SIVAKUMARAN PUGAZHENDHI,CHENNAI vs. PCIT,, CHENNAI-4

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.27/Chny/2022 िनधा"रण वष" /Assessment Year: 2014-15 Sivakumaran Pugazhendhi, The Principal Commissioner 70 Raja Agraharam Street, Vs. Of Income Tax, Poonamalle, Chennai-4. Chennai – 600 056. [Pan: Aiapp-7309-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. T.V. Muthu Abirami, Advocate ""यथ" क" ओर से /Respondent By : Shri M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 05.09.2022 : 21.09.2022 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R

u/s. 263 of the Act 11. On a careful reading of the impugned revision order of PCIT passed under section 263 of the Act, it becomes very much clear that he has revised the assessment order passed under section 143(3) :- 10 -: r.w.s. 147 of the Act. Thus, the issues before us are, firstly, whether the assessment order passed under

EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri George Mathan & Shri Ramit Kochar

20 -: on same stale material which was available with the AO while processing of return of income u/s 143(1)(a) and there was no tangible material available with AO to have prima facie reason to believe that income of the tax-payer has escaped assessment. Thirdly, the partner of the tax-payer firm retired from the assessee firm

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

section 147 of the Act could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant could have been issued beyond four years from expiry of relevant assessment year, unless the AO demonstrates in the assessment year, unless the AO demonstrates in the recorded reasons recorded reasons that income

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

reassessment under sub-section (3) of section 92CD (c) an order made under section 154 or section 155 having the effect of enhancing the assessment or reducing a refund or an order refusing to allow the claim made by the assessee under either of the said sections [except an order referred to in sub-section (12) of section 144BA