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

reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the assessment year assessment year relevant to the previous year in which search is relevant to the previous year in which search is conducted. Applying this yardstick, the conducted. Applying this

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

reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the assessment year assessment year relevant to the previous year in which search is relevant to the previous year in which search is conducted. Applying this yardstick, the conducted. Applying this

DEPUTY COMMISSIONER OF INCOME TAX, NUMGAMBAKKAM vs. JAGANNATHAN SEKAT, CHENNAI

In the result, appeal filed by the In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

u/s 132(4) of the Act cannot be basis of the sworn statement recorded u/s 132(4) of the Act cannot be basis of the sworn statement recorded u/s 132(4) of the Act cannot be sustainable and further held that the admission made u/ sustainable and further held that the admission made u/s

S.SATHYANARAYANAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao]

unexplained investment is applicable only in the case when if the ITA Nos.754 to 756/2015 :- 11 -: amount found during the search is surrendered and tax with interest is paid and the assessee had disclosed the manner in which he had derived undisclosed income. In the present case, admittedly, assessee had only paid taxes partly and all the assessed income

S.SATHYANARAYANAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao]

unexplained investment is applicable only in the case when if the ITA Nos.754 to 756/2015 :- 11 -: amount found during the search is surrendered and tax with interest is paid and the assessee had disclosed the manner in which he had derived undisclosed income. In the present case, admittedly, assessee had only paid taxes partly and all the assessed income

S.SATHYANARAYANAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao]

unexplained investment is applicable only in the case when if the ITA Nos.754 to 756/2015 :- 11 -: amount found during the search is surrendered and tax with interest is paid and the assessee had disclosed the manner in which he had derived undisclosed income. In the present case, admittedly, assessee had only paid taxes partly and all the assessed income

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

unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy CIT, (2012) 340 ITR 53 (Del), there being omission and failure on the part of the assessee to disclose fully and truly material facts Thus reassessment proceedings were held 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

unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy CIT, (2012) 340 ITR 53 (Del), there being omission and failure on the part of the assessee to disclose fully and truly material facts Thus reassessment proceedings were held 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

unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy CIT, (2012) 340 ITR 53 (Del), there being omission and failure on the part of the assessee to disclose fully and truly material facts Thus reassessment proceedings were held to be valid

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

Unexplained cash credits u/s 68 Rs. 2,93,50,000/- Total income Rs. 3,38,42,228/- 6. Aggrieved, assessee challenged the order of assessment u/s 143(3)/147 dated 30.03.2022 before the ld. CIT(A). 7. The ld. CIT(A) in its order from paras 7-7.8 has reproduced the reasons for reopening, relevant portion of Profit and Loss

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

K.SURESH,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

u/s 147 of the Act. 5.2 In the present case, the assessee has not shown bank account with Axis Bank, Adyar Branch, Chennai. As per Explanation 2 of Section147, it is very clear that due to non- disclosure of this by the assessee, the income chargeable to tax had escaped assessment. The assessee has not produced anything before the Commissioner

SHRI GOPAL YADEV SELVA KUMAR,VELLORE vs. ITO, WARD-2, VELLORE

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

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri G. Manjunathaआयकर अपील सं./Ita No.111/Chny/2018 िनधा"रण वष" /Assessment Year: 2011-12 Mr.Gopal Yadav Selva Kumar, V. The Income Tax Officer, 65, Vellore Main Road, Ward-2, 1St Street, Arcot, Vellore-632 503. Vellore. [Pan: Btsps 5973 E] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.Salai Varun Isai Azhagan, Adv. ""यथ" क" ओर से /Respondent By : Mr.Ar.V.Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 15.11.2021 घोषणा क" तारीख /Date Of Pronouncement : 12.01.2022

unexplained investment. 3. The assessee carried the matter in appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee has challenged the reopening of assessment on multiple grounds including non-disposal of objections filed by the assessee in light of the decision of the Hon’ble Supreme Court in the case of M/s.GKN Driveshafts (India) Ltd. v. ITO reported

MENAKURU SUKUMAR REDDY,HYDERABAD vs. DCIT(A), CHENNAI

In the result the appeal of the revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

reassessment proceedings on the following counts: (i) Lack of jurisdiction in issuance of notice u/s 148 of the Act; (ii) Improper service of notice u/s 148 on an incorrect email ID; and (iii) Absence of Document Identification Number (DIN) in the assessment order. However, since the detailed arguments were also addressed on merits by the parties, we first proceed

MENAKURU SUKUMAR REDDY,HYDERABAD vs. DCIT(A), CHENNAI

In the result the appeal of the revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

reassessment proceedings on the following counts: (i) Lack of jurisdiction in issuance of notice u/s 148 of the Act; (ii) Improper service of notice u/s 148 on an incorrect email ID; and (iii) Absence of Document Identification Number (DIN) in the assessment order. However, since the detailed arguments were also addressed on merits by the parties, we first proceed

DCIT, CENTRAL CIRCLE 2(3), CHENNAI vs. RATHINAM PRABAKARAN, KARUR

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1154/Chny/2024 िनधा9रण वष9 /Assessment Year: 2015-16 The Dy. Commissioner Of Rathinam Prabakaran, Income Tax, Vs. 39, Narasimmapuram North, Central Circle-2(3), Karur - 639 001. Chennai. [Pan: Aaipp 4501B]

147 of the Income-tax Act,1961 (hereinafter “the Act”) on 26.03.2022. Rathinam Prabakaran :- 2 -: 2. There is a delay of 17 days in filing the appeal by the Revenue. The Revenue has filed condonation petition stating the reasons for delay in filing the appeal. We have considered the petition of delay in filing the appeal and satisfied that there