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(1)(b

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(1)(b

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(1)(b

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(1)(b

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

b) of sub- section (1) of this section or section 153A or section 153C, as the case section (1) of this section or section 153A or section 153C, as the case section (1) of this section or section 153A or section 153C, as the case may be, as they stood immediately before the co may be, as they stood immediately

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(1)(b

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(1)(b

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

147, 148, 149, 151 and 153. 8.2 Having noticed the above, we may also refer t 8.2 Having noticed the above, we may also refer to the second and the third o the second and the third proviso to section 153A(1). For the sake of convenience, the second and third proviso to section 153A(1). For the sake

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

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 ()

b) of sub-Section (i) of Section 149 of the Act, 1961 for the Assessment Years 2013-14, 2014-15 and 2015-16 (where the income of an assessee escaping assessment to tax is less than Rs.50,00,000/-) and notice has not been issued within limitation under the unamended provisions of Section 149, then proceedings under the amended provisions

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 ()

b) of sub-Section (i) of Section 149 of the Act, 1961 for the Assessment Years 2013-14, 2014-15 and 2015-16 (where the income of an assessee escaping assessment to tax is less than Rs.50,00,000/-) and notice has not been issued within limitation under the unamended provisions of Section 149, then proceedings under the amended provisions

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.

u/s 144C(5) dated 29.11.2023. 2. The assessee has raised following grounds of appeal: ‘’1. Ground 1-General Hyundai Transys INC ('Hyundai INC' or 'the Appellant') submits that the assessment order ('the order') dated 12 December 2023 passed by the Deputy Commissioner of Income Tax, International Tax, Corporate Circle 1(1), Chennai ('Ld. AO') under section 143(3) r.w.s 147

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

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

M.R.PRASAD,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

u/s. ITA Nos.1218 to 1223/2017 :- 7 -: 147 for both the assessment years by virtue of section 149(1) (b) of the Act. I solicit Additional Commissioner’s approval in this regard’’. Assessees raised objections to the reasons wherein it was stated that returns were filed by the assessees prior to the issue of the notices under section

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

u/s. ITA Nos.1218 to 1223/2017 :- 7 -: 147 for both the assessment years by virtue of section 149(1) (b) of the Act. I solicit Additional Commissioner’s approval in this regard’’. Assessees raised objections to the reasons wherein it was stated that returns were filed by the assessees prior to the issue of the notices under section

PRAKASH,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

u/s. ITA Nos.1218 to 1223/2017 :- 7 -: 147 for both the assessment years by virtue of section 149(1) (b) of the Act. I solicit Additional Commissioner’s approval in this regard’’. Assessees raised objections to the reasons wherein it was stated that returns were filed by the assessees prior to the issue of the notices under section

M.R.PRASAD,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

u/s. ITA Nos.1218 to 1223/2017 :- 7 -: 147 for both the assessment years by virtue of section 149(1) (b) of the Act. I solicit Additional Commissioner’s approval in this regard’’. Assessees raised objections to the reasons wherein it was stated that returns were filed by the assessees prior to the issue of the notices under section