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323 results for “reassessment u/s 147”+ Section 2(47)(v)clear

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Key Topics

Section 148160Section 147109Section 143(3)80Addition to Income50Disallowance35Reassessment34Section 13232Reopening of Assessment32Section 143(2)

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

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

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

For Appellant: Shri G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 11Section 142(1)Section 143(2)Section 143(3)

Showing 1–20 of 323 · Page 1 of 17

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Section 1024
Section 26322
Section 153A20
Section 147
Section 148
Section 2(15)

u/s 148 of the Act and by issuing notices under sections 143(2) and 142(1) of the Act sought details on certain points. In response to the said notices, the assessee filed details including objects of the assessee Trust which were reproduced in page No.2 of the assessment order. On examination of the same, we find that the assessee

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2579/CHNY/2017[2013-14]Status: DisposedITAT Chennai06 Dec 2018AY 2013-14

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically in the case of Srichand Lalchand Talreja v. Asst CIT, (1998) 98 Taxman 14, 19 (Bom), where the information regarding acquisition of the asset was not available with the Assessing Officer during the relevant assessment year

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2578/CHNY/2017[2010-11]Status: DisposedITAT Chennai06 Dec 2018AY 2010-11

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically in the case of Srichand Lalchand Talreja v. Asst CIT, (1998) 98 Taxman 14, 19 (Bom), where the information regarding acquisition of the asset was not available with the Assessing Officer during the relevant assessment year

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2580/CHNY/2017[2014-15]Status: DisposedITAT Chennai06 Dec 2018AY 2014-15

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically in the case of Srichand Lalchand Talreja v. Asst CIT, (1998) 98 Taxman 14, 19 (Bom), where the information regarding acquisition of the asset was not available with the Assessing Officer during the relevant assessment year

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 1015/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

v. Orient Craft Limited(supra), only tangible material is required and it is not necessary that there should be a fresh material for assuming jurisdiction u/s.147 of the Act. Our attention was drawn to para 18 of the judgment of Hon’ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Private Limited(supra) and it was submitted

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 1016/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

v. Orient Craft Limited(supra), only tangible material is required and it is not necessary that there should be a fresh material for assuming jurisdiction u/s.147 of the Act. Our attention was drawn to para 18 of the judgment of Hon’ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Private Limited(supra) and it was submitted

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 307/CHNY/2010[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

v. Orient Craft Limited(supra), only tangible material is required and it is not necessary that there should be a fresh material for assuming jurisdiction u/s.147 of the Act. Our attention was drawn to para 18 of the judgment of Hon’ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Private Limited(supra) and it was submitted

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

ITA 1324/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

v. Orient Craft Limited(supra), only tangible material is required and it is not necessary that there should be a fresh material for assuming jurisdiction u/s.147 of the Act. Our attention was drawn to para 18 of the judgment of Hon’ble Supreme Court in the case of Rajesh Jhaveri Stock Brokers Private Limited(supra) and it was submitted

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

ITA 858/CHNY/2020[2009-10]Status: DisposedITAT Chennai18 Oct 2023AY 2009-10

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

ITA 2645/CHNY/2019[2016-17]Status: DisposedITAT Chennai18 Oct 2023AY 2016-17

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

ITA 981/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

ITA 854/CHNY/2020[2010-11]Status: DisposedITAT Chennai18 Oct 2023AY 2010-11

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

ITA 857/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

In the result, the appeal filed by the Revenue in ITA

ITA 856/CHNY/2020[202-13]Status: DisposedITAT Chennai18 Oct 2023

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

ITA 855/CHNY/2020[2011-12]Status: DisposedITAT Chennai18 Oct 2023AY 2011-12

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

2 of the assessment order. Accordingly, reassessment was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT LTU-II, CHENNAI

In the result, the appeal of the assessee is allowed

ITA 1836/CHNY/2017[2008-09]Status: DisposedITAT Chennai25 Feb 2022AY 2008-09

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

For Appellant: Shri Sriram Seshadri, C.AFor Respondent: Shri Abani Kanta Nayak, CIT
Section 143(3)Section 147Section 148Section 151

u/s 28(iv). In view of the above, the amount of Rs.380,25,24, 600/- treated as capital gains by the assessee is required to be assessed as business income. 2. Provision for Warranty: 2.1 During the Financial Year 2007-08, the company has made provision for warranty for Rs.82,47,61,000/- and utilized a sum of Rs.54

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 2618/CHNY/2019[2015-16]Status: DisposedITAT Chennai07 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.R. Vijayaraghavan, AdvFor Respondent: Mr.A. Sasikumar, CIT
Section 115JSection 143(3)Section 14A

v. CIT, reported in (2010) 327 ITR 456 (SC) wherein it was held as under:- “9. …Similarly, section 195 imposes a statutory obligation on any person responsible for paying to a non-resident any sum "chargeable under the provisions of the Act", which expression, as stated above, do not find place in other sections of Chapter XVII

M/S. ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, NCC-8(1), LTU-II,, CHENNAI

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

reassessment proceedings beyond four years from the end of the relevant assessment year, then the AO is duty bound to demonstrate in his reasons recorded prior to issue of notice, the failure on the assessee's part to truly and fully disclose all material facts in the course of original assessment. 12. This legal principle has been reiterated

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

ITA 1256/CHNY/2025[2014-15]Status: DisposedITAT Chennai21 Nov 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 148Section 20Section 250

Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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

ITA 1236/CHNY/2025[2016-17]Status: DisposedITAT Chennai21 Nov 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 148Section 20Section 250

Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income