DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JSR INFRA DEVELOPERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment, if any, relating to any assessment year falling within the period of six assessment years referred to in sub within the period of six assessment years referred to in sub- -section (1) is pending on the date of initiation of the search u/s. 132 of the Act shal pending on the date of initiation of the search

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

1 to section 153A of\nthe Act. In the present case, the AO has attempted to re-open for the AY\n2013-14 which falls beyond ten years from relevant AY 2023-24 from the\nend of the FY (2022-23) in which the search was conducted on the\nassessee (15.06.2022) and therefore lacked jurisdiction to issue notice\nu/s

SOUTHERN AGRIFURANE INDUSTRIES PVT.. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

1 to section 153A of\nthe Act. In the present case, the AO has attempted to re-open for the AY\n2013-14 which falls beyond ten years from relevant AY 2023-24 from the\nend of the FY (2022-23) in which the search was conducted on the\nassessee (15.06.2022) and therefore lacked jurisdiction to issue notice\nu/s

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\nassessee are dismissed

1 to section 153A of\nthe Act. In the present case, the AO has attempted to re-open for the AY\n2013-14 which falls beyond ten years from relevant AY 2023-24 from the\nend of the FY (2022-23) in which the search was conducted on the\nassessee (15.06.2022) and therefore lacked jurisdiction to issue notice\nu/s

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\nassessee are dismissed

1 to section 153A of\nthe Act. In the present case, the AO has attempted to re-open for the AY\n2013-14 which falls beyond ten years from relevant AY 2023-24 from the\nend of the FY (2022-23) in which the search was conducted on the\nassessee (15.06.2022) and therefore lacked jurisdiction to issue notice\nu/s

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

reassessment notice Date of impugned\nnotice under Section 148 - 31.08.2024 This chart is prepared in light of\nthe first proviso of Section 149 of the Act as amended by Finance Act\n2021\n| Relevant Assessment year for\n| initiating proceedings under Section\n| 148 of the Act\n| Without prejudice computation of 10\n| years in light of first proviso

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

1 to section 153A of\nthe Act. In the present case, the AO has attempted to re-open for the AY\n2013-14 which falls beyond ten years from relevant AY 2023-24 from the\nend of the FY (2022-23) in which the search was conducted on the\nassessee (15.06.2022) and therefore lacked jurisdiction to issue notice\nu/s

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

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

1 st April, 2021, according to learned ASG, the Revenue issued approximately 90,000 reassessment notices to the respective assessees under the erstwhile sections 148 to 151 thereof by relying on explanations in the Notifications dated 31st March, 2021 and 27th April, 2021. The said reassessment notices were the subject matter of writ petitions before the various High Courts

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment u/s 143(3) r.w.s. 147, were as under: - 1. As per provisions of section 80AC, no deduction u/s 80IA shall be allowed unless the assessee furnishes a Return of Income for such Assessment Year on or before the due date of filing of return u/s 139 (1) of the Act. 2. The assessee has failed to enclose the certificate

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment u/s 143(3) r.w.s. 147, were as under: - 1. As per provisions of section 80AC, no deduction u/s 80IA shall be allowed unless the assessee furnishes a Return of Income for such Assessment Year on or before the due date of filing of return u/s 139 (1) of the Act. 2. The assessee has failed to enclose the certificate

ST. JOHN FREIGHT SYSTEMS PVT. LTD.,,TUTUCORIN vs. DCIT, CC-1,, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment u/s 143(3) r.w.s. 147, were as under: - 1. As per provisions of section 80AC, no deduction u/s 80IA shall be allowed unless the assessee furnishes a Return of Income for such Assessment Year on or before the due date of filing of return u/s 139 (1) of the Act. 2. The assessee has failed to enclose the certificate

ST. JOHN FREIGHT SYSTEMS LTD.,TUTICORIN vs. DCIT CENTRAL CIRCLE 1, MADURAI

In the result appeals filed in ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकरअपीलसं./Ita Nos.188 & 2898 To 2900/Chny/2019 िनधा"रणवष"/Assessment Years: 2007-08 To 2010-11 V. M/S.St.John Freight – The Dy. Commissioner- Systems Pvt. Ltd., Of Income Tax, C-98, Sipcot Complex, Central Circle-1, Harbour Express Road, Madurai. Tuticorin-628 008. [Pan:Aaacs 4697 N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.R.Vijayaraghavan, Adv. ""थ" की ओर से /Respondent By : Mr.S.Senthil Kumaran, Cit सुनवाईकीतारीख/Date Of Hearing : 13.03.2023 घोषणाकीतारीख /Date Of Pronouncement : 06.04.2023

reassessment u/s 143(3) r.w.s. 147, were as under: - 1. As per provisions of section 80AC, no deduction u/s 80IA shall be allowed unless the assessee furnishes a Return of Income for such Assessment Year on or before the due date of filing of return u/s 139 (1) of the Act. 2. The assessee has failed to enclose the certificate

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

7. .....On 18 October 2019, a search and seizure operation is stated\nto have been carried out in respect of the Alankit Group of\nCompanies6. On 22 March 2022, the petitioner was served with a\nnotice purporting to be under Section 153C of the Act requiring it to\nsubmit a true and correct return of its total income

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

7. .....On 18 October 2019, a search and seizure operation is stated\nto have been carried out in respect of the Alankit Group of\nCompanies6. On 22 March 2022, the petitioner was served with a\nnotice purporting to be under Section 153C of the Act requiring it to\nsubmit a true and correct return of its total income

ACIT, CORPORATE CIRCLE 1(1), CHENNAI vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED (FORMERLY FUTURE SOFT PRIVATE LIMITED), CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.420/Chny/2024 िनधा"रण वष"/Assessment Year: 2006-07 V. The Acit, Capgemini Technology Corporate Circle-1(1), Services India Ltd., Block 3, ‘C’ Wing, 4Th Floor, Chennai. Capgemini Knowledge Park, Airoli Knowledge Park, Thane Belapur Road, Navi Mumbai- 400 708. [Pan: Aaacf 0482 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

7. It is the case on behalf of the Revenue that as there was a non- compliance of twin conditions under Section 10B (8) of the IT Act, namely, the declaration under Section 10B (8) was not submitted along with the original return of income, the assessee shall not be entitled to the exemption/benefit under Section

ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

1) 27[, (1A)] and (2) shall apply to the following\nclasses of assessments, reassessments and recomputation which may, subject to the\nprovisions of 28[sub-sections (3), (5) and (5A)], be completed-\n(i) where the assessment, reassessment or recomputation is made on the assessee or any\nperson in consequence of or to give effect to any finding or direction