Smt. Sainulaptheen Katheeja Umma, Vs. The Income Tax Officer, 25/72, B.O.C. Street, Marthandam Ward – 2, Post, Kanyakumari District, Nagercoil. Tamil Nadu 629 165. [Pan:Avopk8733F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 06.02.2023 घोषणा की तारीख /Date Of Pronouncement : 15.02.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax/Cit 1, Madurai, Dated 05.05.2020 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] Relevant To The Assessment Year 2015-16. 2. The Appeal Filed By The Assessee Is Delayed By 662 Days In Filing The Appeal Due To Outbreak Of Covid-19 Pandemic & Accordingly, The Delay In Filing The Appeal Is Condoned & Admitted For Adjudication.

reassessment proceedings has assigned certain reasons for coming to a conclusion that the assessee is entitled for deduction under Section 54F

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

54F of the Act, the Assessing Officer considered 50% of the investments whereas 100% investments were done through banking channels. Therefore, the assessee stated that it cannot be said that correct particulars of income were not furnished. The assessee ITA Nos.1164 & 1165/Chny/2023 :: 24 :: further pointed out that he was in need of funds for purchase of a new flat, that

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

54F of the Act, the Assessing Officer considered 50% of the investments whereas 100% investments were done through banking channels. Therefore, the assessee stated that it cannot be said that correct particulars of income were not furnished. The assessee ITA Nos.1164 & 1165/Chny/2023 :: 24 :: further pointed out that he was in need of funds for purchase of a new flat, that

MOSBACHER INDIA LLC,CHENNAI vs. ADDL. DIT, CHENNAI

In the result, the appeal is partly allowed in the terms indicated above

54F, 54G and 54 H, be chargeable to income tax under the head capital gains and shall be deemed to be the income of the previous year in which the transfer took place”. The gains on transfer of these participation rights is, therefore, required to be I.T.A. No. 1085/CHNY/2015 Assessment year: 2010-11 Page 15 of 21 treated as capital

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, In respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

reassess taking into consideration the other material in respect of completed assessments/unabated assessments. Meaning thereby, In respect of completed/unabated assessments, no addition can be made by the AO in absence of any incriminating material found during the course of search under Section 132 or requisition under Section 132A of the Act, 1961. However, the completed/unabated assessments can be re-opened

ACIT, NAGERCOIL vs. SHRI J. RAJ PRABHU, NAGERCOIL

In the result, the Revenue appeal is dismissed

Bench: Shri A. Mohan Alankamony & Shri G. Pavan Kumar

54F of the Act nor produced any evidence to the extent of Rs. 4,09,239/- and in respect of second claim of exemption of Rs. 66,95,823/-. The Assessing Officer dealt on the disputed issue at Page 3 of the order and observed that the assessee could not produce the evidence of construction or purchase of Residential house

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen before learned CIT(A) from consequential

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen before learned CIT(A) from consequential

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen before learned CIT(A) from consequential