DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MEADOW INFRASTRUCTURE PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

section 2(22)(e) of the Act. 18. The only issue to be adjudicated in the instant case is whether the loans advanced by M/s. IG3 Infra Limited to the assessee companies can be brought to tax in the hands of the assessee companies as deemed dividend u/s.2(22)(e) of the Act. Before going in to the case

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MUKILANSTRUCTURALS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

section 2(22)(e) of the Act. 18. The only issue to be adjudicated in the instant case is whether the loans advanced by M/s. IG3 Infra Limited to the assessee companies can be brought to tax in the hands of the assessee companies as deemed dividend u/s.2(22)(e) of the Act. Before going in to the case

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S.MINAL CONSTRACTORS AND BUILDERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

section 2(22)(e) of the Act. 18. The only issue to be adjudicated in the instant case is whether the loans advanced by M/s. IG3 Infra Limited to the assessee companies can be brought to tax in the hands of the assessee companies as deemed dividend u/s.2(22)(e) of the Act. Before going in to the case

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S.MAC QUALITY BUILDERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

section 2(22)(e) of the Act. 18. The only issue to be adjudicated in the instant case is whether the loans advanced by M/s. IG3 Infra Limited to the assessee companies can be brought to tax in the hands of the assessee companies as deemed dividend u/s.2(22)(e) of the Act. Before going in to the case

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

2)\nFD Interest as 51,56,40,547 51,56,40,547\nIOS\nFor AY 2010-11, reassessment proceedings were initiated under Section

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

ACIT, CHENNAI vs. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

2)\n66,48,047\n51,56,40,547\n51,56,40,547\nFD Interest as\nIOS\nFor AY 2010-11, reassessment proceedings were initiated under\nSection 148 of the Act and order u/s.143(3) r.w.s.147 was\npassed on 24.03.2016 without any disallowance/addition.\n4.3 Search and seizure operations under Section

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 made thereon is not maintainable when there is time to complete scrutiny assessment under section 143(3) of the Act by issuing a notice under section 143(2) of the Act in response to the revised return of income filed under section 139(5) of the Act. He drew our attention to the decision of the Hon’ble Jurisdictional