DEPUTY COMMISSIONER OF INCOME-TAX, COIMBATORE vs. MS VISWA AND DEVJI DIAMONDS PVT LTD, COIMBATORE

In the result, appeal filed by the Revenue stands dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.327/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-2018. The Deputy Commissioner Viswa & Devji Diamonds Pvt Ltd, Of Income Tax, Vs. New No.16,Old No.239, Corporate Circle 1, T.V.Swamy Road (East) Coimbatore R.S. Puram, Coimbatore 641 002. Pan: Aaccv 4942M

142(1) of the Act were issued to the assessee calling for details of cash deposits during demonetization period. In response to notices, the assessee filed the details through e-proceedings. In support of the demonetization deposits the assessee submitted sales ledger, cash book, stock and VAT returns along with detailed statement of month wise cash deposits to the bank

BONDALAPATI SHIVAJI RAO,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), CHENNAI, CHENNAI

In the result, appeal filed by the assessee stands allowed and\nappeal filed by the Revenue is dismissed

142) wherein the Delhi Bench of this Tribunal held as\nfollows:-\n\"15.3 Since the satisfaction was recorded on 27th July, 2012, therefore,\ndeemed date of search in the case of other person for computing the\nperiod of six years is 27th July, 2012 and the six assessment years\nimmediately preceding the assessment year relevant to previous year in\nwhich

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

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

142 or Section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year." 16. This new Section has made a radical departure from the original Section 147 inasmuch as clauses (a) and (b) of the original Section 147 have been deleted and a new proviso added to Section

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

142 Taxman 713 (SC), where the Assessing Officer attempted to tax under Section 56 what could not be assessed under Section 45, stating as follows:\n\"The argument of the appellant that even if the income cannot be chargeable under section 45, because of the inapplicability of the computation provided under section 48, it could still

M/S. TATVA CLEAN ENERGIES PVT. LTD.,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

68 of the Act and made thereon under section 153A of the Act based on the statement of searched person and seized material, is not justified in the case of the assessee. 9 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 13. The above said conclusion is supported by the decision of the Hon’ble High Court of Gujarat in the case

M/S. MAHINDRA ORCHARDS PVT. LTD.,BANGALORE vs. ACIT, CC-1(2), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

68 of the Act and made thereon under section 153A of the Act based on the statement of searched person and seized material, is not justified in the case of the assessee. 9 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 13. The above said conclusion is supported by the decision of the Hon’ble High Court of Gujarat in the case

M/S. TATVA RENEWABLE POWER PVT. LTD.,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

68 of the Act and made thereon under section 153A of the Act based on the statement of searched person and seized material, is not justified in the case of the assessee. 9 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 13. The above said conclusion is supported by the decision of the Hon’ble High Court of Gujarat in the case

M/S. PIPPALA LEAF DEVELOPERS PVT. LTD.,HYDERABAD vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

68 of the Act and made thereon under section 153A of the Act based on the statement of searched person and seized material, is not justified in the case of the assessee. 9 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 13. The above said conclusion is supported by the decision of the Hon’ble High Court of Gujarat in the case

M/S. OJAS PLANTATIONS PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1769/Chny/2025 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Ojas Plantations Private Limited, Vs. The Assistant Commissioner Of No. 51, Park View Street, Near Gandhi Income Tax/Dc, Road, Alwarthirunagar, Tiruvallur, Central Circle 1(2), Chennai 600 087. Chennai. [Pan:Aabco1853F] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1770/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Pippala Leaf Developers Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aahcp2411J] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1771/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 M/S. Tatva Renewable Power Private Vs. The Assistant Commissioner Of Limited, (Studio N) Sy No. 70, Narne Income Tax/Dc, Nagar, Beside Lanco Hills, Manikonda, Central Circle 1(2), Hyderabad 500 075. Chennai. [Pan: Aaect8340D] (अपीलाथ"/Appellant) (""थ"/Respondent)

68 of the Act and made thereon under section 153A of the Act based on the statement of searched person and seized material, is not justified in the case of the assessee. 9 I.T.A. Nos.1769 to 1772 & 1793/Chny/25 13. The above said conclusion is supported by the decision of the Hon’ble High Court of Gujarat in the case

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

142 (2A) of the Act, after the search, and concluded that the depreciation could not have been claimed in respect of assets acquired by DSL out of the deferred government grant in terms of Explanation 10 to Section 43 (1) of the Act. 5. The Commissioner of Income Tax (Appeals) [CIT(A)] by the common order dated 25th April

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

142 (2A) of the Act, after the search, and concluded that the depreciation could not have been claimed in respect of assets acquired by DSL out of the deferred government grant in terms of Explanation 10 to Section 43 (1) of the Act. 5. The Commissioner of Income Tax (Appeals) [CIT(A)] by the common order dated 25th April

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

142 (2A) of the Act, after the search, and concluded that the depreciation could not have been claimed in respect of assets acquired by DSL out of the deferred government grant in terms of Explanation 10 to Section 43 (1) of the Act. 5. The Commissioner of Income Tax (Appeals) [CIT(A)] by the common order dated 25th April

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

142 (2A) of the Act, after the search, and concluded that the depreciation could not have been claimed in respect of assets acquired by DSL out of the deferred government grant in terms of Explanation 10 to Section 43 (1) of the Act. 5. The Commissioner of Income Tax (Appeals) [CIT(A)] by the common order dated 25th April