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

reassess such income. Proviso to section 147 of course requires that where the assessment under sub-section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of the four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped

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

reassess such income. Proviso to section 147 of course requires that where the assessment under sub-section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of the four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped

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

reassess such income. Proviso to section 147 of course requires that where the assessment under sub-section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of the four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

reassess under section 147 or pass an order enhancing the assessment or reducing the refund of the assessee under section 154.” 10. It has been made clear by the Hon’ble High Court that sub -section (2) does not ifso facto empower the AO to apply the method prescribed by Rules straightaway without considering whether the claim made

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

reassess under section 147 or pass an order enhancing the assessment or reducing the refund of the assessee under section 154.” 10. It has been made clear by the Hon’ble High Court that sub -section (2) does not ifso facto empower the AO to apply the method prescribed by Rules straightaway without considering whether the claim made

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

Bench: This Tribunal.

56(2) (vii)(c) (as in Rs. 92,95,305/- paras 15.1 to 15.5) Gross Total income Rs. 2,37,25,823/- Less: Deduction under Chapter VIA Rs. 2,60,72,169/- Rs. 1,00,000/- Total income Rs. 2,59,72,169/- Assessed income Rs. 2,59,72,170/- 18. The assessee aggrieved by the passing of the said

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

56(2) (vii)(c) (as in Rs. 92,95,305/- paras 15.1 to 15.5) Gross Total income Rs. 2,37,25,823/- Less: Deduction under Chapter VIA Rs. 2,60,72,169/- Rs. 1,00,000/- Total income Rs. 2,59,72,169/- Assessed income Rs. 2,59,72,170/- 16. The assessee aggrieved with the passing of the said

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

viii)(c) of the Act at para 6.6.5 of the impugned order of the first appeal. 25. The assessee aggrieved with the said order of the Ld.CIT(A) had filed the present appeal before us, by raising grounds of appeal challenging the validity of the assumption of jurisdiction u/s.153A of the Act as well as on merits. 26. Since

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

viii)(c) of the Act at para 6.6.5 of the impugned order of the first appeal. 25. The assessee aggrieved with the said order of the Ld.CIT(A) had filed the present appeal before us, by raising grounds of appeal challenging the validity of the assumption of jurisdiction u/s.153A of the Act as well as on merits. 26. Since

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

viii)(c) of the Act at para 6.6.5 of the impugned order of the first appeal. 25. The assessee aggrieved with the said order of the Ld.CIT(A) had filed the present appeal before us, by raising grounds of appeal challenging the validity of the assumption of jurisdiction u/s.153A of the Act as well as on merits. 26. Since

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

viii)(c) of the Act at para 6.6.5 of the impugned order of the first appeal. 25. The assessee aggrieved with the said order of the Ld.CIT(A) had filed the present appeal before us, by raising grounds of appeal challenging the validity of the assumption of jurisdiction u/s.153A of the Act as well as on merits. 26. Since

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

viii)(c) of the Act at para 6.6.5 of the impugned order of the first appeal. 25. The assessee aggrieved with the said order of the Ld.CIT(A) had filed the present appeal before us, by raising grounds of appeal challenging the validity of the assumption of jurisdiction u/s.153A of the Act as well as on merits. 26. Since

JOTHI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(2), CHENNAI

56(2) (vii)(c) (as in\nparas 15.1 to 15.5)\nRs. 92,95,305/-\nRs. 2,37,25,823/-\nGross Total income\nRs. 2,60,72,169/-\nLess: Deduction under Chapter VIA\nRs.\n1,00,000/-\nTotal income\nRs. 2,59,72,169/-\nAssessed income\nRs. 2,59,72,170/-\n\n17.\nThe assessee aggrieved by the passing

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary for us to go into the merits of additions made in respect of other items of additions. Thus all other grounds of appeal filed by the Revenue stand dismissed. In the result

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary for us to go into the merits of additions made in respect of other items of additions. Thus all other grounds of appeal filed by the Revenue stand dismissed. In the result

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary for us to go into the merits of additions made in respect of other items of additions. Thus all other grounds of appeal filed by the Revenue stand dismissed. In the result

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary for us to go into the merits of additions made in respect of other items of additions. Thus all other grounds of appeal filed by the Revenue stand dismissed. In the result

SUNDARAKRISHNAN,CHENNAI vs. PCIT, COIMBATORE

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1935/Chny/2024 िनधा"रण वष" / Assessment Year: 2014-15 Sundarakrishnan, Principal Commissioner Of No. 15, 5Th Main Road, V. Income Tax, Kasturba Nagar, Coimbatore -1. Adyar – 600 020. [Pan: Arbps-4782-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Y. Sridhar, Fca ""यथ" क" ओर से/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 04.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.02.2025 आदेश /O R D E R Per S. R. Raghunatha:

reassessment order. 5. That the appellant craves, leave to add, alter, amend or vary and/or withdraw any or all of the aforesaid grounds of Appeal or at time of hearing of the above appeal.” 4. The Assessee is an individual had filed the Return of Income for A.Y. 2014-15 on 20.01.2015 admitting a taxable :-3-: ITA. No: 1935/Chny/2024 income

V.R.VENKAATACHALAM,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.2634, 2635, 2636, 2637, 2638 & 2639/Mds/2014 ("नधा"रण वष" / Assessment Years : 2006-07, 2007-08, 2008-09, 2009- 10, 2010-11 & 2011-2012)

56 Binny Ltd 17500000 17500000 57 Virion Chemicals & 5425000 Distilleries Ltd 58 Advance for land 37437564 59 TCP 18686728 60 Thiruvalluvar textiles p. ltd 51878171 61 Jagathra holdings p. ltd 100000 62 Four square realtors p. ltd 15519 63 Sun breeze realtors p. ltd 15519 I.T.A.Nos.2634 to 2639/Mds/2014 :- 11 -: Total 524595954 547154871 (f) The assessee vide his letter dated