SHRI 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

u/s 143(2) will not make AO remediless u/s 147/148 of the 1961 Act. The learned CIT-DR relied upon decision of Hon’ble Supreme Court in the case of CIT v. P.V.S.Beedies Private Limited reported in (1999) 237 ITR 13(SC) and it was submitted that even objections raised by internal audit party could be basis for reopening

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

u/s 143(2) will not make AO remediless u/s 147/148 of the 1961 Act. The learned CIT-DR relied upon decision of Hon’ble Supreme Court in the case of CIT v. P.V.S.Beedies Private Limited reported in (1999) 237 ITR 13(SC) and it was submitted that even objections raised by internal audit party could be basis 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

147 and both the first appellate authority as well as the Tribunal accepted the contention of the ITA Nos.2578 to 2580/chny/2017 :- 46 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid

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

147 and both the first appellate authority as well as the Tribunal accepted the contention of the ITA Nos.2578 to 2580/chny/2017 :- 46 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid

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

147 and both the first appellate authority as well as the Tribunal accepted the contention of the ITA Nos.2578 to 2580/chny/2017 :- 46 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells assessee holding that so far as the reassessments related to assessment of unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid

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

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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 was framed u/s.143(3) of the Act vide order dated 26.03.2015 by making disallowance of deduction of Rs.3,47,01,173/- towards release of provisions and non-statutory reserves. Another disallowance was made on account of deduction claimed u/s.36(1)(viia) of the Act on account of non-creation of reserve and doubtful debts amounting to Rs.9

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

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

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

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

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

u/s 148 of the Act and by issuing notices under sections 143(2) and 142(1) of the Act sought details on certain points. In response to the said notices, the assessee filed details including objects of the assessee Trust which were reproduced in page No.2 of the assessment order. On examination of the same, we find that the assessee

ACIT, CUDDALORE CIRCLE,, CUDDALORE vs. M/S. THE CUDDALORE DISTRICT CENTRAL CO-OPERATIVE BANK LTD.,, CUDDALORE

In the result, the appeal of the Revenue is dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

reassessment order, the AO stated that details were called for and assessment was completed after going through the details furnished. This shows that details already filed during 1 round of 147 proceedings were examined and order was passed on 06.03.2015. Thereafter on 31.03.2015 i.e barely after lapse of 24 days, the AO issued notice u/s 148 for re-assessment