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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

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

section 143(3) or under section 147 of the Act and such concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, concluded assessment is being sought to be reopened beyond four years, ITA No.2587/CHNY/2024 & 22 others 2587/CHNY/2024 & 22 others (AYs 2012 (AYs 2012-13 & 2013-14) Shri

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment in such a case as based on change of opinion. Since no decision had been taken at the first instance, there is no question of reviewing it based on change of opinion. Further, in the case of Sun Engineering Works Pvt. Ltd. 198 ITR 297(SC), the Hon'ble Supreme Court has held that re-assessment proceedings

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment in such a case as based on change of opinion. Since no decision had been taken at the first instance, there is no question of reviewing it based on change of opinion. Further, in the case of Sun Engineering Works Pvt. Ltd. 198 ITR 297(SC), the Hon'ble Supreme Court has held that re-assessment proceedings

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment in such a case as based on change of opinion. Since no decision had been taken at the first instance, there is no question of reviewing it based on change of opinion. Further, in the case of Sun Engineering Works Pvt. Ltd. 198 ITR 297(SC), the Hon'ble Supreme Court has held that re-assessment proceedings

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment in such a case as based on change of opinion. Since no decision had been taken at the first instance, there is no question of reviewing it based on change of opinion. Further, in the case of Sun Engineering Works Pvt. Ltd. 198 ITR 297(SC), the Hon'ble Supreme Court has held that re-assessment proceedings

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

32 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells was clear that the assessee had claimed depreciation in the return at the rate of 50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone was sufficient to initiate reassessment proceedings under section 147 and, therefore, such initiation