INDUSTRIAL MINERAL CO, 100%EOU,TUTICORIN vs. ACIT,CENTRAL CIRCLE-1, MADURAI, MADURAI

In the result, the assessee’s appeal ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.390/Chny/2023 (िनधा(रण वष( / Assessment Year: 2012-13) M/S. Industrial Mineral Co. 100% Eou Acit बनाम/ 1/1C, Harbour Express Highway, Central Circle-(1), Vs. Thermal Nagar So, Tuticorin-628 006. Madurai "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaafi-9714-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपील सं./ Ita No.529/Chny/2023 (िनधा(रण वष( / Assessment Year: 2012-13) Acit M/S. Industrial Mineral Co. 100% Eou बनाम/ Central Circle-(1), 1/1C, Harbour Express Highway, Vs. Madurai Thermal Nagar So, Tuticorin 628006 "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaafi-9714-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri N. Arjun Raj (Advocate) – Ld.Ar ""थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 26-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-05-2025 आदेश / O R D E R

reassess the total income of each of the six assessment years immediately preceding the year in which search action u/s.132 of the Act was initiated or requisition u/s.132A was made. The Ld.CIT(A) failed to appreciate that total income of the assessee cannot be brought to tax if the scope of Section 153A is limited to only undisclosed income

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

147, section 148, section 149, section 151 and section 153,\nwhere the Assessing Officer is satisfied that -\n(a) any money, bullion, Jewellery or other valuable article or thing\nseized or requisitioned, \"belongs to, or\n(b) any books of account or documents, seized or requisitioned, pertains\nor pertain to, or any information contained therein, relates to,\na person other

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

147, section 148, section 149, section 151 and section 153,\nwhere the Assessing Officer is satisfied that -\n(a) any money, bullion, Jewellery or other valuable article or thing\nseized or requisitioned, “belongs to, or\n(b) any books of account or documents, seized or requisitioned, pertains\nor pertain to, or any information contained therein, relates to,”\na person other

ASSISTANT COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE-1, TRICHY, INCOME TAX OFFICE, TRICHY vs. KARUPPANNA GOUNDER PALANIAPPA GOUNDER MARIAPPAN, KARUR

In the result, all the three appeals of the Revenue are dismissed

147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003 [but on or before the 31st day of March, 2021],\nthe Assessing Officer shall

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY MOOLIMANGALAM VAISHNAVA PRIYA, CHENNAI

In the result, all the three appeals of the Revenue are dismissed

147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003 [but on or before the 31st day of March, 2021],\nthe Assessing Officer shall

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE,TRICHY vs. MARAGATHAMANI SHANMUGAM, KARUR

In the result, all the three appeals of the Revenue are dismissed

147,\nsection 148, section 149, section 151 and section 153, in the case of a\nperson where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after\nthe 31st day of May, 2003 [but on or before the 31st day of March, 2021],\nthe Assessing Officer shall

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. MEENAKSHI AMMAL TRUST, CHENNAI

In the result, the appeal filed by the Revenue stands dismissed, and the grounds raised by the assessee by way of Rule 27 of the ITAT Rules are partly allowed

Bench: Shri George George K & Shri S.R. Raghunatha

292C which affirm the evidentiary value of any material seized during the course of search for the purposes of search assessments. 6. The Ld.CIT(A) failed to appreciate the decision of the Hon’ble Hyderabad ITAT in the case of ITO v. G.Sridevi (2014), wherein it held that even if the return is filed under 153A/148. Interest u/s 234A applies

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

147 of the Act. It is settled law that reasons as recorded for reopening the reassessment are to be examined on a 'stand-alone' basis. Neither anything can be added to the reasons so recorded nor anything be deleted from the reasons so recorded. The Hon'ble Bombay High Court in the case of Hindustan Lever Ltd. v. R.B. Wadkar

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

147 of the Act, however the ratio decidendi will apply in the present case, because, like Section 147/148 of the Act, the AO gets the authority to assess/reassess the income of a searched person or other person u/s 153A/153C for the extended assessment years (7th to 10th AYs) only if he has in his possession the jurisdictional fact, as discussed