CHUNGATH VARGHESE SUNNY,COIMBATORE vs. DCIT, CC-3(3), CHENNAI

ITA 1805/CHNY/2025Status: DisposedITAT Chennai28 October 2025AY 2021-22Bench: SHRI GEORGE GEORGE K (Vice President), SHRI S.R. RAGHUNATHA (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the penalty notices under Section 270A were vague and invalid, leading to the quashing of penalty orders. For the quantum additions, the Tribunal found merit in the assessee's argument to adopt Net Profit (NP) ratio instead of GP ratio, referencing a previous decision.

What were the facts?

During a search at MJPL, unaccounted purchases by the assessee from MJPL were discovered through seized data and statements. The Assessing Officer (AO) added estimated business income based on Gross Profit (GP) rates.

What were the issues?

Whether the AO erred in applying the Gross Profit ratio for estimating unaccounted income and whether the penalty notices under Section 270A were valid.

Which sections of the Income-tax Act were involved?

Section 153C,Section 143(3),Section 270A,Section 132,Section 132(4),Section 131,Section 270AA,Section 274

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI

Before: SHRI GEORGE GEORGE K & SHRI S.R. RAGHUNATHA

For Respondent: Shri. Shiva Srinivas, CIT
Hearing: 17.09.2025Pronounced: 28.10.2025

PER BENCH:

These ten appeals of the assessee are directed against the different orders of the Learned Commissioner of Income Tax (Appeals), Chennai – 20 [hereinafter referred to as the “ld.CIT(A)”] arising out of the orders passed by the Deputy Commissioner of Income Tax, Central Circle – 3(3), Chennai [hereinafter referred to as the “AO”], u/s.153C r.w.s 143(3)/143(3)/270A of

The order continues below.

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