LEEYAKATHALI AZEESUR RAHMAN,COIMBATORE vs. ASSESSING OFFICER, COIMBATORE

आदेश /O R D E R

PER S. R. RAGHUNATHA, AM

This appeal has been preferred by the assessee against the order passed by the Learned Commissioner of Income Tax, Appeal (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “the Ld. CIT(A)”], dated 02.01.2026, arising from the assessment order dated 19.03.2024 for the Assessment Year (AY) 2022-23 passed by the Assessing Officer, Assessment Unit, Income Tax Department [hereinafter referred to as “the AO”], u/s. 143(3) r.w.s. 144B of the Income-tax Act, 1961 (hereinafter referred to as “the Act”).

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name of M/s.Simco Enterprises. The assessee filed his return of income for the AY 2022-23 by declaring an income of Rs.7,87,630/-. The case was selected for scrutiny under CASS for the following reasons:-

“Here the genuineness of transactions uploaded through CRIU, identity of parties related with transactions and whether the assessee has shown correct income in the ITR may be verified.”

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purchases and sales transactions, ledger copies of JM Jain LLP and confirmed that the assessee has not paid any amount of commission to the parties. Further, the assessee submitted that in respect of JM Jain LLP, the assessee has not made any purchases of Rs.2,09,04,055/- and also stated that no cash payment of Rs.1,18,35,400/- has been made to them. He further submitted that the transactions referred with respect to JM Jain LLP are not pertaining to the assessee and no single payment has been made from any of his bank accounts to JM Jain LLP and confirmed that no purchase transactions are reflected in GSTR2B and no e-way bill was generated to the assessee’s location from the parties. Hence, the proposal to make addition u/s.69C of the Act on account of alleged purchases debited to profit and loss account is not tenable under the Act and prayed for dropping the proposal. Further, the assessee confirmed that no commission also has been paid to them as there is no basic transaction itself made with JM Jain LLP by the assessee.

“Further, the ledger of the assessee in the books M/s. JM Jain LLP clearly depicts the transactions undertaken by the assessee with M/s. JM Jain LLP. It is also pertinent to mention here that the party-wise purchase details submitted by the assessee and the ledger of the assessee (Simco Enterprises) in the books of M/s. JM Jain LLP have names of numerous parties including Unimax Apparels, Deeplaxmi Garments, M.R. Ashoka Hosiery, Raghav Fabrics which are common parties. Hence, the claim of the assessee that he has not made any purchase through M/s. JM Jain LLP is false. As per the ledger, the assessee had made purchases of Rs.2,09,04,055/- (the decimal point is ignored as per the investigation report) from the vendors through M/s. JM Jain LLP. Further, out of the total purchases made, the assessee had made purchases in cash of an amount of Rs. 1,18,35,400/- from vendors through M/s. JM Jain LLP which are neither accounted in the books of the assessee nor any explanation is furnished by the assessee.”

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to invoke the provisions of sec.69C of the Act, the AO is required to first establish that the assessee has actually incurred the expenditure under question. Mere assumption or inference based on third party document without any conclusive evidence of actual expenditure, cannot be the basis for addition u/s.69C of the Act. The leger account relied on by the AO is not maintained by the assessee nor is part of the assessee’s books of account, but it is a third party document not supported by any independent corroborative evidence such as invoices, payment records, stock entries or vendor confirmation. Further, the assessee stated that it is a settled law that the third party document even if seized during the search must be linked directly to the assessee through cogent corroborative evidences. The assessee also submitted that as per the general trade practice, commission if any, is typically borne by the seller and not the buyer. The AO has not rebutted this commercial norms brought on record any material or evidence indicating that the assessee has paid any commission. The assessee also stated that the AO has not given any opportunity to the assessee to cross-examine the third party, whose statement and documents formed the basis of the additions made, which in gross violation of principles of natural justice. In support of the same, the assessee relied on the decision of the Hon’ble Supreme Court in the case of Kishin Chand Chellaram v. CIT (1980) 19 CTR (SC) 360 : (1980) 125 ITR 713 (SC). Further, the assessee relied on the case decided by the Hon’ble Supreme Court in the case of CIT v. M/s.Odeon Builders Private Limited (Civil Appeal No.426 of 2019, dated 11.02.2019) wherein it has been held that the disallowance solely based on third party information without affording the assessee any opportunity to cross-examine the third party to rebut, cannot be sustained. The assessee also stated that the third party statement recorded during the search in itself does not constitute incriminating material unless it is corroborated with direct material evidence relatable to the assessee, by relying on the decision of the Hon’ble Delhi H igh Court in the case of Harjeev Agarwal (70 taxmnn.com 95). Without prejudice to the above arguments, the assessee also submitted that it is well settled principle that in cases where unaccounted transaction, whether on the sales or

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purchases are detected, the entire transaction amount cannot be treated as income and only the profit element embedded in such transactions can be made as addition. This view was affirmed by the Hon’ble Gujarat High Court in the case of CIT v. President Industries (2002) 258 ITR 654 (Guj.). In view of the above arguments, the assessee prayed for deleting the additions made by the AO. On perusal of the submissions and documents and the judicial precedents relied on by the assessee, the ld.CIT(A) was not convinced and confirmed the addition of unaccounted purchases to the tune of Rs.1,18,35,400/- and deleted the addition of 3% commission on the purchase made as statement of Satyanarayana Sharma does not indicate the commission paid was whether to the buyer or the seller and passed an order dated 02.01.2026.

“1. The Learned CIT(A) erred in confirming the addition made by the Assessing Officer solely on the basis of documents allegedly seized from the premises of a third party without establishing their authenticity or proving that the contents of such documents relate to the Appellant. The addition made on the basis of unverified third-party material is unsustainable in law. 2. The Learned CIT(A) failed to appreciate that no opportunity of cross- examination was provided to the Appellant in respect of the persons whose statements or documents were relied upon by the Assessing Officer. The reliance on such material without granting cross-examination is in clear violation of the principles of natural justice and therefore the addition is liable to be deleted. 3. The Learned CIT(A) erred in confirming the addition under section 69C of the Income-tax Act, 1961 without appreciating that the said provision can be invoked only when the Assessing Officer establishes, with cogent evidence, that the assessee has actually incurred expenditure not recorded in the books of account. In the present case, no such evidence has been brought on record and the Assessing Officer has failed to discharge the burden of proof; therefore, the addition sustained Is arbitrary and unsustainable in law. 4. The Learned CIT(A) failed to appreciate that the return of income filed by the Appellant was duly processed and accepted under section 143(1) of the Income- tax Act, 1961 and the books of account were duly audited without any adverse remark. In the absence of any defect in the audited books or any independent material establishing undisclosed transactions, the additions sustained are purely based on assumptions and are therefore unsustainable in law 5. The Learned CIT(A) erred in confirming the assessment order passed by the Learned Assessing Officer under section 143(3) read with section 144B of the Income-tax Act, 1961 without properly appreciating the facts and submissions placed on record by the Appellant.

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observed that, according to the Department, the purchases were allegedly made from different vendors through M/s.JM Jain LLP. Thus, even as per the Department's own case, the identity of the actual selling vendors has not been established. The addition is founded only on the ledger maintained by M/s.JM Jain LLP and the statement of its Marketing Manager, without any independent corroborative evidence linking the assessee with the alleged transactions. 9. Therefore, according to the ld.AR in the absence of supporting material such as invoices, delivery records, confirmations from the alleged vendors, proof of cash payments, or any other reliable evidence establishing a nexus between the assessee and the alleged purchases, the entries contained in a third party's ledger cannot, by themselves, constitute conclusive evidence to sustain the impugned addition. The aforesaid position is further fortified by the decision of the Hon'ble Supreme Court in Assistant Commissioner of Income- tax v. Maulik Jayantilal Patel [(2026) 188 taxmann.com 640 (SC)], affirming the judgment of the Hon'ble Gujarat High Court in Sandhya Maulik Patel v. Assistant Commissioner of Income-tax [(2025) 181 taxmann.com 123 (Guj.)]. The Hon'ble Supreme Court declined to interfere with the finding of that where no incriminating material relating to the assessee was found during the search conducted on a third party, and the Revenue failed to establish any live nexus between the seized material and the assessee, proceedings founded solely on such third-party material were unsustainable in law. 10. The ld.AR submitted that the Ld.CIT(A), while dealing with the addition towards the alleged commission, categorically held that the statement of Shri Satya Narayan Sharma does not specify whether such commission was charged from the buyer or the seller. On this finding, the Ld.CIT(A) rightly deleted the addition made towards the alleged commission. Having accepted that the Revenue's own evidence is silent as to the person upon whom the commission liability was fastened, the Ld.CIT(A) ought to have applied the very same standard while examining the principal addition sustained against the assessee.

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opportunity of cross-examination is one that the AO must discharge on his own accord, as a necessary incident of a fair assessment, and is not one that arises only upon a specific request being made by the assessee. In the present case, the AO neither disclosed the statement during the proceedings nor offered any opportunity of cross-examination of his own motion; the omission is, therefore, entirely that of the AO, and cannot be visited upon the assessee. Consequently, the assessee was deprived of any effective opportunity to examine the contents of the statement, rebut the allegations made therein, or seek cross-examination of the deponent before the AO. The entire addition has thus been founded upon material that was never disclosed to the assessee while the assessment proceedings were pending, and in respect of which the AO himself never extended any opportunity of cross-examination. 14. In these circumstances, the finding of the Ld.CIT(A) that the assessee had not sought cross-examination before the AO is wholly misconceived, and in any event addresses only one half of the omission. A request for cross- examination can arise only when the assessee is made aware, during the course of the assessment proceedings, that the AO proposes to rely upon the statement of a third party. Since the statement itself was never disclosed during the assessment proceedings, the assessee had no opportunity whatsoever to seek cross- examination; and equally, since the AO never himself offered such an opportunity despite relying upon the statement, the default lies squarely with the AO and not with the assessee. 15. Further, the ld.AR contended that this issue is no longer res integra. The Hon'ble ITAT, Raipur Bench, in Jeewan Kukreja vs. DCIT, Circle-1(1), Raipur (ITA No.492/RPR/2025, order dated 12.05.2026), arising out of the very same search conducted in the J.M. Jain Group on 28.05.2022, held that the failure to furnish the statements and other incriminating material relied upon by the AO to the assessee before completing the assessment amounts to a violation of the principles of natural justice and renders the assessment legally unsustainable. Notably, the Tribunal did not, as a condition for granting relief, require that the assessee in that case had made a specific request for cross-examination before

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the AO, it was sufficient that the material and the statement had never been placed before the assessee, and that the AO had not, of his own accord, afforded any opportunity to test the same. The Tribunal, while so holding relied upon the decisions of Tata Capital Financial Services Ltd. vs. ACIT [W.P. No.546/2022 (Bom.) dated 15.02.2022 reiterating that any material proposed to be used against an assessee must be supplied in advance, and an opportunity of cross-examination extended by the AO himself, so as to afford an effective opportunity to rebut the same. The present case stands on an even stronger footing. Here, the statement of Shri Satya Narayan Sharma was never disclosed during the assessment proceedings, nor did the AO at any stage offer, on his own motion, an opportunity to cross-examine the deponent. The assessee, therefore, could never have sought cross-examination of a witness whose statement had not been disclosed while the proceedings were pending, and the AO, for his part, never extended such an opportunity despite being duty-bound to do so. The reliance placed upon such undisclosed third-party material, without the AO himself having offered any opportunity of cross-examination, is in clear violation of the principles of natural justice and the impugned addition, therefore, deserves to be deleted. 16. The ld.AR also argued that the Ld.CIT(A) erred in confirming the addition u/s.69C of the Act without appreciating that the said provision can be invoked only when the AO establishes, with cogent evidence, that the assessee has actually incurred expenditure not recorded in the books of account. In the present case, no such evidence has been brought on record and the AO has failed to discharge the burden of proof; therefore, the addition sustained is arbitrary and unsustainable in law. 17. The ld.AR stated that a plain reading of the provision shows that it operates in two distinct limbs which cannot be conflated. The first limb the words "has incurred any expenditure" requires the Revenue to establish, as a threshold and jurisdictional fact through positive and independent evidence, that the assessee actually incurred the expenditure in question. It is only once this first limb is established that the second limb comes into play namely, that the

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assessee "offers no explanation about the source of such expenditure, or that the explanation offered is unsatisfactory at which point the deeming fiction operates and the burden shifts to the assessee. The deeming fiction contained in the section attaches only to the source of an expenditure once its incurrence is proved; it cannot be used by the Revenue to prove the very fact of incurrence, since that would render the exercise entirely circular the provision does not say "where the AO alleges that an assessee has incurred expenditure," it says "has incurred," which presupposes that incurrence is already an established fact before the section can operate at all. 18. In the present case, the assessee has incurred, recorded in his books, and discharged entirely through banking channels only the consideration reflected in his regular (pakka) purchase invoices figures that fully reconcile with his audited financial statements, his tax audit report u/s.44AB, and his bank statements with Karur Vysya Bank and HDFC Bank. The alleged additional cash (kachcha) component of Rs.1,18,35,400/- finds no place whatsoever in the assessee’s own books of account, in any of his bank accounts, or in any document, invoice, or record recovered from his possession or premises. The entirety of the case for this alleged cash component rests solely upon an entry appearing in a third party's M/s.JM Jain LLP's own unilateral ledger, recovered from that third party's premises during a search to which the assessee was never a party. This ledger, unsupported by any vendor confirmation, any matching bank withdrawal on the assessee’s part, or any other independent corroboration, cannot by itself establish, as a matter of positive evidence, that the assessee incurred this expenditure. The Revenue has therefore never crossed the first, jurisdictional limb of Section 69C, and consequently never became entitled to call upon the assessee to explain the source of an expenditure whose very incurrence by him remains unproved. 19. In support of the above arguments the ld.AR relied on the case law of DCIT, Circle-3(1), Visakhapatnam vs. Vikas Kumar Chhajer [ITA No.212/Viz/2025, order dated 25.07.2025], arising from the identical J.M.Jain search action. The Tribunal held that the statutory presumption u/s.132(4A)

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r.w.s 292C of the Act “can be drawn only against the person in whose case the search was authorised and from whose possession incriminating documents have been found,” and that this presumption “cannot be raised against the assessee as he was not subjected to a search operation” and no material was recovered from him. The Tribunal further found, on facts materially identical to the present case, that the AO, apart from relying upon the third party's excel sheets and ledger accounts, “had failed to place on record any documentary evidence which could irrefutably evidence that the cash deposits disclosed under the name of the assessee in the seized documents were the actual transactions carried out by the assessee.” The same infirmity is present here: beyond the M/s.JM Jain LLP ledger, there is no vendor confirmation, no bank- withdrawal pattern, and no defect in the assessee’s own audited books pointing to actual incurrence of the alleged cash expenditure. In the absence of the first, jurisdictional fact being established through evidence independent of the unverified third- party ledger, invocation of Section 69C is premature and the addition sustained thereunder is unsustainable in law. 20. The ld.AR also argued that the Ld.CIT(A) failed to appreciate that the return of income filed by the assessee was duly processed and accepted u/s.143(1) of the Act and the books of account were duly audited without any adverse remark. In the absence of any defect in the audited books or any independent material establishing undisclosed transactions, the additions sustained are purely based on assumptions and are therefore unsustainable in law. During the course of the subsequent scrutiny assessment proceedings, the assessee duly furnished the AO with a complete set of supporting documentation, including the audited financial statements for the relevant financial year, the tax audit report issued u/s.44AB of the Act, bank statements of all accounts held by the assessee with Karur Vysya Bank and HDFC Bank, the GSTR-9 annual return for the corresponding financial year, and comparative gross profit and net profit ratios for three consecutive assessment years. Not one of these documents was found by the AO to be defective, incomplete, or unreliable; nor did the AO, at any stage of the assessment proceedings, invoke

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the power available to him u/s.145(3) of the Act to reject the assessee’s books of account as unreliable or incorrect. It is a well-established principle that where the books of account of an assessee are regularly maintained, duly audited, and have not been rejected by the AO through the exercise of the power conferred u/s.145(3) of the Act, an addition of a magnitude that dwarfs the returned income in the present case, an addition that is approximately fifteen times greater than the income originally returned by the assessee cannot be sustained purely on the strength of an external and uncorroborated document belonging to a third party, without any corresponding defect having been identified in the assessee’s own regularly maintained records. 21. The ld.AR stated that this Tribunal in Jeewan Kukreja and Vikas Kumar Chhajer, specifically observed that the AO, save for relying upon the third-party server/ledger material, had "failed to place on record any documentary evidence" capable of independently establishing that the transactions recorded therein actually belonged to, and were carried out by, the assessee concerned. 22. In view of the foregoing submissions, the ld.AR prayed to delete the addition of Rs. 1,18,35,400/- confirmed by the Ld.CIT(A) u/s.69C of the Act, in its entirety, as being unsustainable in law and facts. 23. Per contra, the ld.DR for the revenue supported the orders of the authorities and submitted that the Assessing Officer has rightly made an addition based on the ledger account and sworn statement of the searched person M/s.JM Jain LLP. Hence, prayed for confirming the order of the ld.CIT(A). 24. We have heard the rival submissions perused the material available on record and gone through the orders of the authorities along with the paper book filed and judicial precedents relied on. The effective issue before us is whether the addition of Rs.1,18,35,400/- made u/s.69C of the Act towards alleged unaccounted cash purchases, on the basis of material found during the search conducted in the case of M/s. JM Jain LLP, can be sustained in the hands of the assessee. The undisputed position is that the assessee is an individual

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carrying on the business of trading in garments under the name and style of M/s.Simco Enterprises. The assessee filed his return of income declaring total income of Rs.7,87,630/-. During the course of scrutiny, the AO relied upon information emanating from the search conducted in the case of M/s. JM Jain LLP on 28.05.2022 and alleged that the assessee had made purchases aggregating to Rs.2,09,04,055/- through the said concern, out of which purchases of Rs.1,18,35,400/- were allegedly made in cash and were not recorded in the books of the assessee. On this basis, the AO invoked section 69C of the Act. 25. At the outset, it is necessary to appreciate the scope of section 69C. The statutory provision can come into operation only where it is established that the assessee has actually incurred expenditure and such expenditure is either not recorded in the books or its source remains unexplained. Thus, the existence or incurrence of expenditure by the assessee is a foundational fact. The deeming provision relating to the source of expenditure cannot itself be employed to establish that the expenditure was incurred by the assessee in the first place. 26. In the present case, the assessee has consistently denied having undertaken the alleged transactions through M/s. JM Jain LLP. The assessee specifically stated that no payment, whether by cheque, online transfer or cash, was made from any of his bank accounts to M/s. JM Jain LLP; that the alleged purchases were not reflected in GSTR-2B; and that no e-way bill evidencing movement of the alleged goods to the assessee's premises was generated. The assessee also furnished details of purchases, bank accounts, GST records, audited financial statements, ledger accounts and other supporting material during the assessment proceedings. 27. We find that the entire foundation of the impugned addition is the ledger maintained in the books of M/s.JM Jain LLP and the information gathered during the search conducted at the premises of the said third party. The assessee himself was not subjected to the search operation and no incriminating

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document relating to the alleged cash purchases was found from the assessee's business premises, residence, bank accounts or possession. The ld.AR has specifically submitted that there is no invoice, cash receipt, delivery challan, vendor confirmation or other independent documentary evidence recovered from or relatable to the assessee which establishes the alleged cash payment. We are conscious that material discovered during a search at the premises of a third party can constitute relevant information for initiating or conducting proceedings against another person. However, before such material can be made the sole basis for fastening tax liability upon such other person, the Revenue must establish a credible and live nexus between the seized material and the assessee and must also demonstrate that the entries actually represent transactions undertaken by the assessee. A unilateral entry appearing in the books or records of a third party cannot, in the absence of corroboration, automatically be treated as conclusive proof of an actual transaction in the hands of the assessee. 28. In the present case, the AO has relied upon the ledger of the assessee appearing in the books of M/s.JM Jain LLP and has observed that certain names of vendors appearing in the assessee's purchase details were also found in the said ledger. However, this circumstance, by itself, does not establish that the assessee made the alleged cash payments. The AO has not brought on record the corresponding purchase invoices, proof of delivery of goods, confirmation from the actual vendors, evidence of withdrawal of cash by the assessee, or any other independent material demonstrating that the assessee actually incurred the alleged expenditure of Rs.1,18,35,400/-. 29. We also find force in the submission of the ld.AR that even according to the observations of the ld.CIT(A), the alleged purchases were not necessarily purchases from M/s.JM Jain LLP but were stated to have been made from different vendors through M/s.JM Jain LLP. Thus, the identity of the actual vendors, the manner of payment and the alleged cash component require independent verification. The third-party ledger, without such corroboration, does not conclusively establish the actual incurrence of expenditure by the

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assessee. The Revenue has also relied upon the sworn statement of Shri Satya Narayan Sharma, Marketing Manager of M/s. JM Jain LLP, recorded during the search proceedings. However, the assessee has specifically contended that the said statement was not furnished to him during the assessment proceedings and no opportunity to cross-examine the deponent was provided. The ld.CIT(A), while dealing with the issue, rejected the assessee's contention essentially on the ground that no specific request for cross-examination had been made before the AO. 30. In our considered view, where a third-party statement is relied upon as a material basis for making an adverse addition, the assessee must be given an effective opportunity to meet and rebut such material. Such opportunity cannot be reduced to a mere formality of confronting the assessee with the conclusion drawn by the AO. Where the statement of a third party is relied upon against the assessee, the assessee must ordinarily have an effective opportunity to challenge the contents thereof, including by cross-examination where the statement is relied upon for establishing disputed facts. We are unable to accept the reasoning of the ld.CIT(A) that the assessee's failure to specifically request cross-examination before the AO, by itself, cures the defect. If the Revenue proposes to rely upon a third-party statement for fastening a substantial tax liability, the assessee must first be made aware of the material proposed to be used against him and afforded a meaningful opportunity to rebut the same. The ld.AR has specifically submitted that the statement of Shri Satya Narayan Sharma was not disclosed during the assessment proceedings and that the AO himself did not offer an opportunity to cross-examine the deponent. 31. We further find that the same evidentiary material was relied upon for making an addition towards alleged commission of Rs.6,27,122/-. Significantly, the ld.CIT(A) deleted the said commission addition after observing that the statement of Shri Satya Narayan Sharma did not establish whether the commission was payable by the buyer or the seller. Once the Revenue's own material was found insufficient to establish the person liable for the alleged commission, the same material requires equally careful scrutiny before it can

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be relied upon to establish that the assessee actually paid the alleged cash differential in the purchase transactions. We do not mean to suggest that deletion of the commission addition, by itself, automatically requires deletion of the purchase addition. However, it certainly demonstrates that the third-party material relied upon by the Revenue does not, without further corroboration, conclusively establish all the necessary ingredients of the alleged transaction. 32. We now turn to the statutory requirement u/s.69C of the Act. The assessee has maintained that the purchases recorded in its books were duly accounted for and the consideration reflected in the regular purchase invoices was paid through banking channels. The alleged additional cash component of Rs.1,18,35,400/- does not appear in the assessee's books, bank statements or GST records. The Revenue has not identified any corresponding cash withdrawal or other financial trail from the assessee which would demonstrate that such cash was actually paid by the assessee. It is important to distinguish between (i)evidence suggesting that a third party maintained records containing entries against the name of the assessee, and (ii) evidence establishing that the assessee actually incurred the expenditure represented by those entries. The former may give rise to an enquiry, but in the facts before us it cannot, without corroboration, be elevated into conclusive proof of the latter. 33. The assessee has also placed on record audited financial statements, tax audit report u/s.44AB of the Act, bank statements of its accounts maintained with Karur Vysya Bank and HDFC Bank, GSTR-9 and comparative financial results. The assessee has contended that no defect was identified in these records and that the AO did not invoke section 145(3) of the Act to reject the books of account. We are not suggesting that an addition u/s.69C of the Act can never be made where the books of account are not rejected u/s.145(3) of the Act. However, where the assessee's regular books and banking records are not shown to contain the alleged expenditure, the Revenue must nevertheless establish, through cogent evidence, that the assessee incurred the particular expenditure sought to be brought within the ambit of section 69C. In the present case, that essential link is missing.

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failure to provide an effective opportunity to rebut the third-party statement relied upon by the AO further weakens the evidentiary foundation of the impugned addition. Accordingly, we set aside the order of the ld.CIT(A) to this extent and direct the AO to delete the addition of Rs.1,18,35,400/- made u/s.69C of the Act. 37. In the result, the appeal of the assessee is allowed. Order pronounced in the court on 04th September, 2026 at Chennai.

Sd/- Sd/- (मनु कुमार गिरर) (एस.आर.रघुनाथा) (MANU KUMAR GIRI) (S. R. RAGHUNATHA) न्यागिकसदस्य/Judicial Member लेखासदस्य/Accountant Member

चेन्नई/Chennai, धदनांक/Dated, the 04th September, 2026. Devadas आदेशकीप्रधतधलधपअग्रेधर्त/Copy to: 1. अपीलाथी/Appellant 2. प्रत्यथी/Respondent 3.आयकरआयुक्त/CIT– Chennai/Coimbatore/Madurai/Salem 4. धवभागीयप्रधतधनधि/DR 5. गार्ाफाईल/GF DEVADAS Digitally signed by DEVADAS GOPALANACHARY GOPALANACHARY Date: 2026.09.07 14:39:58 +05'30'