EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri George Mathan & Shri Ramit Kochar

90 taxmann.com 86 (Karnataka). 5.3 The Ld.AR submitted in rejoinder that it is a case of transactions between holding company and subsidiary company, which itself shows that these transactions are governed by commercial expediency and hence there is no need to go further to prove that these are business transactions governed by commercial expediency . 6. We have heard rival contentions

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 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 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. 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

M/S. ARCHANA FEMALE CHILD 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. 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 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

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

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 147 of the 1961 Act , by holding as under: “5. I have carefully considered the facts of the case and the submissions of the ld.AR. I have also gone through the decisions and the circular relied on by the AO and AR. In this case the return had only been processed u/s.143(1) of the Act and no assessment

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 147 of the 1961 Act , by holding as under: “5. I have carefully considered the facts of the case and the submissions of the ld.AR. I have also gone through the decisions and the circular relied on by the AO and AR. In this case the return had only been processed u/s.143(1) of the Act and no assessment

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 147 of the 1961 Act , by holding as under: “5. I have carefully considered the facts of the case and the submissions of the ld.AR. I have also gone through the decisions and the circular relied on by the AO and AR. In this case the return had only been processed u/s.143(1) of the Act and no assessment

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 147 of the 1961 Act , by holding as under: “5. I have carefully considered the facts of the case and the submissions of the ld.AR. I have also gone through the decisions and the circular relied on by the AO and AR. In this case the return had only been processed u/s.143(1) of the Act and no 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

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 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