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33 results for “reassessment u/s 147”+ Section 36(1)(viia)clear

Sorted by relevance

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Key Topics

Section 143(3)58Section 14753Section 14847Section 36(1)(viia)42Deduction26Section 26322Reassessment22Reopening of Assessment22Addition to Income

DEPUTY COMMISSIONER INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

ITA 2700/CHNY/2025[2015-16]Status: DisposedITAT Chennai28 Jan 2026AY 2015-16
Section 14ASection 36(1)(viia)

reassessment proceedings for those\nyears were pending.\nDuring the assessment proceedings, the assessee originally claimed\ndeduction of Rs.21,03,27,765/-u/s.36(1)(viia), computed at 7.5%\nof total income plus 10% of aggregate average rural advances, as per\nthe statutory formula. The AO observed that the actual provision\ncreated in the books of account for bad and doubtful debts

DEPUTY COMMISSIONER OF INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

ITA 2699/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Jan 2026AY 2013-14
Section 14ASection 36(1)(viia)

Showing 1–20 of 33 · Page 1 of 2

19
Section 143(2)18
Disallowance18
Section 143(1)16

reassessment proceedings for those\nyears were pending.\nDuring the assessment proceedings, the assessee originally claimed\ndeduction of Rs.21,03,27,765/-u/s.36(1)(viia), computed at 7.5%\nof total income plus 10% of aggregate average rural advances, as per\nthe statutory formula. The AO observed that the actual provision\ncreated in the books of account for bad and doubtful debts

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

ITA 981/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 855/CHNY/2020[2011-12]Status: DisposedITAT Chennai18 Oct 2023AY 2011-12

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 857/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 858/CHNY/2020[2009-10]Status: DisposedITAT Chennai18 Oct 2023AY 2009-10

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

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

ITA 2645/CHNY/2019[2016-17]Status: DisposedITAT Chennai18 Oct 2023AY 2016-17

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 854/CHNY/2020[2010-11]Status: DisposedITAT Chennai18 Oct 2023AY 2010-11

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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

ITA 856/CHNY/2020[202-13]Status: DisposedITAT Chennai18 Oct 2023

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT
Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

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 DHARMAPURI DISTRICT CENTRAL CO-OP. BANK LTD.,DHARMAPURI vs. JCIT, SALEM

The appeal stand partly allowed for statistcial purposes to the extent indicated in the order

ITA 1188/CHNY/2016[2008-09]Status: DisposedITAT Chennai13 Jul 2022AY 2008-09

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकर अपील सं./ Ita No.1188/Chny/2016 (िनधा1रण वष1 / Assessment Year: 2008-09) The Dharmapuri District Central Jcit बनाम/ Co-Operative Bank Ltd. Range-Iii No.81/10H, Bye Pass Road, Salem. Vs. Dharmapuri – 636 701 "थायी लेखा सं./जीआइ आर सं./Pan/Gir No. Aaaat-3148-D (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओरसे/ Assessee By : Shri T. Vasudevan (Advocate) – Ld. Ar ""थ" की ओरसे/Revenue By : Shri Arv Sreenivasan (Addl.Cit) – Ld. Dr सुनवाई की तारीख/ : 19-04-2022 Date Of Hearing घोषणा की तारीख / : 13-07.2022 Date Of Pronouncement

For Appellant: Shri T. Vasudevan (Advocate) – Ld. ARFor Respondent: Shri ARV Sreenivasan (Addl.CIT) – Ld. DR
Section 143(3)Section 147Section 234BSection 36Section 36(1)(viia)

u/s. Branch (Col.2-3) be made 36(1)(viia) advances and based on (Col. 8=2-3-6) Year 7.50% of actual Gross Income recovery of ^ [Not to apply NPAs for AY.07-08 in the absence of release of (Col. 3+6) provision] 1 2 3 4 5 6 7 8 2007-08 168,36

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

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

ITA 1801/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

ITA 1671/CHNY/2014[2007-08]Status: DisposedITAT Chennai28 Dec 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

ITA 1802/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

ITA 1803/CHNY/2014[2009-10]Status: DisposedITAT Chennai28 Dec 2016AY 2009-10

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

ITA 1804/CHNY/2014[2010-11]Status: DisposedITAT Chennai28 Dec 2016AY 2010-11

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

ITA 2034/CHNY/2014[2007-08]Status: DisposedITAT Chennai28 Dec 2016AY 2007-08

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

ITA 2035/CHNY/2014[2008-09]Status: DisposedITAT Chennai28 Dec 2016AY 2008-09

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri V. Vivekanandan, CIT
Section 143(1)Section 143(2)Section 143(3)Section 148Section 194JSection 195JSection 40A

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

TAMILNADU STATE APEX CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

The appeal of the assessee is partly allowed for statistical purpose

ITA 2177/CHNY/2014[2007-2008]Status: DisposedITAT Chennai06 Apr 2016AY 2007-2008

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

For Appellant: Shri. R. Viswanathan, C.AFor Respondent: Shri R. Mohan, CIT, DR
Section 142(1)Section 143(1)Section 143(3)Section 148Section 36Section 36(1)(viia)

147 and 250 of the Income Tax Act, 1961 (herein after referred to as ‘the Act’). Since the issue in these two appeals is common in nature, hence these appeals are combined, heard together, and disposed of by a common order for the sake of convenience. 2. The grounds of appeal raised by the assessee are under :- ‘’2. The Learned

JOINT COMMISSIONER OF INCOME-TAX(OSD),CORPORATE CIRCLE-1(1), CHENNAI vs. IDFC LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

ITA 18/CHNY/2024[2008-09]Status: DisposedITAT Chennai24 Jul 2024AY 2008-09

Bench: Shri Mahavir Singh & Shri Jagadishआयकर अपील सं./Ita No.18/Chny/2024 िनधा9रण वष9 /Assessment Year: 2008-09

For Appellant: Shri M. Murali, CITFor Respondent: Shri Niraj Sheth, Advocate
Section 143(3)Section 147Section 148Section 14ASection 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(viiia)

viia)(c) of the Act and interest on debenture allowable u/s. 36(1)(viii) of the Act. Therefore, the A.O has disallowed the claim after due verification. The Hon’ble Apex Court while confirming the decision of Hon’ble Delhi High Court in the case of CIT vs. Kelvinator of India has observed as under: "....., we find that, prior

JOINT COMMOSSIONER OF INCOME-TAX(OSD),CORPORATE CIRCLE-1(1), CHENNAI vs. IDFC LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

ITA 19/CHNY/2024[2009-10]Status: DisposedITAT Chennai24 Jul 2024AY 2009-10

Bench: Shri Mahavir Singh & Shri Jagadishआयकर अपील सं./Ita No.19/Chny/2024 िनधा9रण वष9 /Assessment Year: 2009-10

For Appellant: Shri M. Murali, CITFor Respondent: Shri Niraj Sheth, Advocate
Section 143(3)Section 147Section 148Section 36Section 36(1)Section 36(1)(viia)Section 36(1)(viiia)

u/s. 36(1)(viia)(c) of the Act. Therefore, the A.O has disallowed the claim after due verification. The Hon’ble Apex Court while confirming the decision of Hon’ble Delhi High Court in the case of CIT vs. Kelvinator of India has observed as under: "....., we find that, prior to the Direct Tax Laws (Amendment) Act, 1987, reopening could