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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specified under the provisions of "148, 153A, 153C of the old regime. Hence, in terms of the proviso, the powers of AO is curtailed to issue notice under Section 148 of the new regime

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit Assessee By : Mr. N. Arjun Raj, Advocate सुनवाईकीतारीख/Date Of Hearing : 08.10.2025 घोषणाकीतारीख / Date Of Pronouncement : 21.11.2025

35 :: introduced by Finance Act, 2021. The timelines for reopening the assessment of AYs 2014-15 to 2016-17 impugned before us, being prior to AY 2021-22, is required to be tested on the tenets of the first proviso to Section 149(1)(b) of the new regime, at the stage of issuance of notice under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

ii) if it is barred at the time when the notice is sought to be issued because of the "time limits specified under the provisions of"148, 153A, 153C of the old regime. Hence, in terms of the proviso, the powers of AO is curtailed to issue notice under Section 148 of the new regime

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] V. The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

35 :: introduced by Finance Act, 2021. The timelines for reopening the assessment of AYs 2014-15 to 2016-17 impugned before us, being prior to AY 2021-22, is required to be tested on the tenets of the first proviso to Section 149(1)(b) of the new regime, at the stage of issuance of notice under section

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 | The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit Assessee By : Mr. N. Arjun Raj, Advocate सुनवाईकीतारीख/Date Of Hearing : 08.10.2025 घोषणाकीतारीख / Date Of Pronouncement : 21.11.2025

35 :: introduced by Finance Act, 2021. The timelines for reopening the assessment of AYs 2014-15 to 2016-17 impugned before us, being prior to AY 2021-22, is required to be tested on the tenets of the first proviso to Section 149(1)(b) of the new regime, at the stage of issuance of notice under section

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

35 :: introduced by Finance Act, 2021. The timelines for reopening the assessment of AYs 2014-15 to 2016-17 impugned before us, being prior to AY 2021-22, is required to be tested on the tenets of the first proviso to Section 149(1)(b) of the new regime, at the stage of issuance of notice under section

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal f

Bench: Shri Aby T. Varkey & Shri Jagadish

147 of the Act vide order dated 09.12.2019 09.12.2019 assessing total loss at Rs. Rs.(-) 301,90,10,983/- in in which which several several additions/disallowances were made, which llowances were made, which inter alia included disallowance included disallowance of the normal deduction of the normal deduction of Rs.21,98,62,276/- originally allowed in respect originally allowed in respect

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. 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

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

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

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

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. 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

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

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