EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri George Mathan & Shri Ramit Kochar

17. The scope and effect of section 147 as substituted with effect from 1-4-1989, as also sections 148 to 152 are substantially different from the provisions as they stood prior to such substitution. Under the old provisions of section 147, separate clauses (a) and (b) laid down the circumstances under which income escaping assessment for the past assessment

THE GATE OF HOPE CHARITABLE TRUST,,CHENNAI vs. ITO(E), WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

2) of the Act, therefore originally, no scrutiny assessment was framed. Therefore, the originally, no scrutiny assessment was framed. Therefore, the originally, no scrutiny assessment was framed. Therefore, the return of income income income filed filed filed by by by assessee assessee assessee stood stood stood accepted accepted accepted by by by the the the Department. Department. Department. Subsequently

THE GATE OF HOPE CHARITABLE TRUST,CHENNAI vs. ITO (EXEMPTIONS) WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

2) of the Act, therefore originally, no scrutiny assessment was framed. Therefore, the originally, no scrutiny assessment was framed. Therefore, the originally, no scrutiny assessment was framed. Therefore, the return of income income income filed filed filed by by by assessee assessee assessee stood stood stood accepted accepted accepted by by by the the the Department. Department. Department. Subsequently

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

17. Further, it is also in the knowledge of the Assessing Officer setting apart the accumulated sum of ₹.1,61,00,000/- for future application under section 11(2) of the Act. Therefore, the Assessing Officer is fully satisfied with the activities of the assessee as charitable in nature and allowed exemption under section 11 of the Act. The decision

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

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

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

R.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

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

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

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

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

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

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

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

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

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. 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