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82 results for “section 68”+ Section 164clear

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Key Topics

Addition to Income42Section 14839Section 143(3)37Section 246A33Section 14728Reopening of Assessment28Section 6826Section 133A26Section 153A24

SUNDARAM SUBRAMANIAN REP. BY LEGAL HEIR S SUNDARAM,PUDUKKOTTAI vs. ITO, CIRCLE-2(1), TRICHY

In the result, both the appeals of the Assessee are partly allowed

ITA 2420/CHNY/2025[2014-15]Status: DisposedITAT Chennai12 Jan 2026AY 2014-15

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

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 147Section 148Section 251Section 68

164 taxmann.com 781 (Calcutta)[27-06-2024] wherein it was held: “Where revenue issued a show cause notice to assessee for adding back amount in question as 'unexplained cash credits' under section 68

SUNDARAM SUBRAMANIAN,PUDUKKOTTAI vs. ITO, CIRCLE-2(1), TRICHY

Showing 1–20 of 82 · Page 1 of 5

Disallowance23
Reassessment22
Section 13216

In the result, both the appeals of the Assessee are partly allowed

ITA 2419/CHNY/2025[2013-14]Status: DisposedITAT Chennai12 Jan 2026AY 2013-14

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

For Appellant: Shri. Y. Sridhar, F.C.AFor Respondent: Shri. Shiva Srinivas, C.I.T
Section 147Section 148Section 251Section 68

164 taxmann.com 781 (Calcutta)[27-06-2024] wherein it was held: “Where revenue issued a show cause notice to assessee for adding back amount in question as 'unexplained cash credits' under section 68

ITO, CHENNAI vs. TVS SHRIRAM GRWOTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

ITA 1345/CHNY/2016[2009-10]Status: DisposedITAT Chennai07 Jun 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

For Respondent: Mr.Percy J. Pardewalla, Sr
Section 10Section 115Section 161(1)Section 164Section 40A(2)(b)

164(1), the relevant income will be assessable not at the maximum rate but at the rate applicable to it as if it were the total income of an AOP. 62. In the present case the AO has not invoked the provisions of Sec.161(1A) of the Act or the proviso to Sec.164(1) of the Act and therefore

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

ITA 982/CHNY/2016[2010-11]Status: DisposedITAT Chennai07 Jun 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

For Respondent: Mr.Percy J. Pardewalla, Sr
Section 10Section 115Section 161(1)Section 164Section 40A(2)(b)

164(1), the relevant income will be assessable not at the maximum rate but at the rate applicable to it as if it were the total income of an AOP. 62. In the present case the AO has not invoked the provisions of Sec.161(1A) of the Act or the proviso to Sec.164(1) of the Act and therefore

ITO, CHENNAI vs. TVS SHRIRAM GROWTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

ITA 1401/CHNY/2016[2010-11]Status: DisposedITAT Chennai07 Jun 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

For Respondent: Mr.Percy J. Pardewalla, Sr
Section 10Section 115Section 161(1)Section 164Section 40A(2)(b)

164(1), the relevant income will be assessable not at the maximum rate but at the rate applicable to it as if it were the total income of an AOP. 62. In the present case the AO has not invoked the provisions of Sec.161(1A) of the Act or the proviso to Sec.164(1) of the Act and therefore

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

ITA 981/CHNY/2016[2009-10]Status: DisposedITAT Chennai07 Jun 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

For Respondent: Mr.Percy J. Pardewalla, Sr
Section 10Section 115Section 161(1)Section 164Section 40A(2)(b)

164(1), the relevant income will be assessable not at the maximum rate but at the rate applicable to it as if it were the total income of an AOP. 62. In the present case the AO has not invoked the provisions of Sec.161(1A) of the Act or the proviso to Sec.164(1) of the Act and therefore

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

ITA 1902/CHNY/2016[2009-10]Status: DisposedITAT Chennai07 Jun 2017AY 2009-10

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

For Respondent: Mr.Percy J. Pardewalla, Sr
Section 10Section 115Section 161(1)Section 164Section 40A(2)(b)

164(1), the relevant income will be assessable not at the maximum rate but at the rate applicable to it as if it were the total income of an AOP. 62. In the present case the AO has not invoked the provisions of Sec.161(1A) of the Act or the proviso to Sec.164(1) of the Act and therefore

ALAGU PROCESS,TIRUPUR vs. ITO, WARD 2(1), TIRUPPUR

In the result the appeal of the assessee is partly allowed

ITA 695/CHNY/2024[2017-18]Status: DisposedITAT Chennai04 Sept 2024AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.695/Chny/2024 िनधा"रण वष" /Assessment Year: 2017-18 Alagu Process, The Income Tax Officer, S.F No.414, Vs. Ward-2(1), Palavanjipalayam Ring Road, Tiruppur. Veerapandi Post, Tirupur – 641 605. [Pan: Aavfa 5147P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri S. Sridhar (Erode), Advocate ""थ" की ओर से /Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/Date Of Hearing : 26.06.2024 घोषणा की तारीख /Date Of : 04.09.2024 Pronouncement आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), (Nfac), Delhi [Hereinafter “Cit(A)”] In Din & Order No. Itba/Nfac/S/250/2023- 24/105992446(1), Dated 19.01.2024. The Assessment Was Framed By The Assessing Officer For The Assessment Year 2017-18 U/S.147 R.W.S

For Appellant: Shri S. Sridhar (Erode), AdvocateFor Respondent: Shri D. Hema Bhupal, JCIT
Section 147Section 148Section 44ASection 68Section 69A

68 instead of Section 69A was a curable mistake, without considering the unique nature and scope of each such provision and the satisfaction to be arrived by the Assessing Officer before invoking each of them. And, for other reasons that may be adduced at the time of hearing, the Appellant humbly prays that the present appeal be admitted, considered

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

ITA 1840/CHNY/2025[2017-18]Status: DisposedITAT Chennai15 Dec 2025AY 2017-18
For Appellant: Shri. R.Venkata Raman, C.AFor Respondent: Shri. Shiva Srinivas, CIT
Section 142(1)Section 143(2)Section 143(3)Section 250Section 47Section 68

sections 14A and 68\nof the Act. By making an addition u/s.69 of the Act, the AO has clearly exceeded\nthe jurisdiction vested in him and travelled beyond the scope of limited scrutiny.\n96. For this reason, we are unable to subscribe to the reasoning adopted by\nthe Ld.CIT(A) that since the asset was included in the gain

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

ITA 1801/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Oct 2025AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

section 139 has been filed after the date of search. Therefore, in the facts and circumstances of the case, these grounds of appeal have no merits." 7.2.6 Thus Hon'ble Delhi High Court has taken view that there is no bar in making regular additions while making assessment u/s 153A for those years where return has not been filed

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

ITA 1535/CHNY/2024[2016-17]Status: DisposedITAT Chennai31 Oct 2025AY 2016-17

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

section 139 has been filed after the date of search. Therefore, in the facts and circumstances of the case, these grounds of appeal have no merits." 7.2.6 Thus Hon'ble Delhi High Court has taken view that there is no bar in making regular additions while making assessment u/s 153A for those years where return has not been filed

SMT. DEVAKUMARI,CHENNAI vs. ACIT, NCC-11, , CHENNAI

In the result, the appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 3066/CHNY/2019[2014-15]Status: DisposedITAT Chennai13 Sept 2023AY 2014-15

Bench: Shri V. Durga Rao & Shri Manjunatha, G.Corrigendum To I.T.A. No.3066/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Smt. Devakumari, Vs. The Assistant Commissioner Of No. 48, Venkata Maistry Street, Income Tax, Mannady, Chennai 600 001. Non Corporate Circle 11, [Pan:Aagpd0150L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) शु""प" आदेश /Corrignendum Order Per V. Durga Rao: The Appeal Of The Assessee In Ita No. 3066/Chny/2019 As Well As The Appeal Filed By The Revenue In Ita No. 3181/Chny/2019 For The Assessment Year 2014-15 Were Disposed Off By The Division Bench ‘B’, Chennai Benches, Chennai Vide Common Order Dated 13.09.2023. The Ld. Counsel For The Assessee Has Brought To The Notice That There Is A Typographical Error In Last Sentence In Para 9 Of The Order, Wherein, The Bench Has Observed That The Element Of Personal Usage Cannot Be Ruled Out In The Absence Of Production Of Electricity Bills & Thereby, The Addition To The Extent Of ₹.2,00,000/- Has Been Sustained Out Of Addition Confirmed By The Ld. Cit(A). However, It Was Also Mentioned That The “Balance Addition Of ₹.3,00,000/- Stands Sustained” Is A Typographical Error.

Section 143(2)Section 143(3)

68 of the Act as well as disallowance of interest relating thereon of ₹.1,01,050/-. 7.1 Before us, the ld. Counsel for the assessee has submitted that both the minors have received gifts in the previous assessment year and the amounts were lying in the bank accounts of the minors unused. Thus, the 14 I.T.A. Nos.3066 & 3181/Chny/19 minors offered

ACIT, NCC-11,, CHENNAI vs. SMT. DEVAKUMARI,, CHENNAI

In the result, the appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 3181/CHNY/2019[2014-15]Status: DisposedITAT Chennai13 Sept 2023AY 2014-15

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.3066/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Smt. Devakumari, Vs. The Assistant Commissioner Of No. 48, Venkata Maistry Street, Income Tax, Mannady, Chennai 600 001. Non Corporate Circle 11, Chennai. [Pan:Aagpd0150L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.3181/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Assistant Commissioner Of Vs. Smt. Devakumari, Income Tax, No. 48, Venkata Maistry Street, Non Corporate Circle 11(1), Mannady, Chennai 600 001. Chennai.

For Appellant: Shri N. Arjun Raj, CAFor Respondent: Shri D. Hema Bhupal, JCIT
Section 143(2)Section 143(3)Section 68

68 of the Act as well as disallowance of interest relating thereon of ₹.1,01,050/-. 7.1 Before us, the ld. Counsel for the assessee has submitted that both the minors have received gifts in the previous assessment year and the amounts were lying in the bank accounts of the minors unused. Thus, the 11 I.T.A. Nos.3066 & 3181/Chny/19 minors offered

ACIT CENTRAL CIRCLE 3(1), CHENNAI vs. SHIV SAHAI & SONS (INDIA) LTD., CHENNAI

ITA 1988/CHNY/2017[2011-12]Status: DisposedITAT Chennai27 Jun 2018AY 2011-12

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. N. Muralikumaran, AdvocateFor Respondent: Shri. D. Prabhu Mukunth Arun
Section 132Section 153A

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

ITA 1485/CHNY/2017[2006-07]Status: DisposedITAT Chennai27 Jun 2018AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. N. Muralikumaran, AdvocateFor Respondent: Shri. D. Prabhu Mukunth Arun
Section 132Section 153A

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

ITA 1449/CHNY/2017[2006-07]Status: DisposedITAT Chennai27 Jun 2018AY 2006-07

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. N. Muralikumaran, AdvocateFor Respondent: Shri. D. Prabhu Mukunth Arun
Section 132Section 153A

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

SAHAI & SONS (I) LTD.,CHENNAI vs. DCIT, CHENNAI

ITA 1447/CHNY/2017[2011-12]Status: DisposedITAT Chennai27 Jun 2018AY 2011-12

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

For Appellant: Shri. N. Muralikumaran, AdvocateFor Respondent: Shri. D. Prabhu Mukunth Arun
Section 132Section 153A

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

In the result, appeals filed by the Revenue are dismissed\nand Cross Objections filed by the assessee are partly allowed

ITA 1303/CHNY/2023[2015-16]Status: DisposedITAT Chennai09 Oct 2024AY 2015-16
Section 1Section 13(1)(c)Section 13(3)(e)Section 147

164(2) of the Act He further held\nthat once there was violation under section 13(1)(c), the trust would lose\nexemption under section 11 in respect of the other income also and thereby\nadded Rs.19,59,537/-and taxed the same at maximum marginal rate.\n5.5 The appellant has contended that the trust installed the Siemens

INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

ITA 1302/CHNY/2023[2014-15]Status: DisposedITAT Chennai09 Oct 2024AY 2014-15
Section 1Section 13(1)(c)Section 13(3)(e)

164(2) of the Act He further held\nthat once there was violation under section 13(1)(c), the trust would lose\nexemption under section 11 in respect of the other income also and thereby\nadded Rs.19,59,537/-and taxed the same at maximum marginal rate.\n5.5 The appellant has contended that the trust installed the Siemens

INCOME TAX OFFICER , BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

In the result, Cross Objections filed by the assessee are partly

ITA 1304/CHNY/2023[2016-17]Status: DisposedITAT Chennai09 Oct 2024AY 2016-17

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

For Appellant: Mr. Arjun Raj, AdvocateFor Respondent: Dr. Samuel Pitta, JCIT
Section 1Section 13(1)(c)Section 13(3)(e)Section 147

164(2) of the Act He further held that once there was violation under section 13(1)(c), the trust would lose exemption under section 11 in respect of the other income also and thereby added Rs.19,59,537/-and taxed the same at maximum marginal rate. 5.5 The appellant has contended that the trust installed the Siemens