SIVAKUMARAN PUGAZHENDHI,CHENNAI vs. PCIT,, CHENNAI-4

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.27/Chny/2022 िनधा"रण वष" /Assessment Year: 2014-15 Sivakumaran Pugazhendhi, The Principal Commissioner 70 Raja Agraharam Street, Vs. Of Income Tax, Poonamalle, Chennai-4. Chennai – 600 056. [Pan: Aiapp-7309-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. T.V. Muthu Abirami, Advocate ""यथ" क" ओर से /Respondent By : Shri M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 05.09.2022 : 21.09.2022 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R

reassessment order passed u/s. 143(3) r/w s. 147 of the act dated 23.11.2019 and the revision order passed by PCIT u/s. 263 of the Act dated 18.11.2021 and also the paper book filed by the assessee consisting of Pages 1 to 84. The first issue raised by the assessee in this appeal is as regards to barred by limitation

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

reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the assessment year assessment year relevant to the previous year in which search is relevant to the previous year in which search is conducted. Applying this yardstick, the conducted. Applying this

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

reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the assessment year assessment year relevant to the previous year in which search is relevant to the previous year in which search is conducted. Applying this yardstick, the conducted. Applying this

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

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

u/s 147 of the Act as Invalid by relying on case laws prior to the amendments made in the Act by Finance Act 2016 in respect of section 147 of the Act w.e.f.01/06/2016 wherein under Explanation 3 It is mentioned that - "For the purposes of assessment or reassessment under this section, the Assessing Officer may assess or reassess the income

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

DCIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

DCIT, COIMBATORE vs. M/S. SENTHIL BUILDING MATERIAL MANUFACTURING CO. (P) LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

M.PALANISAMY,COIMBATORE vs. DCIT, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

DCIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

147, 148, 149, 151 & 153. 7.2 Assessee filed return of income in response to notice u/s. 153A of the Act on 27.04.2007. Period of 21 months u/s. 153B of the Act should be reckoned from the end of the financial year in which the last of 11 44 Appeals of S/Shri M.Palanisamy, A. Senthilkumar, T.M.Muthukumar, O. Arumugasamy & others authorization