M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

M/S. ARCHANA FEMALE CHILD TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

150; (ba) an order of assessment or reassessment under section 153A except an order passed in pursuance of directions of the Dispute Resolution Panel or an order referred to in sub-section (12) of section 144BA; (bb) an order of assessment or reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section

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

reassessment proceeding u/s 147 r.w.s 148 of the Act is that the ld. Assessing Officer must have reason to believe that any income chargeable to tax has escaped assessment for any assessment year. The Hon’ble Gujarat High Court in Prafull Chunnilal Patel vs ACIT (supra) even went to the extent that at the initiation stage formation of reasonable belief

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

reassessment proceeding u/s 147 r.w.s 148 of the Act is that the ld. Assessing Officer must have reason to believe that any income chargeable to tax has escaped assessment for any assessment year. The Hon’ble Gujarat High Court in Prafull Chunnilal Patel vs ACIT (supra) even went to the extent that at the initiation stage formation of reasonable belief

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

reassessment proceeding u/s 147 r.w.s 148 of the Act is that the ld. Assessing Officer must have reason to believe that any income chargeable to tax has escaped assessment for any assessment year. The Hon’ble Gujarat High Court in Prafull Chunnilal Patel vs ACIT (supra) even went to the extent that at the initiation stage formation of reasonable belief

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

PRAKASH,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

150(1) would not stand in the way for initiating 11 Assessing Officer’s remark : In the case at sl.No.8, a survey u/s. 133A was conducted on 20.12.2002. The individual listed out in sl. Numbers 1 to 7 are all partners in different firms connected with the survey conducted on 20.12.2002. Though returns have been filed for the other

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

150(1) would not stand in the way for initiating 11 Assessing Officer’s remark : In the case at sl.No.8, a survey u/s. 133A was conducted on 20.12.2002. The individual listed out in sl. Numbers 1 to 7 are all partners in different firms connected with the survey conducted on 20.12.2002. Though returns have been filed for the other

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

150(1) would not stand in the way for initiating 11 Assessing Officer’s remark : In the case at sl.No.8, a survey u/s. 133A was conducted on 20.12.2002. The individual listed out in sl. Numbers 1 to 7 are all partners in different firms connected with the survey conducted on 20.12.2002. Though returns have been filed for the other

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

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

Bench: Shri Abraham P. George]

150(1) would not stand in the way for initiating 11 Assessing Officer’s remark : In the case at sl.No.8, a survey u/s. 133A was conducted on 20.12.2002. The individual listed out in sl. Numbers 1 to 7 are all partners in different firms connected with the survey conducted on 20.12.2002. Though returns have been filed for the other

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

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

Bench: Shri Abraham P. George]

150(1) would not stand in the way for initiating 11 Assessing Officer’s remark : In the case at sl.No.8, a survey u/s. 133A was conducted on 20.12.2002. The individual listed out in sl. Numbers 1 to 7 are all partners in different firms connected with the survey conducted on 20.12.2002. Though returns have been filed for the other