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

ANISH KUMAR WIFE 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

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

M/S. ANISH KUMAR EDUCATION 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

M/S. ANISH KUMAR EDUCATION 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

M/S. ANISHKUMAR MALE 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

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 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

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 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

ANISH KUMAR WIFE 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

ASSISTANT COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE-10, CHENNAI vs. SJ SURYAH, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.806/Chny/2023 िनधा"रण वष"/Assessment Year: 2002-03 V. Shri S.J.Suryah, The Asst. Commissioner- No.35-1D, Of Income Tax, 114, Neelakanta Mehta Street, Central Circle-2(4), T. Nagar, Chennai-600 017. Chennai. [Pan: Alyps 3012 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

271A, 271B and 271(1)(c) are initiated separately." 4. As evident from the above recording made during the course of assessment proceeding, the entire legal requirement, i. initiation during the pendency of the proceeding ii. Recording of satisfaction and iii. Initiated for concealment of total income has been met. Section 271(1B) clarifies if due recording of reason

SHRI.S.J.SURYAH,CHENNAI, TAMIL NADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.806/Chny/2023 िनधा"रण वष"/Assessment Year: 2002-03 V. Shri S.J.Suryah, The Asst. Commissioner- No.35-1D, Of Income Tax, 114, Neelakanta Mehta Street, Central Circle-2(4), T. Nagar, Chennai-600 017. Chennai. [Pan: Alyps 3012 R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

271A, 271B and 271(1)(c) are initiated separately." 4. As evident from the above recording made during the course of assessment proceeding, the entire legal requirement, i. initiation during the pendency of the proceeding ii. Recording of satisfaction and iii. Initiated for concealment of total income has been met. Section 271(1B) clarifies if due recording of reason

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs. ACIT, CIRCLE 3(1), TRICHY, TRICHY

In the result, all the appeals of the assessee are allowed for

Bench: Shri Aby T. Varkey & Shri Jagadish

271A may be levied for money lending part of business.” 35. In result, the appeal of assessee is PARTLY ALLOWED, with income to be computed as per the revised returned incomes filed by the assessee, after ITA Nos.1300 to 1303 & 1304/Chny/2025 (AYs 2008-09 to 2011-12 & 2013-14) Seetharaman Bakthavatsalam :: 4 :: benefit of telescoping of initial Capital & Income

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs. ACIT, CIRCLE 3(1), TRICHY, TRICHY

In the result, all the appeals of the assessee are allowed for

Bench: Shri Aby T. Varkey & Shri Jagadish

271A may be levied for money lending part of business.” 35. In result, the appeal of assessee is PARTLY ALLOWED, with income to be computed as per the revised returned incomes filed by the assessee, after ITA Nos.1300 to 1303 & 1304/Chny/2025 (AYs 2008-09 to 2011-12 & 2013-14) Seetharaman Bakthavatsalam :: 4 :: benefit of telescoping of initial Capital & Income

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs. ACIT, CIRCLE 3(1), TRICHY, TRICHY

In the result, all the appeals of the assessee are allowed for

Bench: Shri Aby T. Varkey & Shri Jagadish

271A may be levied for money lending part of business.” 35. In result, the appeal of assessee is PARTLY ALLOWED, with income to be computed as per the revised returned incomes filed by the assessee, after ITA Nos.1300 to 1303 & 1304/Chny/2025 (AYs 2008-09 to 2011-12 & 2013-14) Seetharaman Bakthavatsalam :: 4 :: benefit of telescoping of initial Capital & Income

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs. ACIT, CIRCLE 3(1), TRICHY, TRICHY

In the result, all the appeals of the assessee are allowed for

Bench: Shri Aby T. Varkey & Shri Jagadish

271A may be levied for money lending part of business.” 35. In result, the appeal of assessee is PARTLY ALLOWED, with income to be computed as per the revised returned incomes filed by the assessee, after ITA Nos.1300 to 1303 & 1304/Chny/2025 (AYs 2008-09 to 2011-12 & 2013-14) Seetharaman Bakthavatsalam :: 4 :: benefit of telescoping of initial Capital & Income

SEETHARAMAN BAKTHAVATSALAM,TRICHY vs. ACIT, CIRCLE 3(1), TRICHY, TRICHY

In the result, all the appeals of the assessee are allowed for

Bench: Shri Aby T. Varkey & Shri Jagadish

271A may be levied for money lending part of business.” 35. In result, the appeal of assessee is PARTLY ALLOWED, with income to be computed as per the revised returned incomes filed by the assessee, after ITA Nos.1300 to 1303 & 1304/Chny/2025 (AYs 2008-09 to 2011-12 & 2013-14) Seetharaman Bakthavatsalam :: 4 :: benefit of telescoping of initial Capital & Income

PALAVESAKANNU PALANI,TIRUNELVELI vs. ITO, WARD-1, TIRUNELVELI

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita Nos.1575, 1576, 1577 & 1578/Chny/2024 (िनधा"रणवष" / Assessment Years: 2013-14, 2013-14,2015-16 & 2015-2016) Palavesakannu Palani, Vs. The Income Tax Officer, 28, Ram Nagar, Ward 1, Thiyagaraja Nagar, Tirunelveli. Palamkottai, Tirunelveli 627 002. [Pan: Awvpp 9442L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Kathir, Advocate ""यथ" क" ओर से /Respondent By : Ms Kavitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 26.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 28.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

147, obtained necessary approvals from the competent authority and issued notice u/s 148 dated 25.03.2020. In response to the Notice u/s 148 of the Act, the assessee has filed the return of income for the AY 2013-14 on 30.11.2020 admitting gross total income of Rs.3,03,791/- During the course of reassessment proceedings, in response to the query u/s

PALAVESAKANNU PALANI,TIRUNELVELI vs. ITO,WARD-1, TIRUNELVELI

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita Nos.1575, 1576, 1577 & 1578/Chny/2024 (िनधा"रणवष" / Assessment Years: 2013-14, 2013-14,2015-16 & 2015-2016) Palavesakannu Palani, Vs. The Income Tax Officer, 28, Ram Nagar, Ward 1, Thiyagaraja Nagar, Tirunelveli. Palamkottai, Tirunelveli 627 002. [Pan: Awvpp 9442L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Kathir, Advocate ""यथ" क" ओर से /Respondent By : Ms Kavitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 26.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 28.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

147, obtained necessary approvals from the competent authority and issued notice u/s 148 dated 25.03.2020. In response to the Notice u/s 148 of the Act, the assessee has filed the return of income for the AY 2013-14 on 30.11.2020 admitting gross total income of Rs.3,03,791/- During the course of reassessment proceedings, in response to the query u/s