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Facts
During a search operation under Section 132 on M/s. Sri Balaji Educational and Public Charitable Trust and its Managing Trustee, M.K. Rajagopalan (assessee), an additional income of Rs. 325 crores was disclosed across five assessment years. For AY 2017-18, which was not covered by a prior settlement, the Assessing Officer (AO) made protective additions for a shortfall in disclosed income (Rs. 54.61 crores) and unexplained cash deposits during demonetisation (Rs. 32.00 crores) under Section 69 read with Section 115BBE. The CIT(A) subsequently deleted these additions.
Held
The Tribunal upheld the CIT(A)'s decision, confirming that the principle of telescoping applies. It found that the assessee had already disclosed substantial income in preceding years, which was accepted by the Income Tax Settlement Commission (ITSC), and the AO failed to demonstrate that this income was utilized elsewhere. Consequently, the cash deposits during demonetisation were satisfactorily explained by previously taxed income, and the protective addition for shortfall in disclosure was unwarranted as the substantive addition was already made in the Trust's hands, thereby preventing double taxation.
Key Issues
Whether the CIT(A) was justified in deleting protective additions for shortfall in disclosed income and unexplained cash deposits, applying the telescoping principle against income already disclosed and settled for previous assessment years.
Sections Cited
132, 132(1), 132(4), 143(3), 245D, 245D(4), 250, 69, 115BBE, 153A
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Income Tax Appellate Tribunal, ‘A’ BENCH, CHENNAI
Before: SHRI ABY T VARKEY & SHRI S. R. RAGHUNATHA
आदेश /O R D E R PER S. R. RAGHUNATHA, AM :
This appeal is filed by the Revenue against the orders of the Commissioner of Income-tax (Appeals), Chennai-20 for the assessment year 2017-18 dated 06.02.2025. The Order u/s.250 of the Income Tax Act, 1961 (in short “the Act”) in the case of the assessee Shri M.K.Rajagopalan was rendered in DIN and Order No.ITBA/APL/S/250/2024-25/1073002821(1).
:-2-: ITA. No.:1443/Chny/2025 2. At the outset, we find that there is a delay of 20 days in filing the appeal filed by the revenue and the revenue explained the reasons for delay in filing the appeal. The revenue has filed affidavit stating the reasons for delay in filing the appeal is due to cases having time barring date for completion of pending assessment on 31.03.2025 were to be completed and as the case is related to old AY, the tracing out of the relevant miscellaneous records took some time and once the records were traced out, immediately the appeal paper were made ready and appeal is being filed on 20.05.2025. After considering the affidavit filed by the revenue and also hearing both the parties, we find that there is a reasonable cause for the revenue in not filing appeal on or before the due date prescribed under the law and thus, in the interests of justice, we condone delay in filing of appeal and admit the appeal filed by the revenue for adjudication.
The brief facts of the case are that M/s.Sri Balaji Educational and Public Charitable Trust, is a Registered Public Charitable Trust engaged in providing education through the educational institutions run under its aegis in the streams of Medicine, Engineering, Arts, Science and Allied Disciplines.
An action u/s.132 of the Act was undertaken in the case of the M/s.Sri Balaji Educational and Public Charitable Trust, on 24.06.2016 and the residential and office premises of the Chairman and Managing Trustee M.K.Rajagopalan (hereinafter referred to as ‘assessee’) was simultaneously covered in the said action. Based on the material gathered during the course of search and transactions portrayed in it, the assessee volunteered to disclose an additional total income of Rs.325.00 crores spread across five assessment years.
Both the assessee and that of the Trust, availed the benefit of settlement under Chapter XIX-A of the Act and orders u/s.245D(4) of the Act were passed in both the cases and substantial portion of the income disclosed as search were covered in the said settlement. However, the assessment years that were :-3-: ITA. No.:1443/Chny/2025 covered in the said settlement pertain to assessment years (A.Y.) 2013-14 to 2016-17.
The year under consideration relates to A.Y.2017-18 which was not covered by the proceedings under Chapter XIX-A of the Act. Based on the records and the deposition of the person searched, an order u/s.143(3) of the Act was passed for the A.Y.2017-18 on 28.12.2018 arriving at a taxable income of Rs.93,42,23,400/- as against the income reported of Rs.4,81,06,900/- in the Income tax return filed.
The addition to total income of Rs. 88,61,16,500/- comprises of two components being: a. The shortfall in declaration in the total quantum of income offered to tax spread across five assessment years from A.Y. 2013-14 to 2017-18 was lesser by Rs.54,61,00,000/- in comparison to the total quantum disclosed u/s.132(4) of the Act of Rs.325.00 crores and thus the differential sum of Rs.54.61 crores was brought to tax on protective basis. b. During the period of demonetisation, the assessee had deposited SBNs of Rs.32,00,16,500/- and while according to the AO, the source of such cash deposit was unexplained, the same were brought to tax u/s.69 r.w.s 115BBE of the Act.
These additions to total income of Rs.88.61 crores had resulted in additional tax demand of Rs.51,92,62,811/-.
The details of protective additions and the reasoning given by the Assessing Officer for the above additions are given below:
SUMMARY OF ADDITIONAL INCOME OFFERED YEAR WISE Sl.No. Year Amount in Crores 1 2012-13 21.77 2 2013-14 78.24 3 2014-15 98.41 4 2015-16 46.88 5 2016-17 79.70 (54.18+25.52) Total 325
:-4-: ITA. No.:1443/Chny/2025
It is submitted that the source for the seized cash of Rs 80,42,38,0007/-(excluding the amount of Rs 2,31,49 800 of tuition fee and an amount of Rs.22,61,700 belonged to Smt. Padma Srinivasan) is out of the above admitted income and can be telescoped against the disclosure it is also submitted that the amount advanced by me to certain parties in the year 2012-13 of Rs. 5.30 crores and Rs.11 crores in the year 2015-16 are from and out of the above receipts as stated in the earlier para SI.No.1. 4 During the course of assessment proceedings, on verification of the return of income filed for the assessment year in question, it is noticed that the assessee has offered donation in the form of voluntary contribution at Rs 25,09,88,510/- as against undisclosed amount of Rs. 79,70,00,000/- admitted during the course of search and post search proceedings. In this regard, vide this office show cause notice dated 29- 8-2018, the assessee was asked to furnish explanation for not adhering to the admission made during the course of search proceedings. In response, the assessee has furnished a comparative chart depicting the income admitted before the Investigation wing & income admitted which is enclosed herewith as annexure-
1. 1.
5. On careful consideration of the said chart, it is noticed that as against total donations receipt of Rs.55.01 crores, the assessee has admitted in the return of income for the year under consideration at Rs 25.09 crores resulting in not offering income of Rs 29.92 crores. Further, as against the admitted buffer undisclosed income of Rs.24.69 crores, no income was admitted by the assessee. In total, the assessee had failed to offer an agreed amount of Rs.54.61 crores for the assessment year under consideration.
18. In view of the above discussion and in view of the fact that there are seized documents evidencing the receipt of the donation amount as also the Managing trustee has admitted on behalf of the trust buffer undisclosed amount for omission & commission difference amount of Rs.54,61,00,000/- is treated as undisclosed income of the assessee and protectively added to total income & brought to tax accordingly.
Aggrieved by the said addition, the assessee preferred an appeal before the learned Commissioner of Income Tax, Appeal – 20, Chennai, (‘ld.CIT(A)’) and had stated that these additions are unwarranted.
In the statement of facts before the ld.CIT(A), it was expressed that the disclosure made at the time of search action u/s.132(1) of the Act on 24.06.2016 have been adhered to in the Returns of Income filed for A.Yrs. 2013-14 to 2016- 17 before the Settlement Commission and in the ITR filed in regular course for the A.Y.2017-18. Therefore, the addition on account of shortfall in disclosure was according to the assessee, is not correct.
:-5-: ITA. No.:1443/Chny/2025 12. With regard to the source of cash deposit made during F.Y.2016-17, a predominant portion of which was during the period of demonetisation, the assessee pleaded that the same were sourced out of the income already disclosed in the past assessment years before the Settlement Commission and since there is no process by which the same income can be coerced twice, by the principle of telescoping the second addition was according to the assessee, unprecedented.
The ld.CIT(A), while disposing the appeal in 25 dated 06.02.2025 had allowed all the grounds of appeal of the assessee and directed the AO to delete the entire addition to total income as the same according to the ld.CIT(A) lacked basis.
14. Addition on account of shortfall in disclosure of income:
14.1 In the disclosure made at the time of search u/s.132(4) of the Act, a total disclosure made by the assessee was Rs.325.00 crores. Initially, the income was to be offered in the hands of the assessee, and while the nature and source of such quantum could not be established to that of the assessee and was firmly pivoted to be the income of the Trust in which the assessee is a Managing Trustee, the taxation of income got shifted to the Trust in respect of this disclosure of Rs.325.00 crores.
14.2 This migration was firmed up in all the assessment years except for the year under consideration, as the order to be passed determining the income in the hands of the Trust u/s.245D of the Act by the Settlement Commission had attained finality. But for the year under consideration, since it was a regular assessment, the shortfall in disclosure made was assessed on a substantive basis in the hands of the Trust and on a protective basis in the hands of the assessee.
:-6-: ITA. No.:1443/Chny/2025 14.3 On the merits of the addition made in the hands of the Trust, which was also contested in both the appeals for A.Y.2017-18, the AO found that the component of income agreed to be offered for A.Y.2017-18 out of the total quantum of Rs.325.00 crores was Rs.79.70 crores and while the income disclosed in the hands of the Trust for A.Y.2017-18 was only Rs.25.09 crores, the shortfall of Rs.54.61 crores was added.
14.4 For the reasons stated earlier, since in the regular assessment for A.Y.2017-18, the person in whose hands the income was to be taxed was not firmed up at the time of assessment, the shortfall of Rs.54.61 crores was assessed in the hands of the Trust on a substantive basis and the same income was assessed on a protective basis in the hands of the assessee.
14.5 The ld.CIT(A) had the opportunity to adjudicate the appeal of the Trust and in the order passed u/s.250 of the Act in that case, a major portion of the addition was held to be taxable in its hands. When the substantive addition in the hands of the Trust was upheld, the ld.CIT(A) found that the protective addition fails and therefore the duplicated addition in the hands of the assessee was directed to be deleted.
6.1.10. With respect to the addition made by the AO on account of buffer income of Rs.24.26 crores offered by the appellant in the statements recorded in the course of search and the letter dated 26.08.2016, it is noted that this amount was offered by the appellant purely as additional buffer income to cover up any commissions/omissions. In the said letter, it was clearly admitted by the appellant that the incriminating material seized contain Rs.300.74 crores for AY 2013-14 to 2017-18 and the said buffer amount of Rs.24.26 crores was offered additionally which is over and above the amount of Rs.300.74 crores of unaccounted anonymous donations arising out of incriminating materials seized vide different annexures. On perusal of the statements recorded and letter dated 26.08.2016, it is clear that the total unaccounted anonymous donations received by the appellant arising out of the incriminating materials seized vide various annexures is only to the tune of Rs.300.74 crores (which includes Rs.245.71 crores for AY 2013-14 to 2016-17 & Rs.55.03 crores for AY 2017-18). The amount of Rs.245.71 crores of unaccounted anonymous donations for AY 2013-14 to 2016-17 was already settled by the Hon'ble IBS-II, New Delhi as discussed in the earlier paragraphs. Further, the unaccounted anonymous donations of Rs.55.03 crores which relates to AY 2017-18 is also partly offered by the appellant in the return of income filed for AY 2017-18 to the tune of Rs. 25,09,88,505/- and the balance amount of Rs.29,93,11,490/- has been held by me in the above paragraph as additional undisclosed income to be taxed in the hands
:-7-: ITA. No.:1443/Chny/2025 of the appellant for AY 2017-18. Thus, the entire amount of Rs.300.74 crores arising out of the incriminating material seized during the course of search has already been brought to tax and there is no material evidence available with the AO to bring to tax the additional sum of Rs.24.26 crores over and above the incriminating material seized in the course of search. It is also noted that the appellant had originally admitted the additional sum of Rs.24.26 crores in the statements recorded and letter filed on 26.08.2016 only to keep up the initial disclosure of Rs.325 crores. It is a well-settled law that no addition can be made merely based on the statement recorded u/s 132(4) of the Act without any corroborative materials. Hence, I am of the opinion that the addition made by the AO of Rs. 24.26 crores on account of additional buffer income admitted by the appellant is without any material evidence and the same cannot be sustained.
Addition on account of cash deposited 15.1 During F.Y. 2016-17 the assessee had deposited cash of Rs.32.00 crores and the same was deposited after the date of search. The search action revealed that the assessee was left with an cash balance of Rs.2.27 crores at the time of search and the same belongs to the Trust. In the absence of any explanation and a fresh source, the same remains unexplained and therefore the AO made this addition of Rs.32,00,16,500/-.
15.2 The ld.CIT(A) appreciated that consequent to the search, the assessee had disclosed an additional income of Rs.23.71 crores in the return of income filed for A.Y.2013-14 to 2015-16 and Rs.47,05,00,000/- in A.Y. 2016-17 to tax and had also paid the taxes thereon. The additional income disclosed in the preceding years was accepted to be the source of cash deposited during F.Y.2016-17 and extended the benefit of telescoping. The ld.CIT(A) accordingly directed the AO to delete the addition and the grounds raised by the assessee was allowed by holding as under :
6.2.8. From the above, it is noted that during the course of search in the case of M/s SBCEPT and the appellant, the incriminating materials were seized. The total unaccounted anonymous donations emanating from the material seized was quantified by the appellant himself as Rs.300.74 crores (Rs.245.71 crores for AY 2013-14 to 2016- 17 and Rs. 55.03 crores for AY 2017-18) in Annexure-5 (reproduced as above). Subsequently, the Hon'ble IBS-II, New Delhi, vide order dated 14.06.2023, has finally settled that the entire unaccounted anonymous donations emanating out of the seized material for the AY 2013-14 to 2016-17 of Rs.245.71 crores pertain to the Trust only and not the appellant. The remaining unaccounted anonymous donations of Rs.55.03 crores
:-8-: ITA. No.:1443/Chny/2025 pertaining to AY 2017-18 has also been considered by me in the hands of the Trust in the appeal order passed in the case of the Trust for AY 2017-18 in 20 dated 06.02.2025. Thus, the unaccounted anonymous donations of Rs.300.74 crores arising out of the entire incriminating seized material has been taxed in the hands of the Trust. Further, the Hon'ble IBS has also denied the claim of M/s SBECPT for getting telescoping of Rs.46.98 crores which was offered by the appellant in his return of income for AY 2016-17 as the unaccounted donations of the Trust. Meaning thereby, the unaccounted anonymous donations of Rs.46.98 crores related to AY 2016-17 arising out of the incriminating material seized during the course of search, is taxed in the hands of the Trust as per order u/s 245D(4) dated 14.06.2023 and the additional income admitted by the appellant in the return of income filed for AY 2016-17 is not telescoped against income of the Trust. On these facts and circumstances, it is seen that the appellant had already offered the additional income of Rs.47,05,00,000/- to tax in AY 2016-17 and paid the taxes thereon, which is to be allowed as source for cash in hand as on 31.03.2016 of Rs.43:47 crores and the same is to be allowed as source for the cash deposited during the FY 2016-17 by the appellant. In other words, it can be stated that the income admitted by the appellant in the AY 2016-17 is to be telescoped with the cash deposited in the subsequent year, i.e., AY 2017-18. Further, it is also noted that the appellant had not only offered Rs.47.05 crores in the AY 2016-17, he had also offered an additional income of Rs.23.71 crores pertaining to AY 2013-14 to 2015-16 in the return of income filed u/s 153A and also settlement application filed after the date of search without any incriminating material and not claimed any application of income other than the cash deposited in his bank accounts for AY 2017-18. Hence, the addition of Rs. 32,00,16,500/- u/s 69 on account of cash deposits in the bank account is deleted and the ground raised by the appellant is allowed.
The Department accepted that the protective assessment does not subsist when the appeal in respect of the substantive assessment is adjudicated. However, on the issue of accepting the source of cash deposited during the F.Y.2016-17 as out of the additional income disclosed in A.Y.2016- 17 was not acceptable and therefore objecting to the same, the following grounds of appeal were submitted:
“1. The order of the ld. Commissioner of I.T. (Appeals) is opposed to law and facts of the case.
Whether the learned CIT Appeal was justified in law and facts in deleting the addition of ₹32,00,17,500/- representing the cash deposited during demonetization period, by holding that the additional income of ₹47,05,00,000/- offered for AY 16-17 is to be allowed as source for cash deposit? 3. Whether the learned CIT Appeal was justified in law and facts in deleting the addition of ₹32,00,16,500/- representing cash deposited during demonetisation period, without appreciating that undisclosed cash up to the date of search (24/06/2016) was already seized and could not be available / in possession of assessee to deposit later during demonetisation period i.e., from 8/11/2016 in 30/12/2016?
:-9-: ITA. No.:1443/Chny/2025 4. For these grounds and any other ground, including amendment of grounds that may be raised during course of appeal, proceeding, the order of Ld.CIT Appeal may be set aside and the order of assessing officer may be restored”
The Ld. CIT (ld.DR) for the revenue vehemently opposed the relief granted by the ld.CIT(A) and supported the order of the AO by relying on the grounds appeal raised by the revenue.
The ld.AR of the assessee, argued that the relief extended by the ld.CIT(A) was in accordance with the principle laid down by the Hon’ble Supreme Court and therefore, the relief extended by the ld.CIT(A) is unquestionable.
The ld.AR further stated that the total disclosure made and accepted in the Final Order u/s.245D(4) of ITSC dt. 25.09.2018 was Rs.88,41,43,495/-. The particulars of the disclosure made and incorporated in Pg.No. 4 of the order u/s.245D(4) of the Act in the case of the assessee was tabulated and provided as under: M.K. Rajagopal 1. 2013-14 Additional Income offered as per Final 13,87,12,778 Order dt. 13.03.2017 u/s.245D(4) of 2. 2014-15 6,42,45,569 the Act by ITSC, Chennai. 3. 2015-16 12,98,65,498 4. 2016-17 55,13,19,650 Total 88,41,43,495
According to the AR, while the AO had not established that the cash generated as a result of such disclosure was utilised elsewhere and not deposited in the bank account of the assessee, the natural corollary is that the income offered to tax in the earlier years is available to explain the source of cash deposited in the subsequent year as the benefit of telescoping is automatic.
:-10-: ITA. No.:1443/Chny/2025 21. Telescoping means identifying an income and its application, so that ultimately tax is levied either only on the income or on its application. In other words, in case where an assessee has certain undisclosed income and also certain undisclosed investments, then it could be presumed that the undisclosed investments have been sourced out of the undisclosed income, so that only the income may be taxed or only the investment may be taxed and not both, in the hands of the assessee under the provisions of the Act.
The said theory which is judicially accepted in the case decided by the Hon’ble Supreme Court in Anantharam Veerasinghaiah & Co. v. CIT (1980) 123 ITR 457 (SC), is in effect, a theory of probability or inference which is applied in order to avoid taxing the same income twice – once on earning and then on utilizing / expending it. The theory of telescoping is applied keeping in view the well-established canon of taxation that the same income cannot be taxed twice.
During the course of the hearing, the ld.AR highlighted that the principle of telescoping of income disclosed by the assessee in the preceding years against the cash deposited during the F.Y.2016-17 has been endorsed by the Income Tax Settlement Commission in the order u/s.245D(4) of the Act dated 25.09.2018 and the relevant extract of the decision contained in para 3.1 of the order contained in page No.20 was reproduced to be:
“with regard to the alleged unaccounted receipts to the tune of Rs.181 crores, the same is discussed in the hands of the trust. As regards bifurcation of the cash seized of Rs.82.93 crores, we find that the cash balance in the books of the trust as well as the individual has been telescoped to the extent of the additional income offered. Hence, applicant’s plea is accepted in this regard”.
Therefore, it was pleaded by the ld.AR that the relief granted by the ld.CIT(A) is fair and correct and hence does not require the interference.
:-11-: ITA. No.:1443/Chny/2025 25. We have heard the rival contentions perused the material available on record and gone through the orders of the authorities along with the paper book and case laws relied on. The assessee is a managing trustee of M/s.Sri Balaji Educational and Public Charitable Trust. An action u/s.132 of the Act was undertaken in the case of the M/s.Sri Balaji Educational and Public Charitable Trust, on 24.06.2016 and the residential and office premises of the Chairman and Managing Trustee M.K.Rajagopalan (assessee) was simultaneously covered in the said action. As per the material gathered during the course of search and other records found, the assessee and the Trust agreed to disclose an additional total income of Rs.325.00 crores spread across five assessment years.
We note that the assessee and that of the Trust, availed the benefit of settlement under Chapter XIX-A of the Act and orders u/s.245D(4) of the Act were passed in both the cases and substantial portion of the income disclosed as search were covered in the said settlement. However, further we find that the assessment years that were covered in the said settlement pertain to assessment years (A.Y.) 2013-14 to 2016-17.
It is noted that the year under consideration relates to A.Y.2017-18 which was not covered by the proceedings under Chapter XIX-A of the Act. Therefore, in the scrutiny assessment the AO considering the records and the deposition of the person searched, an order u/s.143(3) of the Act was passed for the A.Y.2017-18 on 28.12.2018 added Rs. 88,61,16,500/- to the income declared of Rs.4,81,06,900/- in the return of income filed by the assessee. The first addition was made on protective basis on account of shortfall in declaration in the total quantum of income offered to tax spread across five assessment years from A.Y. 2013-14 to 2017-18 was lesser by Rs.54,61,00,000/- in comparison to the total quantum disclosed u/s.132(4) of the Act of Rs.325.00 crores.
:-12-: ITA. No.:1443/Chny/2025 28. The other addition is in respect of the SBNs deposited of Rs.32,00,16,500/-during the period of demonetisation, according to the AO, the source of such cash deposit was unexplained, the same were brought to tax u/s.69 r.w.s 115BBE of the Act.
On perusal of the order of the ld.CIT(A), we note that the ld.CIT(A) has appreciated that consequent to the search, the assessee had disclosed an additional income of Rs.23.71 crores in the return of income filed for A.Y.2013- 14 to 2015-16 and Rs.47.05 crores in A.Y. 2016-17 to tax and had also paid the taxes thereon. The source for cash deposited during F.Y.2016-17 is considered for the benefit of telescoping based on the income disclosed in the preceding years.
It is an undisputed fact that the assessee has disclosed and offered to tax additional income aggregating to Rs.88.41 crores for A.Ys. 2013-14 to 2016- 17 as per the final order of the Settlement Commission dated 25.09.2018. The Settlement Commission itself, in para 3.1 of its order, has recorded that the “cash balance in the books of the Trust as well as the individual has been telescoped to the extent of additional income offered”. Therefore, the contention of the department cannot be accepted.
Further, we note that the AO has not demonstrated that the undisclosed income additionally offered to tax have been utilised elsewhere and thus is not available to explain the source of cash deposited in the subsequent year. The search action in the case of the Trust and that of the assessee had unravelled all the investments made by the assessee and the Assessing Officer in the assessment order has not identified any investments outside the books of accounts, which were acquired out of such undisclosed income relating to the past years.
:-13-: ITA. No.:1443/Chny/2025 32. In the absence of such finding, the additional income offered to tax in the earlier years, will automatically be available to explain the source of cash deposited subsequently. Our view is also supported by the decision of the Hon’ble Supreme Court in the case of Anantharam Veerasighaiah (supra), and the benefit of telescoping has to be necessarily extended to the assessee.
It is a trite law that the same income cannot be taxed twice, once at the time of earning the same and again for the second time, when the same is applied. There is no concept of duplication of taxation of the same income. We are taking support of the Hon’ble Apex Court’s decision in the case of Anantharam Veerasinghaiah (supra) the Hon’ble Bombay High Court in the case of CIT v. Jawanmal Gemaji Gandhi [1985] 151 ITR 353 (Bom), wherein it was held that: “secret profits or undisclosed income of an Appellant earned in an earlier assessment year can constitute a fund, though concealed, from which the Appellant may draw subsequently. In the reported case there was acquired gold during the latter half of the assessment year and it could be that the undisclosed income earned in that very year constituted a fund from which the asset was acquired.”
The decision cited above squarely applies to the facts of the assessee and while the benefit of telescoping of undisclosed income relating to A.Yrs. 2013-14 to 2016-17 is available, the source of cash deposited during F.Y. 2016- 17 already stands explained. Therefore, we do not find any infirmity in the decision of the ld.CIT(A) in providing the telescoping for the cash deposit made during the impugned assessment year.
Further, the contention of the AR that the ITSC in its order u/s.245D(4) of the Act had approved the telescoping of additional income against the cash deposited during the year is also found to be true. Accordingly, we concur with the ld. CIT(A) that the cash deposits during the demonetisation period stand satisfactorily explained from previously taxed income, and no separate addition
:-14-: ITA. No.:1443/Chny/2025 u/s.69 of the Act is warranted and thus the appeal filed by the Revenue stands dismissed.
In the result, the appeal of the revenue is dismissed.
Order pronounced in the open court on 01st December, 2025 at Chennai.