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339 results for “reassessment u/s 147”+ Section 45(4)clear

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Key Topics

Section 14894Section 14783Section 143(3)75Addition to Income52Section 13239Reassessment32Disallowance28Section 153A21Section 153C

EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

ITA 1503/CHNY/2014[2005-06]Status: DisposedITAT Chennai07 Nov 2019AY 2005-06

Bench: Shri George Mathan & Shri Ramit Kochar

Section 143(3)Section 147Section 148Section 2(22)(e)

4. In the present case, the assessment is sought to be reopened within a period of four years of the end of the relevant Assessment Year. Where an assessment is sought to be reopened beyond a period of four years, the proviso to Section 147 stipulates as a jurisdictional requirement that there must be a failure on the part

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

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

ITA 307/CHNY/2010[2001-02]Status: Disposed

Showing 1–20 of 339 · Page 1 of 17

...
19
Section 25019
Reopening of Assessment18
Section 143(2)15
ITAT Chennai
19 May 2020
AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

45 -: learned CIT-DR that there were tangible material before the AO to come to conclusion that the income of the assessee has escaped assessment and the reasons for reopening of concluded assessment were having live link with t formation of belief that income of the assessee has escaped assessment. The learned CIT-DR relied upon decision

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

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

ITA 1016/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

45 -: learned CIT-DR that there were tangible material before the AO to come to conclusion that the income of the assessee has escaped assessment and the reasons for reopening of concluded assessment were having live link with t formation of belief that income of the assessee has escaped assessment. 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

ITA 1324/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

45 -: learned CIT-DR that there were tangible material before the AO to come to conclusion that the income of the assessee has escaped assessment and the reasons for reopening of concluded assessment were having live link with t formation of belief that income of the assessee has escaped assessment. The learned CIT-DR relied upon decision

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

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

ITA 1015/CHNY/2012[2001-02]Status: DisposedITAT Chennai19 May 2020AY 2001-02

Bench: Shri George Mathan & Shri Ramit Kochar

For Appellant: Mr. S.Sridhar, AdvFor Respondent: Dr. M.Srinivasa Rao, CIT
Section 143(3)Section 147Section 263

45 -: learned CIT-DR that there were tangible material before the AO to come to conclusion that the income of the assessee has escaped assessment and the reasons for reopening of concluded assessment were having live link with t formation of belief that income of the assessee has escaped assessment. The learned CIT-DR relied upon decision

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2578/CHNY/2017[2010-11]Status: DisposedITAT Chennai06 Dec 2018AY 2010-11

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

45 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells tax and, the reassessment was held to be valid. In Sunder Carpet Industries v. ITO, (2010) 324 ITR 417 (All), held that the Departmental Valuer's Report constituted material for entertaining a belief of escaped income in the years under consideration. The reassessment proceeding was held to be valid. 5.22. In Aurobindo Sanitary

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2579/CHNY/2017[2013-14]Status: DisposedITAT Chennai06 Dec 2018AY 2013-14

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

45 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells tax and, the reassessment was held to be valid. In Sunder Carpet Industries v. ITO, (2010) 324 ITR 417 (All), held that the Departmental Valuer's Report constituted material for entertaining a belief of escaped income in the years under consideration. The reassessment proceeding was held to be valid. 5.22. In Aurobindo Sanitary

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2580/CHNY/2017[2014-15]Status: DisposedITAT Chennai06 Dec 2018AY 2014-15

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

45 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells tax and, the reassessment was held to be valid. In Sunder Carpet Industries v. ITO, (2010) 324 ITR 417 (All), held that the Departmental Valuer's Report constituted material for entertaining a belief of escaped income in the years under consideration. The reassessment proceeding was held to be valid. 5.22. In Aurobindo Sanitary

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. 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-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

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 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

INCOME TAX OFFICER, COIMBATORE vs. DAMAYANTI RAMACHANDRAN, GN MILLS POST, COIMBATORE

In the result, both the appeals of revenue for the A

ITA 103/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Aug 2025AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.103/Chny/2025, ननिाारण वर्ा/Assessment Year: 2015-16

For Appellant: Mr.Ketan K. Ved, C.AFor Respondent: Mr.Bipin C.N, CIT
Section 45(4)

u/s 147 was passed. Final assessment order was passed. 11.1 The ld.DR further submitted that after the assessee has requested for reasons, the AO has provided the reasons on 29.09.2020. Thereafter the assessee has raised objections against the reopening of the case. The AO has disposed of the reasons with a speaking Order on 10.09.2021. The final Order was completed

SHRI R PANNERSELVAM,,CHENNAI vs. DCIT, CC-3(3),, CHENNAI

In the result, the appeal filed by the assessee is allowed

ITA 3356/CHNY/2019[2008-09]Status: DisposedITAT Chennai23 May 2022AY 2008-09

Bench: Shri Mahavir Singhand Shri Girish Agrawal

For Appellant: Shri. S. Sridhar, Advocate &For Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 143(3)Section 147Section 263Section 54F

45,066/- from NHAI for the land acquired for NH-4 project. However, the assessee had not offered any capital gain from the above transaction. Due to assessee's failure to admit capital gains in respect of the above, there is reason to believe that income chargeable to tax has escaped assessment. During the course of survey it was found

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

ITA 1670/CHNY/2024[2018-19]Status: DisposedITAT Chennai21 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri G. Baskar, Advocate &For Respondent: Ms. Gouthami Manivasagam, JCIT
Section 11Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 2(15)

4 placed at page 110 of the paper book. On perusal of page 111 of the paper book, it is noted that the assessee has shown purchase cost, amount applied for charitable purpose and amount accumulated or set apart for specified purposes, which clearly demonstrates that the Assessing Officer specifically asked the assessee to furnish the details 18 I.T.A. Nos.1667

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

ITA 1256/CHNY/2025[2014-15]Status: DisposedITAT Chennai21 Nov 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 148Section 20Section 250

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

ITA 1236/CHNY/2025[2016-17]Status: DisposedITAT Chennai21 Nov 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Mrs. C. Yamuna, CIT &
Section 132Section 148Section 20Section 250

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