S.DEVENDRAN,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

u/s. 143(1) of the Act, had come up before the Hon’ble Supreme Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500. Their Lordship has held as under at para 12 to 18 of the judgment:- ‘’12. What were permissible under the first proviso to section 143(1)(a) to be adjusted

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. 143(1) of the Act, had come up before the Hon’ble Supreme Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500. Their Lordship has held as under at para 12 to 18 of the judgment:- ‘’12. What were permissible under the first proviso to section 143(1)(a) to be adjusted

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

u/s. 143(1) of the Act, had come up before the Hon’ble Supreme Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500. Their Lordship has held as under at para 12 to 18 of the judgment:- ‘’12. What were permissible under the first proviso to section 143(1)(a) to be adjusted

PRAKASH,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

u/s. 143(1) of the Act, had come up before the Hon’ble Supreme Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500. Their Lordship has held as under at para 12 to 18 of the judgment:- ‘’12. What were permissible under the first proviso to section 143(1)(a) to be adjusted

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. 143(1) of the Act, had come up before the Hon’ble Supreme Court in the case of ACIT vs. Rajesh Jhaveri Stock Brokers P. Ltd 291 ITR 500. Their Lordship has held as under at para 12 to 18 of the judgment:- ‘’12. What were permissible under the first proviso to section 143(1)(a) to be adjusted

ACIT, CUDDALORE CIRCLE,, CUDDALORE vs. M/S. THE CUDDALORE DISTRICT CENTRAL CO-OPERATIVE BANK LTD.,, CUDDALORE

In the result, the appeal of the Revenue is dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

reassessment order, the AO stated that details were called for and assessment was completed after going through the details furnished. This shows that details already filed during 1 round of 147 proceedings were examined and order was passed on 06.03.2015. Thereafter on 31.03.2015 i.e barely after lapse of 24 days, the AO issued notice u/s 148 for re-assessment

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 ()

u/s 148 were issued to assessee on 30.06.2021 after enactment of the Finance Act, 2021 wherein the section 148 has undergone drastic change specifically in respect of limitation, quantum of escapement, approval and procedure.This is evident from the following observations as rendered by the Hon’ble Supreme Court in Ashish Agarwal [(2022) 444 ITR 1 (SC) / 286 Taxman

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 ()

u/s 148 were issued to assessee on 30.06.2021 after enactment of the Finance Act, 2021 wherein the section 148 has undergone drastic change specifically in respect of limitation, quantum of escapement, approval and procedure.This is evident from the following observations as rendered by the Hon’ble Supreme Court in Ashish Agarwal [(2022) 444 ITR 1 (SC) / 286 Taxman

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

147 / 148 has been found to be barred by limitation on account of suffering from incurable deficiencies. The appeal of the revenue for impugned year vide ITA No. 491 for AY- 2008-09 is therefore dismissed in limine. 11.1 The issue seminal to all the remaining ITA Nos. 492, 494, 495 & 496 / Chny

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

147 / 148 has been found to be barred by limitation on account of suffering from incurable deficiencies. The appeal of the revenue for impugned year vide ITA No. 491 for AY- 2008-09 is therefore dismissed in limine. 11.1 The issue seminal to all the remaining ITA Nos. 492, 494, 495 & 496 / Chny

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

147 / 148 has been found to be barred by limitation on account of suffering from incurable deficiencies. The appeal of the revenue for impugned year vide ITA No. 491 for AY- 2008-09 is therefore dismissed in limine. 11.1 The issue seminal to all the remaining ITA Nos. 492, 494, 495 & 496 / Chny

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 148 was issued to assessee on 15.04.2021 after enactment of the Finance Act, 2021 wherein the section 148 has undergone drastic change specifically in respect of limitation, quantum of escapement, approval and procedure.This is evident from the following observations as rendered by the Hon’ble Supreme Court in Ashish Agarwal [(2022) 444 ITR 1 (SC) / 286 Taxman

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

1) of the Act by the learned Commissioner of income-tax (Appeals).\n010. 011. Fact shows that the assessee has debited the above sum to the profit\nand loss account and claimed as allowable. The Assessing Officer questioned the\nsame and assessee submitted that the above claims are incurred on account of\nthe contractual obligations between the insurance company

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

1) of the Act by the learned Commissioner of income-tax (Appeals).\n010. 011. Fact shows that the assessee has debited the above sum to the profit\nand loss account and claimed as allowable. The Assessing Officer questioned the\nsame and assessee submitted that the above claims are incurred on account of\nthe contractual obligations between the insurance company

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

1) of the Act by the learned Commissioner of income-tax (Appeals).\n010. 011. Fact shows that the assessee has debited the above sum to the profit\nand loss account and claimed as allowable. The Assessing Officer questioned the\nsame and assessee submitted that the above claims are incurred on account of\nthe contractual obligations between the insurance company

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

1) of the Act by the learned Commissioner of income-tax (Appeals).\n010. 011. Fact shows that the assessee has debited the above sum to the profit\nand loss account and claimed as allowable. The Assessing Officer questioned the\nsame and assessee submitted that the above claims are incurred on account of\nthe contractual obligations between the insurance company

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

1) of the Act by the learned Commissioner of income-tax (Appeals).\n010. 011. Fact shows that the assessee has debited the above sum to the profit\nand loss account and claimed as allowable. The Assessing Officer questioned the\nsame and assessee submitted that the above claims are incurred on account of\nthe contractual obligations between the insurance company

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

1) of the Act by the learned Commissioner of income-tax (Appeals).\n010. 011. Fact shows that the assessee has debited the above sum to the profit\nand loss account and claimed as allowable. The Assessing Officer questioned the\nsame and assessee submitted that the above claims are incurred on account of\nthe contractual obligations between the insurance company