LKS GOLD HOUSE PVT. LTD.,CHENNAI vs. DCIT, CC-3(4), CHENNAI

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ITA 3151/CHNY/2025Status: DisposedITAT Chennai18 May 2026AY 2020-2121 pages

In favour of the assessee: the assessee's appeal was allowed. From the AI summary of this appeal.

AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the 'J-Pack' software entries were unreliable due to inconsistencies like impossible purity percentages and miniscule quantities, and the assessee's denial of transactions was not adequately disproven. The Tribunal also noted the denial of cross-examination opportunity.

What were the facts?

The assessee, engaged in gold jewellery business, faced additions to its income based on unaccounted transactions found in the 'J-Pack' software seized during a search at M/s Mohanlal Jewellers Pvt Ltd (MJPL). The assessee denied these transactions and requested cross-examination of MJPL representatives.

What were the issues?

Whether additions based on third-party software data, which the assessee denies and challenges for reliability, can be sustained without corroborative evidence and cross-examination.

Which sections of the Income-tax Act were involved?

Section 132,Section 153C,Section 131,Section 132(4)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘A’ BENCH: CHENNAI

Before: SHRI ABY T. VARKEY & MS. PADMAVATHY. S

Hearing: 30.04.2026Pronounced: 18.05.2026

आदेश / O R D E R PER ABY T. VARKEY, JM:

These are appeals preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), (hereinafter referred to as ‘Ld.CIT(A), Chennai-20, all dated 17.10.2025 for the Assessment Years (hereinafter referred to as “AY”) 2017-18 to 2021-22.

2.

Since the issues involved are common, and the appeals for all the assessment years were heard together and both the parties argued them

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 2 :: together raising similar arguments on the issues, accordingly, for the sake of convenience and brevity, we dispose of the appeals by this consolidated order.

3.

Grievance raised by the assessee in all above appeals relate to the addition made by way of estimated income derived from unaccounted transactions with M/s Mohanlal Jewellers Pvt (in short ‘MJPL’).

4.

Both sides agree that facts and the issue involved are identical in all appeals. Hence, we take up the appeal for AY 2021-22, which decision will apply mutatis mutandis for other appeals. Before adverting to the grounds raised by the assessee, we first consider it fit to cull out the basic facts in the case by referring to the facts for AY 2021-22. The assessee is M/s LKS Gold House Pvt Ltd, company is engaged in the business of manufacturing and trading of gold jewellery. The assessee filed its return of income for AY 2021-22 on 29.01.2022 declaring a total income of Rs.16,05,09,682/-. A search u/s.132 of the Act was conducted on 10.11.2020 in the case of M/s Mohanlal Jewellers Chennai Pvt Ltd (in short ‘MJPL’) and other related persons. During the course of the search, certain electronic records including desk-top data and pen drives containing information from the “J-Pack” accounting software were seized which inter alia contained incriminating material having a bearing on the

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 3 :: total income of the assessee. The case of the assessee was centralized on 29.04.2021 and thereafter the case for AY.2017-18to 2020-21 were reopened u/s.153C of the Act by issuing notice on 15.02.2022 and for the relevant assessment year AY.2021-22 notice u/s.143 was issued on 15.02.2022.

5.

The AO observed that the statements of certain persons including Shri Rajendra Kothari of MJPL were recorded u/s.132(4) of the Act, wherein it was stated that “J-Pack” software inter alia contained details of transactions relating to purchase and sale of gold made outside the regular book of accounts. On examination of the data retrieved from the “J-Pack” software the AO of the searched person noticed a ledger account in the name of “AKB”, which was allegedly linked to the assessee. The ledger reflected the transactions of purchase of gold jewellery ornaments. Shri Rajendra Kothari, in his statement recorded u/s.131 of the Act dated 30.11.2020, had identified that the said ledger pertains to M/s LKS Jewelleries, Akbar (M/S LKS Gold House, Chennai PAN No. AAACL7611F). Further, Shri Suresh Khatri in response to question No.27 in statement recorded u/s.131 dated 04.12.2020 concurred with the statement given by Shri Rajendra Kothari. Having regard to the details of the opening and closing balances recorded under the ledger “AKB” in the “J-Pack” software of MJPL, the AO tabulated the data concerning the assessee which is

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 4 :: found at Page No.3 of the assessment order. The AO is noted to have provided the copy of the ledger extracted from “J-Pack” software and asked the assessee to explain the transactions maintained in the ledger extract from the “J-Pack” software along with documentary evidences. Pursuant to which the AO notes that assessee filed its reply along with ledgers of M/s MJPL in its books, copies of bank statement. In addition to the above, the assessee stated that the transaction pertaining to the assessee’s sister concerns have already been reflected in “AKB” ledger in “J-Pack”. The Group concerns of the assessee as noted by the AO as under: - 1. M/s LKS Gold House Pvt Ltd T Nagar- PAN No. AAACL7611F (Assessee) 2. M/s LKS Gold Heaven Anna Nagar – PAN No. AADFL0942P. 3. M/s LKS Gold Marked Tambarram – PAN No. AAAFL7775K The AO also noted that the assessee had produced bills/invoices in respect of purchases made by M/s LKS Gold House Pvt Ltd T Nagar – PAN No. AAAL7611F(Assessee), M/s LKS Gold Heaven Anna Nagar – PAN No. AADFL0942P and M/S LKS Gold Marked Tambarram – PAN No. AAAFL7775K from MJPL during the year under consideration. The assessee also asserted before the AO that it had done only those transactions with MJPL which were recorded in its books of account. Thus, the assessee is noted to have denied whatever additional transactions which were reflected in the “J-Pack” account maintained by M/s MJPL. However, the AO taking note of the unaccounted transactions as per “J-

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 5 :: Pack” ledger issued show-cause notice to the assessee on 09.03.2023 and 16.03.2023 to explain why the undisclosed income should not be brought to tax. In response, the AO notes that the assessee submitted its reply on 16 and 19 March, 2023 wherein assessee submitted that it did not have any documentary evidence with regard unaccounted gold purchase as per the “J-Pack” ledger. The assessee again reiterated before the AO that no unaccounted purchases were made during the year under consideration with the MJPL and requested the AO to accept the audited financial statements of the assessee for the relevant years. However, the AO didn’t agree and asked the assessee to prove that it didn’t carry out any unaccounted transactions with MJPL. The assessee reiterated its stand that it didn’t carry out any unaccounted transaction with MJPL and specifically requested for cross-examination of Shri Suresh Khatri of MJPL. The AO brushed aside the assessee’s request for cross-examination of MJPL through the makers of the statement by stating that adverse view against assessee is not based on their statement, and since assessee couldn’t prove that it didn’t carry out any unaccounted transaction with MJPL, took a view that assessee had carried out unaccounted transactions with M/s MJPL. Thereafter, the AO verified the transaction recorded in the “J-Pack” ledger pertaining to A.Y.2021-22 made with MJPL recorded in the books of the assessee till 10.11.2020 (date of search of MJPL). The AO is

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 6 :: noted to have analyzed the seized material and thereafter quantified the unaccounted transactions conducted by the assessee during the period from 01.04.2020 to 10.11.2020 at Rs.21,93,83,273/- (i.e. 45,026.45 grams) on which he applied gross rate of 9.81% and made addition of Rs.2,15,21,499/-.

6.

Aggrieved the assessee is noted to have preferred an appeal before the Ld.CIT(A) who has partly allowed the appeal of the assessee. In this context, it is noted that the assessee has furnished reconciliation statement of the transactions recorded in the books of assessee’s sister accounts vis-a-vis “J-Pack” ledger. Having noticed the same, the Ld.CIT(A) directed the assessee to furnish the relevant invoice in respect of purchases of 9243.40 grams (accounted in the books of account of its group entity M/s LKS Gold Heaven Pvt Ltd), but not considered by the AO while passing the assessment order, and the Ld.CIT(A) directed the AO to verify the same and allow credit for this accounted purchases (9243.40 grams) it this purchases are part of the entries made in “AKB” ledger. However, the Ld.CIT(A) did not accept the contention of the assessee regarding the sale of old beaten gold and bullion sales to MJPL by observing as under: - “7.3.7. With regard to the contention of the appellant regarding the sale of old beaten gold & bullion sales to MJPL, it is noted that such receipt of metal from the parties would be entered only on the 'Receipt' side of the 'A K B' ledger maintained in J-Pack, whereas, the sales made

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 7 :: by MJPL to the appellant are recorded on the "Issued' side of the said ledger. The AO has also adopted the total sales as per "Issued' side of the said ledger. Thus, the appellant has to explain only the 'Issued' side of the said ledger and the sale of old gold and gold bullion by the appellant to MJPL is irrelevant as the same is recorded only on the 'Receipt' side of the said ledger. Even if the said sale of bullion to MJPL is to be considered, it will only reduce the closing balance of the metal issued or received, on any given date. This will not alter/affect the total purchases of the appellant for the year under consideration. Hence, I am of the opinion that there is no impact of the sale of old beaten gold/bullion made by the appellant to MJPL while reconciling the 'Issued' side of the said ledger. Therefore, the unaccounted purchases made by the appellant from MJPL cannot be reduced by the quantity of old gold & bullion sold by the appellant to MJPL.” 7. Still not satisfied by the partial relief granted by the Ld CIT(A), the assessee is before us.

8.

Heard both parties and perused the material placed before us. We note that, a search action was conducted on the premises of the MJPL, in the course of it a pen drive was found which contained accounts maintained in “J-Pack” software. The facts available on record shows that MJPL had admitted that the accounts maintained in its software contained both their unaccounted and accounted transactions and also offered additional income across several years with reference to the details and ledgers found therefrom. It is further observed that “J-Pack” software also contained ledgers of the parties with whom MJPL inter alia had unaccounted transactions and one of the ledgers was titled “AKB”. It is seen that Shri Rejendra Kothari from whose possession this Pen-drive was found had explained the modus operandi for recording unaccounted transactions in these ledgers. It is also noted that Shri Suresh Khatri, key

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 8 :: person of MJPL has confirmed the version of Shri Kothari. We observe that when assessee was confronted with this J-Pack ledger, has denied to have carried out any unaccounted purchases from MJPL and filed copy of the ledger of M/s MJPL in its book, along with copies of bank statement and reconciliation of issued & receipts and entries shown in “J-Pack” ledgers. The assessee also furnished bills/invoices copies for accounted purchases made from M/s MJPL including that of three (3) sister concerns during the relevant years, and making charges paid to M/s MJPL and claimed that it had done only those transactions with MJPL which were recorded in its books of account and requested AO to accept the audited financial statement of the assessee. The AO at Para 8.4 of the assessment order acknowledged that assessee denied the transaction as shown in the “J- Pack” account which have not been recorded in its (assessee’s) books of accounts. However, the AO brushed aside the denial made by the assessee on the reason that some of the transactions which have been recorded in the books of account of the assessee are also found recorded in the J-Pack account in the same manner. Therefore, according to AO the correctness of the entries in the J-Pack account cannot be denied by the assessee. In other words, the transactions recorded by assessee in its book’s tallies with the J-Pack account in the same manner date wise. Hence, it is improbable that ledger maintained by MJPL in J-Pack software

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 9 :: would be wrong. Further, according to AO, assessee failed to reconcile the unmatched entries, nor prove that it didn’t carry out unaccounted transaction with MJPL. Therefore, the AO rejected the denial of assessee and thereafter quantified the unaccounted transactions conducted by the assessee during the period from 01.04.2020 to 10.11.2020 at Rs.21,93,83,273/- on which he applied gross profit rate of 9.81% and made addition of Rs.2,15,21,499/-. The assessee is noted to have filed appeal before Ld CIT(A), who gave partial relief to assessee subject to verification as stated therein the order, which impugned action is under challenge before us.

9.

We find that the impugned addition hinges on the entries of ledger extract of AKB in the books of MJPL maintained in J-Pack software and the statements of Shri Kothari and Suresh Khatri of MJPL. When confronted with the ledger extract of AKB in the books of MJPL, the assessee is noted to have denied the unaccounted transactions and asserted that it has purchased only 49,877.440 gms of gold from MJPL (AY 2021-22), [which includes the gold purchased by sister concerns] and filed relevant evidence like bills/invoices, books of account and payments made through banking channel. However, the AO didn’t accept the denial of unaccounted purchases because out of the gold issued weighing 94,903.89 gms as per J-Pack ledger, only gold weighing 49,877.440 gms

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 10 :: was accounted in the books of the assessee, hence according to AO, balance gold 45,026.45 gms needs to be treated as unaccounted purchases. Failure of the assessee to reconcile the unmatched entries, and failure to prove that it didn’t carry out unaccounted transaction with MJPL, were the reasons given to reject the assessee’s denial of carrying out any unaccounted transaction with MJPL. We do not agree with the reasoning given by the AO for fastening the liability/addition for the following reasons.

10.

We agree with the Ld.AR that, the assessee cannot be expected to prove a negative. Instead, the onus lay on the Revenue to substantiate the unmatched entries with some independent tangible material, if they were seeking to use the same against the assessee. According to us, the entries found in “J-Pack” application software which was seized from the premises of MJPL, could have been explained by MJPL alone. The case of the Revenue is that Shri Kothari of MJPL had claimed these entries to be unaccounted for, and thus it was rightly added in the hands of the assessee. On the other hand, the Ld.AR has submitted that, the statement given by Shri Kothari could have been in the context of the books of account of the MJPL and not the assessee. The Ld.AR submitted that, the Shri Kothari who was an employee of MJPL could not have possibly known as to whether the assessee had accounted or not, these

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 11 :: transactions in their books of account. He corroborated his submission by showing that majority of these entries were recorded in the books of account of the assessee. We also note that no opportunity to cross- examine Shri Kothari/Suresh Khatri was given to the assessee. We thus, find force in the Ld.AR’s plea that the statement of Shri Kothari cannot come to the aid of the AO to fasten a liability on the assessee without corroborative material which is absent in this case.

11.

It is settled that presumption set out in section 132(4), 132(4A) and 292C is only against the searched person which in this case is MJPL. Hence, contents of the material seized from the possession of the MJPL viz. entries in J-Pack application software seized from MJPL, can be presumed to be true only qua MJPL. Likewise, the statement of Shri Kothari recorded on the basis of material found in his possession can be used as valid evidence in the income tax proceedings of MJPL. Thus, said presumption cannot be extended to the assessee, unless the assessee was afforded an opportunity to cross-examine him. It is well settled in law that such 3rd party material or statement cannot be treated as conclusive proof against an assessee, unless there is other corroborative material linking the same to the assessee. Hence, we thus agree with the assessee that the contents of J-pack software, which was unilaterally maintained by

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 12 :: that party (MJPL) cannot be straight away used adversely against the assessee, without any corroborative material evidence. It is noted that assessee was able to substantially reconcile the entries out of the total entries found in the J-Pack application software. Insofar as the unmatched entries are concern, the assessee had contended that, these could have been mistakenly entered by Shri Rajendra Kothari in the software under the name of assessee. To support his contentions, he referred to certain contra entries, which suggest that when Shri Kothari identified the entries which were wrongly posted to the name of the assessee, he would pass a contra entry to transfer it to the correct head, which this Tribunal in identical facts and circumstances noted in Lalitha Jewelry Case [ITA Nos.675 to 680/Chny/2025 dt.12.06.2025]. We agree with the Ld AR that these unmatched entries could also be a case of incorrect accounting, mistaken identity or that the entries of some other customers were wrongly posted to these accounts.

12.

According to us, ordinarily any unmatched entries with the books of 3rd party raises a suspicion against the assessee, then AO to enquire and bring corroborative evidence against assessee, especially when assessee has denied such transaction. However, the AO despite assesee’s denial has not enquired about the veracity of such entries found in the ledger of MJPL and has refused to allow cross-examination of the makers

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 13 :: of statement on behalf of MJPL. Such an omission on the part of AO in the given facts of the case vitiates the adverse view taken against the assessee that it indulged in unaccounted transaction with MJPL and the addition made is fragile for violation of natural justice.

13.

Further, the Ld.AR submitted that the contents of the ledger extracted from the “J-Pack” software of MJPL is riddled with inaccuracies, so it is unreliable and hence it is unsafe to rely on it to make additions, based on unreliable ledger. For such a proposition, he invited our attention to the “J-Pack” ledger extracts of “AKB” in the books of MJPL (on sample basis, as per the J-Pack software for Financial Year 2016-17, relevant to AY 2017-18 & AY 2019-20) found kept in paper book at Page No.48 to 62 and also the “J-Pack” ledger qua the assessee which is kept at Page No.33 to 45, basis AO has quantified the purported unaccounted transaction allegedly conducted by the assessee on which he applied gross profit and made the addition while passing the quantum order u/s. 143(3)/153C order for the captioned assessment years. He pointed out that ‘bills’ accounted in the assessee's regular books and paid through banking channels are absent from the J-Pack ledger. According to him, if the J-Pack ledger were a complete or reliable mirror of the assessee's dealings with MJPL, every bill recorded in the assessee's regular books ought to find a corresponding entry in J-Pack. However, there are

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 14 :: instances of purchase bills not reflecting under the ‘Issue column’ of J- Pack ledger, thereby raising serious question of the reliability of the J- Pack ledger relied upon by the Assessing Officer, to draw adverse inference against assessee. Certain instances, brought to our notice as noted below: (a) Purchase Bill No. 16 dated 09.04.2016 (relevant to AY 2017- 18): The screenshot of the invoice is captured below:

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 15 :: The screenshot of the J-Pack ledger relevant for AY 2017-18 wherein the 1800 grams purchased from MJPL is not reflecting under ‘Issued Column’ during the relevant period:

(b) Purchase Bill No. 2323 dated 15.10.2018 (relevant to AY 2019-20): The screenshot of the invoice is captured below:

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 16 ::

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 17 :: The screenshot of the J-Pack ledger relevant for AY 2019-20 wherein the 636.050 grams purchased from MJPL is not reflecting under Issued Column during the relevant period: Receipt Issued Details Gross Touch Net Wt Amount Gross Touch Net Wt Amount

The Ld AR brought to our notice that above purchases from M/s Mohanlal Jewellers P Ltd were duly carried out and suffered indirect taxes and effected the payments through proper banking channels. The said purchases were not reflecting in J-Pack software in the relevant date thereby raises serious questions about its reliability. The Ld AR emphasized that when bills, supported by tax invoices and bank payments, do not appear in J-Pack shows that J-Pack is neither complete nor a parallel "true" ledger. According to him, it is, at best, a private working file unilaterally maintained by a third party (MJPL) with admitted omissions and errors. He submitted that when J-Pack has been shown to omit genuine, undisputed transactions cannot be relied upon for accepting or rejecting transactions claimed in the assessee's books. Hence, no

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 18 :: adverse inference can conclusively drawn against the assessee on the strength of such a document.

B. Impossible "Touch %" (purity) figures

The Ld AR, submitted that throughout the seized ledger, the "Touch %" (purity) is uniformly recorded as 100.00, a figure that is physically impossible in the jewellery trade. Even refined bullion does not exceed 99.5%–99.9% purity, and worked jewellery is 91.6% (22K), 75% (18K) or 58.5% (14K). A blanket recording of 100% across thousands of entries is a hallmark of a software-generated dummy field, not a record of real- world transactions.

C. Miniscule quantities

The Ld AR also brought to our notice that J-Pack ledger also contains transactions of miniscule weight which is illogical especially in view of the fact that the assessee is dealing in wholesale. The certain instances of such miniscule quantities are tabulated below: Assessment Date Net weight Touch Year 2017-18 19.12.2016 1.240 100 2017-18 10.01.2017 0.700 100 2018-19 26.04.2017 1.400 100 2018-19 03.08.2017 0.180 100 2018-19 31.08.2017 1.560 100 2019-20 23.09.2018 1.300 100 2019-20 14.11.2018 0.510 100 2019-20 08.12.2018 0.220 100

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 19 :: 2020-21 11.05.2019 0.300 100 2020-21 18.05.2019 0.330 100 2020-21 07.07.2019 0.040 100 2021-22 16.06.2020 0.280 100 2021-22 28.07.2020 0.290 100 2021-22 02.10.2020 0.840 100

14.

Hence, in the given facts of the present case, having regard to the infirmities and inconsistencies pointed out in the entries maintained by the 3rd party in their application software as discussed above, there is merit in the case of assessee that the unmatched entries may not relate or pertain to it.

15.

Moreover, once the assessee had denied unaccounted transactions with MJPL, thereby challenged the veracity of the contents of the entries in the J-Pack application software, then not only the AO ought to have examined Shri Kothari to test the veracity of his statement but he also ought to have confronted Shri Kothari of M/s MJPL to ascertain the true content and nature of the unmatched entries. Also, an opportunity should have been given to the assessee to cross-examine Shri Kothari/Suresh Khatri particularly when the assessee at all times had denied having any unaccounted transaction with MJPL and even MJPL had submitted their confirmation of accounts. In our considered view on the given facts, the impugned addition cannot be sustained since assessee has not accepted the contents of the J-Pack ledgers in its entirety qua assessee, and specifically denied having any unaccounted transaction with MJPL and

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 20 :: asserted that the entries maintained is unreliable qua assessee. In such a scenario, in order to fasten liability, there should be corroborative evidence, which is absent. Anyway, the entries maintained by the 3rd party in their application software alone cannot be held to be conclusive proof against the assessee, hence, it would be unsafe to fasten addition in the hands of assessee. Therefore, in the light of fore going discussion, we direct the deletion of addition for AY 2021-22.

16.

No change in facts or law could be pointed out qua other captioned AYs, hence on the aforesaid reasoning, the grounds of appeal on merits against addition are allowed on the basis of the same reasoning given for A.Y.2021-22. Thus, assessee succeeds and we direct the impugned additions be deleted for all the assessment years.

17.

In the result, appeals of the assessee are allowed.

Order pronounced on the 18th day of May, 2026, in Chennai. Sd/- Sd/- (प�ावती .एस) (एबी टी. वक�) (PADMAVATHY. S) (ABY T. VARKEY) लेखा सद�य/ACCOUNTANT MEMBER �या�यक सद�य/JUDICIAL MEMBER चे�नई/Chennai, �दनांक/Dated: 18th May, 2026. YS

ITA Nos.3148 to 3152/Chny/2025 (AYs 2017-18 to 2021-22) LKS Gold House Pvt. Ltd. :: 21 :: आदेश क� ��त�ल�प अ�े�षत/Copy to: 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT, Chennai / Madurai / Salem / Coimbatore. 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF

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