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

reassessment which was earlier required to be\nmade u/s 153A/153C of the Act, is now required to be made under\nSection 143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149

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

reassessment which was earlier required to be\nmade u/s 153A/153C of the Act, is now required to be made under\nSection 143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149

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

reassessment which was earlier required to be\nmade u/s 153A/153C of the Act, is now required to be made under\nSection 143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149

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

reassessment which was earlier required to be\nmade u/s 153A/153C of the Act, is now required to be made under\nSection 143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149

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

reassessment which was earlier required to be\nmade u/s 153A/153C of the Act, is now required to be made under\nSection 143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149

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

reassessment which was earlier required to be\nmade u/s 153A/153C of the Act, is now required to be made under\nSection 143 or 144 or 147 of the Act. As a consequence, the timelines for\nsearch related cases qua AYs prior to AY 2021-22, would be governed by\nfirst proviso to Section 149

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

reassessment notices ITA No.567 /Chny/2024 for AY 2014-15 & SP No.24/Chny/2024 for AY 2014-15 Shri Jesudason Biji :: 16 :: has also observed that if the law permits the revenue to take further steps in the matter they shall be at liberty to do so. 6. Having taken note of the substituted sections 147-151 of the Act by the Finance

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

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

147 shall apply as they apply\nfor the purposes of that section.\n:: 20 ::\n(2) & (3) ****\n8. The time limit for issue of notice under section 148 of the Act was\nrevised with effect from 01.04.2021 and the legislature in order to make\nthe amendment prospective introduced the first proviso to section 149(1).\nThe intent of the first

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 ()

149, then proceedings under the amended provisions cannot be initiated. 12. For all the reasons aforestated, the impugned notice under Section 148 of the Act, 1961 issued on 01.04.2021 for the Assessment Year 2014-15 and the impugned notice dated 13.01.2022 under Section 144 of the Act, 1961 and the reassessment order dated 13.01.2022 under Section 147 read with Section

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 ()

149, then proceedings under the amended provisions cannot be initiated. 12. For all the reasons aforestated, the impugned notice under Section 148 of the Act, 1961 issued on 01.04.2021 for the Assessment Year 2014-15 and the impugned notice dated 13.01.2022 under Section 144 of the Act, 1961 and the reassessment order dated 13.01.2022 under Section 147 read with Section

HYUNDAI TRANSYS INC,REPUBLIC OF KOREA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.338/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Hyundai Transys Inc, Vs. The Deputy Commissioner Of 105, Sindang Income Tax, 1 Ro Seongyeon, International Tax, Myeon, Corporate Circle 1(1) Seosan, Ccn 356851 Chennai. Korea.

149, then proceedings under the amended provisions cannot be initiated. 12. For all the reasons aforestated, the impugned notice under Section 148 of the Act, 1961 issued on 01.04.2021 for the Assessment Year 2014-15 and the impugned notice dated 13.01.2022 under Section 144 of the Act, 1961 and the reassessment order dated 13.01.2022 under Section 147 read with Section

RABBIT BUILDERS,KARAIKAL vs. ACIT, THANJAVUR

In the result, the assessee’s appeals are allowed for statistical

Bench: Shri Chandra Poojari & Shri V. Durga Raoआयकर अपील सं./ I.T.A. Nos.1377, 1378 & 1379/Mds/2013 ("नधा"रण वष" / Assessment Years : 2004-05, 2005-06 & 2007-2008)

u/s. 147 of the Income-tax Act so as to issue 148 notice of the Act. In our opinion there is no merit in the argument of the assessee’s counsel section 147 of the Act permits reassessment of income that has escaped assessment income in any assessment year subject to provisions of sections 149

RABBIT BUILDERS,KARAIKAL vs. ACIT, THANJAVUR

In the result, the assessee’s appeals are allowed for statistical

Bench: Shri Chandra Poojari & Shri V. Durga Raoआयकर अपील सं./ I.T.A. Nos.1377, 1378 & 1379/Mds/2013 ("नधा"रण वष" / Assessment Years : 2004-05, 2005-06 & 2007-2008)

u/s. 147 of the Income-tax Act so as to issue 148 notice of the Act. In our opinion there is no merit in the argument of the assessee’s counsel section 147 of the Act permits reassessment of income that has escaped assessment income in any assessment year subject to provisions of sections 149

RABBIT BUILDERS,KARAIKAL vs. ACIT, THANJAVUR

In the result, the assessee’s appeals are allowed for statistical

Bench: Shri Chandra Poojari & Shri V. Durga Raoआयकर अपील सं./ I.T.A. Nos.1377, 1378 & 1379/Mds/2013 ("नधा"रण वष" / Assessment Years : 2004-05, 2005-06 & 2007-2008)

u/s. 147 of the Income-tax Act so as to issue 148 notice of the Act. In our opinion there is no merit in the argument of the assessee’s counsel section 147 of the Act permits reassessment of income that has escaped assessment income in any assessment year subject to provisions of sections 149

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, all the three appeals of the assessee for the A

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

147, Section 148, Section 149 and section 151 shall apply otherwise the new reassessment laws will apply. It was conclude that in this case, the :-19-: ITA. No:3046, 3047 & 3048/Chny/2025 AO has issued notice u/s

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI , CHENNAI

In the result, all the three appeals of the assessee for the A

u/s. 148 of the Act, though dated 31.03.2021, was digitally signed and issued on 01.04.2021, making it subject to the new reassessment regime under section 148A. Since the AO failed to follow the mandatory procedure under section 148A, the reassessment proceedings were quashed.", "result": "Allowed", "sections": [ "147", "144", "148", "148A", "149

POOJA PRABHAKAR,CHENNAI vs. INCOME TAX OFFICER, NON CORPORATE WARD 15(1), CHENNAI, CHENNAI

In the result, all the three appeals of the assessee for the A

147, Section 148, Section 149 and section 151 shall apply otherwise\nthe new reassessment laws will apply. It was conclude that in this case, the\nAO has issued notice u/s

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

149(1)(b) of the Act”, as applicable for A.Y. 2014-15. 11. The ld. DR, with reference to furnishing of gist of reasons recorded, argued that rendering the reassessment illegal citing G.K.N. Driveshafts (India) Ltd. v. ITO (supra) is factually incorrect. She argued that no specific request for supply of reasons sought by the assessee and placing on reliance