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

23 -: distribution tax as also it is also taxable in certain situations in the hands of recipients. The said Section 2(22) of the 1961 Act is reproduced hereunder: “ (22) 83-84“dividend” 85 includes— *** *** (e) any payment by a company, not being a company in which the public are substantially interested, of any sum (whether as representing a part

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

23 :: "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income "147. If the Assessing Officer has reason to believe that any income chargeable to tax has escaped assessment for any assessment year, he chargeable to tax has escaped assessment for any assessment year, he chargeable

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

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