PERUMAL ALAGESAN,TIRUCHIRAPALLI vs. ITO, SALEM

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ITA 2243/CHNY/2026Status: DisposedITAT Chennai13 October 2026AY 2017-1810 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal allowed the assessee's appeal for statistical purposes and restored the matter to the AO. The Tribunal admitted additional evidence submitted by the assessee under Rule 29 of the ITAT Rules, 1963, noting its substantial bearing on the adjudication. The AO was directed to consider this evidence after providing a proper opportunity of being heard to the assessee. The assessee was directed to cooperate with the AO and substantiate each entry in the bank statement with narration, fulfilling the requirements of Section 69A. The Tribunal did not comment on the legal and factual grounds raised by the assessee. The appeal was allowed subject to the deposit of Rs. 25,000/- to the Tamil Nadu State Legal Services Authority.

What were the facts?

The assessee, Perumal Alagesan, is in appeal against the order of the Ld. CIT(A) for Assessment Year 2017-18. The assessee was identified as a non-filer by the Directorate of Income Tax (Systems) due to significant transactions in FY 2016-17, including TDS on rent, aggregate bank credits of Rs. 7,08,94,981/-, TDS on rent from another deductor, and cash deposits totaling Rs. 2,04,000/-. A notice under Section 148 was issued on 27.03.2024, and the assessee filed a return on 29.06.2024 declaring Rs. 6,76,390/-. The Assessing Officer (AO) made an addition of Rs. 7,10,98,981/- under Section 69A. The Ld. CIT(A) dismissed the assessee's appeal, leading to the present appeal before the ITAT.

What were the issues?

1. Whether the initiation of re-assessment proceedings is bad in law as the notice under Section 148 and order under Section 148A were issued by the jurisdictional AO instead of the National Faceless Assessment Centre, as argued by the assessee. 2. Whether the notice under Section 143(2) was issued in an invalid format, violating CBDT instructions, rendering the assessment order void-ab-initio, as contended by the assessee. 3. Whether there was due application of mind by the competent authority before approving under Section 151, a fact the assessee seeks verification of from assessment records. 4. Whether the Ld. CIT(A) was justified in not accepting the books of accounts filed during appellate proceedings, despite the assessee claiming all receipts and payments were duly recorded and the AO making mere allegations, as argued by the assessee. 5. Whether the AO was justified in assessing the entire bank credits of Rs. 7,10,98,981/- as income, when the assessee claims to have adequate sources and that not all deposits constitute income, as argued by the assessee. 6. Whether the AO should have applied the "Peak credit" concept instead of assessing entire bank credits, as an alternate plea by the assessee. 7. Whether the lower authorities were justified in invoking Section 115BBE for AY 2017-18, when the section came into effect from 01.04.2017, as argued by the assessee, relying on S.M.L.E Microfinance Limited vs. ACIT and Comal Ramachandran Gayathri vs. DCIT.

Which sections of the Income-tax Act were involved?

Section 148,Section 148A,Section 143(2),Section 151,Section 69A,Section 115BBE,Section 139,Section 282

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘C’ BENCH: CHENNAI

Before: HONOURABLE GEORGE GEORGE K. & SHRI GAGAN GOYAL

Hearing: 24.08.2026Pronounced: 13.10.2026

आयकर अपीलीय अधिकरण ’सी’ न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI माननीय श्री जॉजज जॉजज के., उपाध्यक्ष एवं श्री गगन गोयल लेखा सदस्य के समक्ष BEFORE HONOURABLE GEORGE GEORGE K., VICE PRESIDENT AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER आयकर अपील सं./ITA No. 2243/Chny/2026 ननिाारण वर्ा /Assessment Years: 2017-18 Perumal Alagesan, v. Income Tax Officer, No.237 Therkkukadu, Ward-1(6), Pudupet S.O (Salem), Salem. Attur, Tiruchirappalli, Tamil Nadu-636 141. [PAN: AJHPA0846J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee by : Mr. T. S. Lakshmi Venkataraman, C.A, Ld. AR प्रत्यर्थी की ओर से /Revenue by : Ms. Nayani Swapna, CIT, Ld. DR सुनवाईकीतारीख/Date of Hearing : 24.08.2026 घोषणाकीतारीख /Date of Pronouncement : 13.10.2026 आदेश / O R D E R PER GAGAN GOYAL, AM: This is an appeal preferred by the assessee against the order of Ld. Commissioner of Income Tax (A) / NFAC, (hereinafter referred as the ‘Ld. CIT(A)’), Delhi dated 31.03.2026, for the Assessment Year (hereinafter referred as the ‘AY’) 2017-18.

GROUDS OF APPEAL 1. On the facts and circumstances of the case the order of first appellate authority dated 31.03.2026 in dismissing the appeal of the appellant is bad in law and is not legally justified. 2. On the facts and circumstances of the case, the First Appellate Authority is not justified in sustaining the order of the Ld. Assessing officer, where the notice u/s. 148 dated 27.03.2024 and order u/s. 148A dated 27.03.2024 has been issued by ITO, Ward 1(6), Salem. It is submitted that the initiation of re-assessment proceedings is bad in law in as much as the same has to be done by National Faceless Assessment Centre of the Income Tax department and not by the jurisdictional assessing officer. In view of this, the assessment order passed is not legally valid and bad in law

ITA No.2243/Chny/2026 Perumal Alagesan 3. On the facts and circumstances of the case, the First Appellate Authority is not justified in sustaining the order of the Ld. Assessing officer, where The AO has made a legal error in issuance of notice u/s. 143(2) of the Act dated 19.07.2024, The notice u/s. 143(2) of the Act has been issued in an invalid format in violation to the CBDT instruction no. F. No. 225/157/2017/ITA-II dated 23-06-2017 and accordingly, the assessment order passed consequently is void-ab-initio and bad in law 4. On the facts and circumstances of the case, the First Appellate Authority is not justified in sustaining the order of the Ld. Assessing officer, where the fact whether there is due application of mind by the competent authority before giving approval u/s. 151 of the Act which fact has to be verified from the assessment records. 5. On the facts and circumstances of the case, the First Appellate Authority is not justified in sustaining the order of the Ld. Assessing officer, where the CIT(A) is not justified in not accepting the books of accounts filed in the course of appellate proceedings. Without any defects found in the books of accounts, the Assessing Officer making mere allegations is not justified and bad in law. All receipts and payments were duly recorded in the books of accounts. The Action of the Assessing Officer is against the principles of natural justice and bad in law. 6. On the facts and circumstances of the case, the First Appellate Authority is not justified in sustaining the order of the Ld. Assessing officer, where the AO is not justified in assessing the entire credits in the bank account of the assessee amounting to Rs. 7, 10, 98,981/- made by the assessee in his bank accounts during the financial year 2016-17 as income. The Assessee has got adequate sources to explain the cash deposits and other credits in the above bank accounts. Even otherwise the entire deposits made in bank accounts do not constitute income and the action of the AO in assessing the entire deposits is not legally justified. 7. On the facts and circumstances of the case, the First Appellate Authority is not justified in sustaining the order of the Ld. Assessing officer, where The AO instead of assessing the entire bank credits as income could have applied the "Peak credit" concept in framing the assessment which position has to be looked into with reference to the bank statement. This may be taken as an alternate plea. 8. On the facts and circumstances of the case, the lower authorities are not justified in invoking the provisions of section 115BBE of the Act for the A.Y. 2017-18 when the above section came into operation from 01.04.2017 and it is not applicable for the above A.Y. In this connection following case laws are relied upon, a) Decision of Hon'ble Madras High Court in the case of S.M.L.L.E Microfinance Limited Vs. ACIT in W.P NO. 2078 of 2020 and 1742 of 2020 by order dated 19.11.2024 b) Decision of ITAT Chennai Bench in the case of Comal Ramachandran Gayathri Vs. DCIT, Non-Corporate Circle 10(1), Chennai in ITA No: 1268/CHNY/2025. 9. In view of the above grounds and other submissions to be made at the time of appeal hearing, the order U/s. 250 passed by Commissioner of Income Tax (Appeals), NFAC may be cancelled and justice rendered.

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ITA No.2243/Chny/2026 Perumal Alagesan 2. The brief facts of the case are that the assessee was amongst the non-filer of return u/s. 139 of the Act. But, the case of the assessee has been identified and flagged by the Directorate of Income Tax (Systems), Central Board of Direct Taxes (CBDT). The information flagged is that, during the F.Y. 2016-17 relevant to A.Y. 2017-18, the assessee has entered the following transactions, but not filed the return of income for the assessment year 2017-18: -

Information Amount Amount (In Source Account No. Description Description Rs.) TDS statement – Rent Jaisuryas Deductor Amount paid or (Section TDS-1941). Retail Ventures CMBJ04248G credited 3,20,000/- Pvt Ltd. Total credits in the The Karur 1109280000001673, Aggregate gross bank account of Karur Vysya Bank Ltd 1109172000003401 & amount credited 7,08,94,981/- Vysya Bank 1109280000001310 TDS statement – Rent Hatsun Agro Deductor Tan Amount paid or 3,96,960/- (Section TDS 1941) Product Ltd CHEH00039E credited Cash deposits in one The Lakshmi 110328000000092 Aggregate gross or more accounts Vilas Bank Ltd amount received (other than a current from person in 2,04,000/- account and time cash deposit) of a person.

3.

In view of the above, a notice u/s. 148 of the Act was issued vide dated 27.03.2024, in response to the same, the assessee filed return of income on 29.06.2024 declaring total income at Rs. 6, 76, 390/-. Ultimately the case of the assessee was assessed after making addition of Rs. 7, 10, 98, 981/- u/s. 69A of the Act. The assessee being aggrieved with the same preferred an appeal before the Ld. CIT(A) who in turn dismissed the appeal of the assessee. The assessee being further aggrieved preferred the present appeal before us.

4.

We have gone through the order of the AO, the order of the Ld. CIT(A) and submissions of the assessee along with the grounds raised. It is observed that the assessee has rental income and has been involved in the business of money lending. Despite having taxable income, no return of income was voluntarily filed by the assessee. We have gone through the paper book filed by the assessee vide dated 18.08.2026 and analyzed the various documents in the form of written submissions before the lower authorities, reply filed with the AO along with

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ITA No.2243/Chny/2026 Perumal Alagesan enclosures i.e. Bank statements and rental agreement, written submission along with petition for additional evidence and production of additional evidence, financial statement for the A.Y. 2017-18, impugned bank statement of other person assessed in the name of the appellant, admission of additional evidence in terms of Rule 29 of the ITAT Rules, 1963, list and details of person to whom loans and advanced and interest income obtained during the A.Y. 2017-18, copies of loan certificate from various financiers and details of documents pledged for obtaining the loans from various financiers.

5.

It is observed through the bank accounts of the assessee that there is a massive cash introduction vis-à-vis contra entries also there. Moreover, we have gone through the balance sheet of the assessee vide page nos. 36 to 39 of the paper book and observed that during the year under consideration the assessee earned gross interest of Rs. 24, 20, 500/- and paid interest to the tune of Rs. 5, 77, 777/- to private parties and Rs. 14, 77, 018/- to banks. In addition to this, the assessee has also incurred bank commission and charges to the tune of Rs. 1, 72, 298/-. Meaning thereby the net income from money lending was only Rs. 1, 93, 407/-.

6.

It is further observed that the total of the balance sheet of the assessee was Rs. 3, 12, 45, 795/-. Out of this the assessee has assets in the immovable property, motor vehicle, cash in hand, bank balance etc., to the tune of Rs. 1,43,74,527/-, whereas the assessee has taken loans to the tune of Rs. 2, 59, 78, 957/-. Meaning thereby the assessee is incurring interest costs on Rs. 2, 59, 78, 957/-, whereas the amount of loan is being used for acquiring the assets mentioned (supra) in addition to parking the same with debtors to earn interest. In view of the above discussions, we are of the firm view that the assessee is not disclosing his income in a true and fair manner as the income from interest is being adjusted against the interest incurred for personal purposes as well as money lending business.

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ITA No.2243/Chny/2026 Perumal Alagesan 7. It is further observed vide para 5 of the appeal order is further observed, as reproduced below: - 5. The additional grounds of appeal as well as the petition for admission of additional evidence filed by the appellant were forwarded to the Assessing Officer for his comments and for submission of a remand report in accordance with Rule 46A of the Income-tax Rules. In response thereto, the Assessing Officer furnished remand report dated 18.03.2026, wherein it was stated that the appellant, an individual, had entered into transactions during the relevant previous year comprising rent receipts from Jaisuryas Retail Ventures Pvt. Ltd. and Hatsun Agro Product Limited, aggregate gross credits of Rs.7,08,94,981/- in the bank account maintained with Karur Vysya Bank and cash deposits of Rs.2.04,000/- in Lakshmi Vilas Bank, but had not originally filed return of income under section 139(1), it was further stated that, in response to notice under section 148, the appellant filed return declaring total income of Rs.6,76,390/- and the assessment was thereafter completed under section 147 read with section 148 on 13.02.2025 by making addition of Rs.7,10,98,981/- under section 69A. The AO has referred to the appellants submission dated 17.02.2026 along with copy of return acknowledgement and computation of income for A.Y. 2017-18, wherein it was claimed that he was engaged in money-lending business and had disclosed income at Rs. 24,20,500/-. However, the Assessing Officer, after considering the said submissions, reported that the appellant had failed to furnish satisfactory explanation in respect of the impugned bank credits and cash deposits and had not produced material evidence regarding rent receipts or any substantial documentary evidence in support of the alleged money-lending business, such as details of parties to whom loans were advanced, duration of loans or amount of interest charged; according to the Assessing Officer, in the absence of satisfactory justification, the credits and cash deposits in the accounts with Karur Vysya Bank and Lakshmi Vilas Bank remained unexplained and, therefore, the stand taken in the assessment order was reiterated in the remand report, The said remand report dated 18.03.2026 is reproduced as under:- "A remand report has been called for in the case of the assessee for the A.Y. 2017-18 on the submissions made by the assessee during the course of appellate proceedings. The assessee is an individual by status. As per the information available with the department, the assessee had entered into the following transactions during the F.Y. 2016-17 but did not file Return of Income for this year. Description Source Amount Rent (Section TDS-1941) JAISURYAS RETAIL VENTURES PVT Rs. 3,20,000/- LTD DEDUCTOR Aggregate gross amount THE KARUR VYSYA BANK LTD Rs. 7,08,94,981/- credited

Description Source Amount Rent (Section TDS-1941) HATSUN AGRO PRODUCT LIMITED Rs 3,96,960/- Amount paid or credited Cash THE LAKSHMI VILAS BANK LIMITED Rs 2,04,000/- deposits in one or more accounts (other than a current account and time deposit) 2. As the assessee did not file his Return of Income u/s 139(1) for the assessment year 2017-18, Notice under section 148 of the IT Act, 1961 was issued to him to file Return of Income. In response to notice u/s 148 of the Act, the assessee filed return of income, declaring total income of Rs. 6,76,390/-. During the course of assessment proceedings, various statutory notices had been issued to the assessee and in response the assessee submitted the details called for. Based on the details

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ITA No.2243/Chny/2026 Perumal Alagesan submitted by the assessee and material available on record, assessment u/s. 147 read with section 148 of the Income-tax Act dated 13/02/2025 was completed in this case in the following manner. Total income as per return filed u/s. 139(1) of the Act No ITR filed Total Income as per ITR filed in response to Notice u/s 148 Rs. 6,76,390/- Add: Unexplained Money u/s 69A Rs. 7,10,98,981/- Assessed Income Rs. 7,17,75,371/-

Aggrieved by the above order, the assessee filed appeal before Id. CIT(A). The Id. CIT (A), NFAC has called for remand report and the same is submitted as under: Grounds of Appeal and Comments of AO 3. A remand report has been called for in this case on the submissions made by the assessee during the course of appellate proceedings Accordingly, a hearing notice has been issued to the assessee to furnish the relevant details in response, the assessee has submitted the following details: i. Submission letter dated 17.02.2026 ii. Copy of ITR acknowledgment along with computation of income for the AY 2017-18 4. Vide the above submission letter dated 17.02.2026, the assessee has submitted that he was engaged in money lending business for the AY 2017-18. Also, on perusal of the income Computation Statement for the A.Y. 2017-18, it is seen that the income of the assessee from money lending business was Rs 24,20,500/- and the total taxable income was Rs 6,76,392/-. 5. As per the information available with the department, during the year under consideration the aggregate gross amount credited in the bank account of the assessee maintained with THE KARUR VYSYA BANK LTD was amounting to Rs.7,08,94,981/ Also, the total cash deposits in THE LAKSHMI VILAS BANK LIMITED's bank account was to the tune of Rs. 2,04, 000/- However, in response to hearing notice, the assessee has failed to provide any satisfactory response in connection with the deposits. The assessee did not furnish any material evidence in respect of rent receipts. Although, the assessee has stated that he was doing money lending business during the year, no substantial documentary evidence has been provided in relation to this activity such as details of unsecured loans, parties to whom loan was given, duration and amount of interest charged Without any material evidence and satisfactory justification the credits/cash deposits made into the accounts with THE KARUR VYSYA BANK and THE LAKSHMI VILAS BANK LIMITED remains unexplained. The same amount is liable to be added to the income of the assessee and taxed accordingly. 6. In the light of the above, it is seen that the assessee has nothing to say in this matter and hence the contention and claim of the assessee is not acceptable. The Remand Report is submitted."

8.

We have further observed the contents of the order of the Ld. CIT (A), wherein he stated “The remand report furnished by the Assessing Officer was confronted to the appellant for his comments; however, despite being afforded an opportunity, no rejoinder or further submission was filed by the appellant controverting the observations made by the Assessing Officer in the remand proceedings. Accordingly, the appeal is being adjudicated on the basis of the material available on record, including the assessment order, written submissions filed by the appellant, the additional evidence placed on record, and the remand report submitted by the Assessing Officer. The appellant has repeatedly stated that

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ITA No.2243/Chny/2026 Perumal Alagesan the source of the credits was money-lending business. However, beyond this assertion, no credible third-party or transaction-level evidence has been brought on record to demonstrate the existence, scale and genuineness of such activity. In a genuine money-lending business, particularly one involving substantial circulation of funds, one would ordinarily expect at least basic supporting material such as party- wise details of borrowers, dates on which loans were advanced, amounts advanced to each party, terms and duration of lending, rate of interest charged, details of recovery of principal and interest, confirmations from borrowers, promissory notes, loan agreements, security details, demand promissory notes, receipts ledger extracts of individual parties, and at least some material demonstrating continuity and organization of such business. No such primary evidence has been furnished either during assessment proceedings or even during remand proceedings. The remand report specifically records that no substantial documentary evidence was provided regarding the money-lending activity, including details of parties to whom loans were given, duration and interest charged. Significantly, this factual observation of the Assessing Officer has remained unrebutted, as no rejoinder to the remand report was filed by the appellant.”

9.

In view of the above remarks by the authorities below and our own observations discussed (supra), it is observed that the participation of the assessee before the authorities below is not appreciable and based on the submissions of the assessee before them, we do not find any infirmity in their respective orders, i.e. AO and Ld. CIT(A). But, as the assessee has filed the documents (originally required to be filed before the authorities below) before us along with a petition under Rule 29 of the ITAT Rules, 1963 (that is why the assessee needs to file an application in terms of Rule 29 of the Appellate Tribunal Rules, 1963). Here, it is pertinent to mention that none of the grounds taken by the assessee are eligible to be adjudicated except the application filed by the assessee in terms of Rule 29 of Appellate Tribunal Rules, 1963.

10.

Now, based on the above facts, this tribunal has to verify only the application filed by the assessee in terms of Rule 29 of the Appellate Tribunal Rules, 1963. For ready reference Rule 29 of the Appellate Tribunal Rules, 1963 is being reproduced below as under: Rule - 29, INCOME-TAX (Appellate Tribunal) Rules, 1963 Production of additional evidence before the Tribunal.

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ITA No.2243/Chny/2026 Perumal Alagesan 29. The parties to the appeal shall not be entitled to produce additional evidence either oral or documentary before the Tribunal, but if the Tribunal requires any document to be produced or any witness to be examined or any affidavit to be filed to enable it to pass orders or for any other substantial cause, or , if the INCOME-TAX authorities have decided the case without giving sufficient opportunity to the assessee to adduce evidence either on points specified by them or not specified by them, the Tribunal, for reasons to be recorded, may allow such document to be produced or witness to be examined or affidavit to be filed or may allow such evidence to be adduced. Now, in the light of the provisions of the Rule 29 of the Appellate Tribunal Rules, 1963, it can be concluded that there are no rights vested with the assessee to file even an application before the Bench. Rather, it is the prerogative of the bench to Order for production of any document or witness to be examined.

11.

In the case as discussed (supra), there was ample opportunities given to the assessee by the AO and the Ld. CIT (A), but in vain. The assessee never came forward with the relevant documents/explanations. This apart, Rule 18(4) of the INCOME-TAX (Appellate Tribunal) Rules, 1963, is also referable. That Rule provides that if any party desires to file additional evidence, then the same shall be filed by way of a separate paper book containing such particulars as are referred to in sub- rule (3) accompanied by an application stating the reasons for filing such additional evidence. If rule 18(4) is read with Rule 29 of the Appellate Tribunal Rules, 1963, there cannot be any difficulty in holding that in terms of Rule 29 of the Appellate Tribunal Rules, 1963, an additional evidence can also be produced by the assessee on an application, provided the Tribunal should satisfy as to the reasons before entertaining such additional evidence and the Tribunal should also afford sufficient opportunity to the Revenue to rebut those additional evidence.

12.

That apart, there was no specific objection raised by the Revenue at the time when the application was filed and the Revenue. In this context, we may also refer to the observation of the Tribunal that the Revenue did not contradict any of the averments made by the assessee in the petition seeking for production of additional evidence. In the given facts of the case, the Tribunal is considered to be the first appellate authority, as far as the issue involved in the present matter is concerned, i.e. Addition of Rs. 7,10,98,981/- on account of section 69A of the Act. It is true that before the documents filed by way of additional evidence were considered, the Page 8 of 10

ITA No.2243/Chny/2026 Perumal Alagesan Revenue had the opportunity to refute those documents. Nevertheless, in terms of Rule 29 of the Income-tax (Appellate Tribunal) Rules, 1963 a provision of opportunity is contemplated, and, in our opinion, such opportunity shall be given to the Assessing Officer. Rebuttal must be only by the Assessing Officer, who will be in a better position to verify the genuineness of those documents and accordingly, he may accept or may not accept the case of the assessee. In the event certain doubts are entertained based on the documents produced as additional evidence, it would be only proper for the Tribunal to remit the matter.

13.

Although we do not understand why the same has never been filed before the authorities below, for sake of better adjudication of tax liability, we allow to submit the same before us and accepted also. The additional evidence submitted by the assessee is duly accepted. We have given thoughtful consideration, and are of the considered view, that as the information as has been filed by the assessee before us as additional evidence would have substantial bearing on the adjudication of the issue in hand, therefore, the same merits to be admitted. Thus, in terms of our aforesaid observations admit the additional evidence placed on our record by the assessee under Rule 29 of the Income-Tax Appellate Tribunal Rules, 1963.

14.

In view of the above, without any comments on the grounds raised by the assessee (both legal and factual), the appeal of the assessee is allowed for statistical purposes only and the matter is restored back to the AO with a direction to consider the evidence adduced by the assessee before us after giving a proper opportunity of being heard as per the provisions of section 282 of the Act. Further, the assessee is also directed to cooperate in the proceedings before the AO and must come forward with relevant evidence (as submitted before us) without seeking any adjournment to substantiate each and every entry in the bank statement (which is under challenge and added back for the purposes of section 69A of the Act) with narration and has to fulfill the requirements of section 69A of the Act.

15.

In the result, the appeal of the assessee is allowed for statistical purposes only in above terms and directions. This order of the Bench is subject to deposit of Rs. 25,000/-(Rupees twenty five thousand only) to the Tamil Nadu State Legal Page 9 of 10

ITA No.2243/Chny/2026 Perumal Alagesan Services Authority, within 15 days of receiving this order and the receipt of the same is to be produced before the registry for verification. Order pronounced on the 13th day of October 2026, in Chennai.

Sd/- Sd/- (जॉजा जॉजा के.) (गगन गोयल) (GAGAN GOYAL) (GEORGE GEORGE K.) लेखा सदस्य/ACCOUNTANT MEMBER उपाध्यक्ष /VICE PRESIDENT चेन्नई/Chennai, ददनाांक/Dated: 13th October 2026. KB आदेश की प्रततललपप अग्रेपषत/Copy to: 1. अपीलार्थी/Appellant 2. प्रत्यर्थी/Respondent 3. आयकर आयुक्त/CIT, Chennai /Madurai/Coimbatore/Salem 4. पवभागीय प्रतततनधि/DR 5. गार्ड फाईल/GF Digitally signed K BABU by K BABU Date: 2026.10.16 09:08:21 +05'30'

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