ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. LIFE LINE AUTO FINANCE, KARUR

67\nTTJ 247 (All).\n6.5.11 In particular, it is of critical importance that the evidence to\ncorroborate the narrations indicating payments in the seized material\nfound with a third party is available with specific reference to the fact\nregarding actual transfer of money from the said third party to the\nrecipient named in the said entries in the seized material

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

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY MOOLIMANGALAM VAISHNAVA PRIYA, CHENNAI

In the result, all the three appeals of the Revenue are dismissed

67 TTJ 247 (All).\n6.2.13 In particular, it is of critical importance that the evidence to corroborate\nthe narrations indicating payments in the seized material found with a third\nparty is available with specific reference to the fact regarding actual transfer\nof money from the said third party to the recipient named in the said entries\nin the seized material

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE,TRICHY vs. MARAGATHAMANI SHANMUGAM, KARUR

In the result, all the three appeals of the Revenue are dismissed

67 TTJ 247 (All).\n6.2.13 In particular, it is of critical importance that the evidence to corroborate\nthe narrations indicating payments in the seized material found with a third\nparty is available with specific reference to the fact regarding actual transfer\nof money from the said third party to the recipient named in the said entries\nin the seized material

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, TRICHY, INCOME TAX OFFICE, TRICHY vs. KARUPPANNA GOUNDER PALANIAPPA GOUNDER MARIAPPAN, KARUR

In the result, all the three appeals of the Revenue are dismissed

67 TTJ 247 (All).\n6.2.13 In particular, it is of critical importance that the evidence to corroborate\nthe narrations indicating payments in the seized material found with a third\nparty is available with specific reference to the fact regarding actual transfer\nof money from the said third party to the recipient named in the said entries\nin the seized material

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. M/S CHOLAMANDALAM INVESTMENT & FINANCE COMPANY LTD, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

Reassessment • cannot be made Wherein it was held that assessing officer had allowed a deduction after making inquiries and considering the reply of the assessee, then the subsequent withdrawal of the same under Section 148 amounts to change of opinion which is invalid In this connection the Ld.AR placed reliance on below judicial precedents - The Hon’ble Bombay High Court

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

Reassessment • cannot be made Wherein it was held that assessing officer had allowed a deduction after making inquiries and considering the reply of the assessee, then the subsequent withdrawal of the same under Section 148 amounts to change of opinion which is invalid In this connection the Ld.AR placed reliance on below judicial precedents - The Hon’ble Bombay High Court

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

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

reassessment, the assessment order is not sustainable and relied upon the judgment cited as CIT vs. Kabul Chawla - 380 ITR 173 (Del.). 10. Assessee brought on record copy of computation of income along with acknowledgement of return for income, copy of special audit report furnished u/s.142(2A) and reply filed by the assessee to the special audit report, available

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment ITA Nos.207

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment ITA Nos.207

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment ITA Nos.207