MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 25.07.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 25.07.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

THANARAJ SUMATHI,MAYILADUTHURAI vs. ITO, WARD-1,, KUMBAKONAM

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

SUPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, which vitiates the reopening of the assessment

SAPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, which vitiates the reopening of the assessment

CHAHIDA BEGAM,PUDUCHERRY vs. INCOME TAX OFFICER, WARD 3, PUDUCHERRY RANGE, INCOME TAX OFFICE, PUDUCHERRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 29.03.2023 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

LOGANATHAN DHANDAPANI,CHENNAI vs. ACIT, NCC-3(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

In the result, appeal filed by the assessee is partly allowed

reassessment proceedings were\ninvalid as the notices u/s. 148A and 148 were not issued in a\nfaceless manner, contrary to Section 144B and Section 151A of the\nAct and the schemes notified by the CBDT in March 2022. Reliance\nwas placed on several High Court decisions which had quashed\nreassessment proceedings initiated by jurisdictional officers instead\nof through the faceless

TYSPL 100 ANDIMADAM PACCS LIMITED, ANDIMADAM vs. COMMISSIONER OF INCOME TAX APPEAL, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1428/Chny/2025 Assessment Years: 2019-20 Tyspl 100 Andimadam Paccs Income Tax Officer, Limited, Ward-1, Udiyarpalayam, Ariyalur, Kumbakonam. Perambalur, Tamil Nadu-621 801. [Pan: Aacat7731L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : G.Reddi Prakash, C.A प्रत्यर्थी की ओर से /Revenue By : Mr.Krishna Kumar Jcit सुनवाई की तारीख/Date Of Hearing : 18.08.2025 घोषणा की तारीख /Date Of Pronouncement : 20.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

reassessment order u/s. 147 r.w.s. 144B dated 29.02.2024. It is the case of the Ld.Counsel for the assessee that as per section

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

In the result, the the appeals filed by the assessee is allowed and the assessee is allowed and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

147 or for issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show enquiry by issuance of a show-cause notice or passing order under cause notice or passing order under

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

In the result, the the appeals filed by the assessee is allowed and the assessee is allowed and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

147 or for issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show enquiry by issuance of a show-cause notice or passing order under cause notice or passing order under

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

In the result, the the appeals filed by the assessee is allowed and the assessee is allowed and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

147 or for issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show enquiry by issuance of a show-cause notice or passing order under cause notice or passing order under

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

In the result, the the appeals filed by the assessee is allowed and the assessee is allowed and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

147 or for issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show enquiry by issuance of a show-cause notice or passing order under cause notice or passing order under

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

In the result, the the appeals filed by the assessee is allowed and the assessee is allowed and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

147 or for issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior issuance of notice under section 148A and for conducting a prior enquiry by issuance of a show enquiry by issuance of a show-cause notice or passing order under cause notice or passing order under

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

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, 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

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

u/s 148. - If it is not a fit case to issue a notice under section 148 of the Act, the order passed under clause (d) of section 148A to that effect shall be served on the assessee. Tanay Sharma DCIT(OSD), ITJ-I Copy to: 1. Chairman, Members and all other officer in CBDT of the rank of Under Secretary

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

u/s 148. - If it is not a fit case to issue a notice under section 148 of the Act, the order passed under clause (d) of section 148A to that effect shall be served on the assessee. Tanay Sharma DCIT(OSD), ITJ-I Copy to: 1. Chairman, Members and all other officer in CBDT of the rank of Under Secretary

MRS. ROOPA RATHI,CHENNAI vs. ITO, NCW-10(3), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1707/Chny/2025 Assessment Years: 2018-19 Mrs.Roopa Rathi, Income Tax Officer, Door No.1, Damodar Murthy Street, Non-Corporate Ward-10(3), Kilpauk, Chennai. Chennai-600 010. [Pan: Ajapr6077R] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.Hitesh, Advocate For Mr.D.Anand, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 25.08.2025 घोषणा की तारीख /Date Of Pronouncement : 04.09.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

section 68 of the Act. The Ld. Counsel argued that it is assailing the order of Ld.CIT(A) both on legal grounds as well as on the merits of the case. As the legal ground of the appellant assessee strikes at the very root of the reassessment order u/s. 147 r.w.s. 144B