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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JSR INFRA DEVELOPERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

36 taxmann.com 523, wherein the Hon'ble High Court has held that it is not open for the assessee to seek deduction or claim expenditure which has is not open for the assessee to seek deduction or claim expenditure which has is not open for the assessee to seek deduction or claim expenditure which has not been claimed

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

reassessment under Section 147/148 should only be issued in accordance with the new Section 147, and where the original assessment had been made under Section 143(3) then in view of the proviso to Section 147, the notice under section 148 would be illegal if issued more than four years after the end of the relevant assessment year. The same

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed u/s

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed u/s

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed u/s

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed u/s

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed u/s

CITY UNION BANK LIMITED,KUMBAKONAM vs. JCIT, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

reassessment was made on account of change of opinion. 4. The Brief facts of the case are the assessee is a Banking Company and Return of Income was filed on 25.10.2007 electronically and the Return of income was processed u/s. 143(1) on 18.02.2008. Subsequently, the case was selected for scrutiny and Assessment was completed u/s