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

44 -: income. The notice u/s 143(2) of the 1961 Act was not originally issued and return of income was manually processed by invoking provisions of Section 143(1) of the 1961 Act . It was submitted that department has all the right to invoke provisions of Section 147 of the 1961 Act. The learned CIT-DR relied upon decision

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

44 -: income. The notice u/s 143(2) of the 1961 Act was not originally issued and return of income was manually processed by invoking provisions of Section 143(1) of the 1961 Act . It was submitted that department has all the right to invoke provisions of Section 147 of the 1961 Act. The learned CIT-DR relied upon decision

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT LTU-II, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act and hence, the reopening is bad in law and (ii) the second issue raised is that the assessee filed complete details before AO during original assessment proceedings and hence, there is change of opinion in reopening of assessment on the same set of facts because no new material is brought on record for reopening

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

u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically in the case of Srichand Lalchand Talreja v. Asst CIT, (1998) 98 Taxman 14, 19 (Bom), where the information regarding acquisition of the asset was not available with the Assessing Officer during the relevant assessment year

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

u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically in the case of Srichand Lalchand Talreja v. Asst CIT, (1998) 98 Taxman 14, 19 (Bom), where the information regarding acquisition of the asset was not available with the Assessing Officer during the relevant assessment year

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

u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically in the case of Srichand Lalchand Talreja v. Asst CIT, (1998) 98 Taxman 14, 19 (Bom), where the information regarding acquisition of the asset was not available with the Assessing Officer during the relevant assessment year

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

147 to verify the source of the immovable property purchased by him to the tune of Rs.39,42,000/- . The AO issued notice u/s 148 to the assessee on 27.03.2017. In response to the notice 148, the assessee filed return of income on 13.12.2021 declaring a total income of Rs. 0/-. In response to notice under C.O.No.27/Chny/2025 section

SANTECH SOLUTONS PVT LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is treated as 9

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No.1036/Mds/2016 "नधा"रण वष" /Assessment Year : 2008-2009

u/s 148 was issued’’. During the course of assessment proceedings, assessee had filed a letter dated 12.11.2010 which stated as under:- Date: 12/11/2010 To The Assistant Commissioner of Income Tax Company Circle VI(I), Chennai - 34 Sub:!T Assessment - AY 08-09 Ref Notice u/s.143(2) dated 12.08.2009 Dear Sir, Further to our appearance before your goodself

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

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

44,730 Total : Rs.3,47,01, 173 The release of above amounts during the previous year relevant to assessment year 2008-09 related to reserves created in earlier years. Prior to assessment year 2008-09 i.e. upto assessment year 2007-08 the bank was entitled to claim deduction under Section 80P of the I.T. Act, 1961. From the assessment year

M/S. ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, NCC-8(1), LTU-II,, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

reassessment proceedings beyond four years from the end of the relevant assessment year, then the AO is duty bound to demonstrate in his reasons recorded prior to issue of notice, the failure on the assessee's part to truly and fully disclose all material facts in the course of original assessment. 12. This legal principle has been reiterated

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 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

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