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

35\nof the paper book), the Ld.AR submitted that all assets and liabilities of the\nproprietorship concern stood vested in the company; hence, the first statutory\ncondition stood fulfilled. Drawing attention to para 10 of the assessment order,\nthe Ld. AR submitted that the AO has categorically recorded that the assessee's\npost-succession shareholding in the company

FAIVELEY TRANSPORT TECHNOLOGIES INDIA PVT. LTD.,HOSUR vs. ACIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

ab-initio, as the twin conditions prescribed under Section 263 of the Act, i.e., the order of the Learned Assessing Officer ('Ld. AO') shall be 'erroneous' and 'prejudicial to the interests of the Revenue' are not satisfied. 2.2. On the facts and circumstances of the case and in law, the Ld. PCIT erred in concluding that the order

ST.JOSEPH'S EDUCATIONAL TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

35,33,650/- for the asst. year 2020-21. Also, furnish the following details in connection with corpus donation received for the asst. years 2014-15 to 2020-21: S.No Asst. Name & Amount of Corpus Date of receipt of year Address of donation donation donation/corpus donor(s) donation Contact No. JAYARAMAN SARAVANAN DC/ACIT CENT CIR 1(3) CHENNAΙ

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

35,33,650/- for the asst. year 2020-21. Also, furnish the following details in connection with corpus donation received for the asst. years 2014-15 to 2020-21: S.No Asst. Name & Amount of Corpus Date of receipt of year Address of donation donation donation/corpus donor(s) donation Contact No. JAYARAMAN SARAVANAN DC/ACIT CENT CIR 1(3) CHENNAΙ

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

35 33 (P.) Ltd. Pradesh 7 Saravana Developers HC-Karnataka 387 ITR 239 57 8 Chemsworth (P.) Ltd. HC-Karnataka 119 taxmann.com 65 358 9 Hari Iron Trading Co HC-Punjab & 263 ITR 437 69 Haryana 10 Shriram Properties Limited ITAT-Chennai 2023 (4) TMI 375 76 11 Cavinkare (P.) Ltd. ITAT-Chennai 149 taxmann.com 97 296 12 Rajkumar Impex

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

35,33,650/- for the asst. year 2020-21.\nAlso, furnish the\nfollowing details in connection with corpus donation received for the asst. years\n2014-15 to 2020-21:\nS.No Asst.\nyear\nName\n& Amount\nAddress of donation\nof Corpus\ndonor(s)\nContact No.\nDate of receipt of\ndonation/corpus\ndonation\nJAYARAMAN SARAVANAN\nDC/ACIT CENT CIR 1(3) CHENNAI

INTERNATIONAL SEAPORT DREDGING PRIVATE LIMITED,CHENNAI vs. PCIT - 1, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI MANU KUMAR GIRI (Judicial Member)

35(4)” is finding mentioned therein as under: Assessment year Amount of brought Amount of forward unabsorbed depreciation set off Sl.No depreciation against the current year income (1) (2) (3) (4) i 2016-17 ii 2013-14 14491494 14491494 iii 2012-13 148847374 148847374 iv 2010-11 270130659 270130659 v 2009-10 164803652 164803652 vi Total 598273179 598273179 ii. Facts

CT. RAMANATHAN (HUF),PUDUKKOTTAI vs. PCIT 1, MADURAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.761/Chny/2025 Assessment Years: 2020-21 C.T.Ramanathan(Huf), Income Tax Officer, No.7/45, Ct.Rm.S.House, M.St.S. Street Ward-1, Kulipirai, Pudukottai Dist, Pudukottai. Tamil Nadu-622 402. [Pan: Aaahc0701L] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.V.Subbarayan, Dcit(Retd.) प्रत्यर्थी की ओर से /Revenue By : Mr.M.K.Biju, Cir Dr By Virtual. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 25.06.2025 आदेश / O R D E R

35 Ltd. Pradesh Chemsworth (P.) Ltd. HC-Karnataka 119 taxmann.com 358 Shriram Properties Limited ITAT-Chennai 2023 (4) TMI 375 Cavinkare (P.) Ltd. ITAT-Chennai 149 taxmann.com 296 Rajkumar Impex Pvt. Limited ITAT-Chennai 2023 (6) TMI 812 FCA Engineering India Pvt. Ltd. ITAT-Chennai ITΑ 684/CHNY/2023 Keller (M) SDN BHD ITAT-Chennai ITA 1319/CHNY/2023 International Seaport Dredging ITAT-Chennai

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

In the result, all the three appeals of the assessee stand allowed

Bench: Shri George George K & Shri S.R. Raghunatha

ab initio and consequently, the reassessment order passed on 29.03.2024, being founded upon an invalid notice, stands vitiated in entirety and deserves to be quashed. 21. The assessee relies on the following decision in support of his submission: 21.1 The ld.AR submitted that the Hon’ble Bombay High Court in the case of Hexaware Technologies Vs. Commissioner of Income

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

2) statements. The Ld. AR however rebutted ITA No.1321/Chny/2025 & Others R. Viswanathan :: 58 :: this plea of the Ld. CIT, DR by showing us that, Shri CPA had retracted these statements on 09.05.2017 and thereafter he was also cross- examined by the Revenue and his statement was recorded on 06.06.2017. The Ld. AR submitted that during his cross examination, Shri

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

35 :: addition. This according to him, showe addition. This according to him, showed that, the AO himself doubted the d that, the AO himself doubted the credibility and reliability of the electronic data found in the database credibility and reliability of the electronic data found in the database credibility and reliability of the electronic data found in the database seized

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

35 :: addition. This according to him, showe addition. This according to him, showed that, the AO himself doubted the d that, the AO himself doubted the credibility and reliability of the electronic data found in the database credibility and reliability of the electronic data found in the database credibility and reliability of the electronic data found in the database seized

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

35 :: addition. This according to him, showe addition. This according to him, showed that, the AO himself doubted the d that, the AO himself doubted the credibility and reliability of the electronic data found in the database credibility and reliability of the electronic data found in the database credibility and reliability of the electronic data found in the database seized

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

ab-initio void. According to Ld AR, in order to validly usurp\njurisdiction u/s 153C of the Act, it was incumbent upon the AO to first\nidentify the relevant material, that was found and seized from the\npremises of the searched person(s), which in his view, ‘belonged to’ or\n‘related to’ or ‘pertained to’ the assessee

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

ab-initio void. According to Ld AR, in order to validly usurp\njurisdiction u/s 153C of the Act, it was incumbent upon the AO to first\nidentify the relevant material, that was found and seized from the\npremises of the searched person(s), which in his view, ‘belonged to’ or\n‘related to’ or ‘pertained to’ the assessee

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

ab-initio void. According to Ld AR, in order to validly usurp\njurisdiction u/s 153C of the Act, it was incumbent upon the AO to first\nidentify the relevant material, that was found and seized from the\npremises of the searched person(s), which in his view, ‘belonged to’ or\n‘related to’ or ‘pertained to’ the assessee