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

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

234 ITR 10, affirmed the stand of the ld.CIT(A). No contrary facts were brought to our notice by either side and more specifically by the Revenue, therefore, we find no infirmity in the conclusion drawn by the ld.CIT(A). 4.3 Our above conclusion will also cover the remaining appeals of the Revenue on identical issue. 5. Now we shall

SANTECH SOLUTONS PVT LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is treated as 9

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No.1036/Mds/2016 "नधा"रण वष" /Assessment Year : 2008-2009

u/s 148 was issued’’. During the course of assessment proceedings, assessee had filed a letter dated 12.11.2010 which stated as under:- Date: 12/11/2010 To The Assistant Commissioner of Income Tax Company Circle VI(I), Chennai - 34 Sub:!T Assessment - AY 08-09 Ref Notice u/s.143(2) dated 12.08.2009 Dear Sir, Further to our appearance before your goodself

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

reassessment order passed under section 147 r.w.s. 144B of the Act, in the facts and circumstances of the case. 21 I.T.A. Nos.1667 to 1670/Chny/24 22. The ld. AR Shri G. Baskar, Advocate adopted the same arguments advanced in earlier assessment year 2014-15 in respect of “change of opinion”. He relied on the decision of Hon’ble High Court

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment order passed under\nsection 147 r.w.s. 144B of the Act, in the facts and circumstances of the\ncase.\n22. The Id. AR Shri G. Baskar, Advocate adopted the same arguments\nadvanced in earlier assessment year 2014-15 in respect of \"change of\nopinion\". He relied on the decision of Hon'ble High Court of Gujarat in the\ncase

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

reassessment order passed under\nsection 147 r.w.s. 144B of the Act, in the facts and circumstances of the\ncase.\n22. The Id. AR Shri G. Baskar, Advocate adopted the same arguments\nadvanced in earlier assessment year 2014-15 in respect of \"change of\nopinion\". He relied on the decision of Hon'ble High Court of Gujarat in the\ncase

ASTORIA LEATHERS,CHENNAI vs. ITO, CHENNAI

In the result, the appeals filed by the assessee in I

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

u/s 147 of the Act and consequently erred framing the reassessment in terms of section 143(3) read with 147 of the Act without assigning proper reasons and justification.” 3 I.T.A. Nos.2548-2553 & 2673-2674/M/14 2.2 It is evident from the assessment order that the Assessing Officer has passed the assessment under section 143(3) r.w. section 147

ASTORIA LEATHERS,CHENNAI vs. ITO, CHENNAI

In the result, the appeals filed by the assessee in I

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

u/s 147 of the Act and consequently erred framing the reassessment in terms of section 143(3) read with 147 of the Act without assigning proper reasons and justification.” 3 I.T.A. Nos.2548-2553 & 2673-2674/M/14 2.2 It is evident from the assessment order that the Assessing Officer has passed the assessment under section 143(3) r.w. section 147

ASTORIA LEATHERS,CHENNAI vs. ITO, CHENNAI

In the result, the appeals filed by the assessee in I

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

u/s 147 of the Act and consequently erred framing the reassessment in terms of section 143(3) read with 147 of the Act without assigning proper reasons and justification.” 3 I.T.A. Nos.2548-2553 & 2673-2674/M/14 2.2 It is evident from the assessment order that the Assessing Officer has passed the assessment under section 143(3) r.w. section 147

ASTORIA LEATHERS,CHENNAI vs. ITO, CHENNAI

In the result, the appeals filed by the assessee in I

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

u/s 147 of the Act and consequently erred framing the reassessment in terms of section 143(3) read with 147 of the Act without assigning proper reasons and justification.” 3 I.T.A. Nos.2548-2553 & 2673-2674/M/14 2.2 It is evident from the assessment order that the Assessing Officer has passed the assessment under section 143(3) r.w. section 147

SAME DEUTZ FAHR ITALIA SPA,ITALY vs. ASSISTANT COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

reassessment proceedings is invalid. 2.5 The Assessing Officer ought to have appreciated that merechange of opinion cannot per se be the reason for re-opening under section 147 since there was no fresh material on record which merits such re opening. 2.6 The Assessing Officer erred in reopening the assessment based on certain information which was available in a different

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought