K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

K. SADASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

K. BASKAR,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

K. PARAMASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

K. BASKAR,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

S. EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

M. NATESAN,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

M. VELUSAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

S. ARAVIND,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

P. KARUNANITHI,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment orders that, according to AO, both the cost of land & cost of construction of the building were construction of the building were not correctly disclosed/offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounde offered by the trustees. Based on the loose sheets impounded at the time of survey

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

147 and both the first appellate authority as well as the Tribunal accepted the contention of the ITA Nos.2578 to 2580/chny/2017 :- 46 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid

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

147 and both the first appellate authority as well as the Tribunal accepted the contention of the ITA Nos.2578 to 2580/chny/2017 :- 46 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid

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

147 and both the first appellate authority as well as the Tribunal accepted the contention of the ITA Nos.2578 to 2580/chny/2017 :- 46 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid

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 order passed under section 147 r.w.s. 144B of the Act, in the facts and circumstances of the case. 21 I.T.A. Nos.1667 to 1670/Chny/24 22. The ld. AR Shri G. Baskar, Advocate adopted the same arguments advanced in earlier assessment year 2014-15 in respect of “change of opinion”. He relied on the decision of Hon’ble High Court

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment order passed under\nsection 147 r.w.s. 144B of the Act, in the facts and circumstances of the\ncase.\n22. The Id. AR Shri G. Baskar, Advocate adopted the same arguments\nadvanced in earlier assessment year 2014-15 in respect of \"change of\nopinion\". He relied on the decision of Hon'ble High Court of Gujarat in the\ncase