M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

u/s 147, which the appellant has, it is considered, to have erroneously and prematurely appealed against. 9. During the course of the appellate proceeding the AR has filed a note relating to what has been termed as his deniability of liability to be assessed / reassessed and its appealibility, the contents of which are reproduced hereunder: “1. The appeal against

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

reassess such income. Proviso to section 147 of course requires that where the assessment under sub-section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of the four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped

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

reassess such income. Proviso to section 147 of course requires that where the assessment under sub-section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of the four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped

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

reassess such income. Proviso to section 147 of course requires that where the assessment under sub-section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of the four years from the end of the relevant assessment year, unless any income chargeable to tax has escaped

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

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

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

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

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

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

reassessment cannot be continued on the basis of the original notice under Section 148, and that a fresh notice is necessary. 13. In this present appeal, the case has been reopened for scrutiny u/s 147 to verify the source of the immovable property purchased for a consideration of Rs.39,42,000/- and no addition has been made in assessment

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