THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

ITA 2577/CHNY/2025Status: DisposedITAT Chennai09 March 2026AY 2018-1946 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal is hearing appeals against the CIT(A)'s orders concerning various assessment years. The judgment details the proceedings leading up to the assessment order and the specific additions made, including those related to deemed dividends and foreign travel expenses.

What were the facts?

Following a search operation, the assessee's assessment was referred for special audit due to complex real estate transactions and unclear accounting. The special audit report led to additions to the assessee's total income, including deemed dividends and foreign travel expenses.

What were the issues?

The primary issues revolve around the validity of the assumption of jurisdiction under Section 153A, additions made based on special audit findings, and the treatment of deemed dividends and foreign travel expenses.

Which sections of the Income-tax Act were involved?

Section 132,Section 153A,Section 143(2),Section 142(1),Section 142(2A),Section 245C,Section 245D,Section 143(3),Section 17(2),Section 24(a),Section 2(22)(e),Section 56(2)(vii)(c),Section 132(4)

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Cases cited in this judgment(8)Show list

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ITA Nos: 2569, 2570, 2571, 2573 to 2577/Chny/2025

PER BENCH:

ITA No(s). 2571, 2573 - 2577/CHNY/2025 for the Assessment Year: 2012-13 to 2016-17 & 2018-19:

The assessee aggrieved by the order(s) of the Learned Commissioner of Income Tax (Appeals) – (in short “ld.CIT(A)”) for the Assessment Year(s) – (in short "A.Y.”) 2012-13 to 2016-17 & 2018-19 dated 24.07.2025, has filed the present batch of 6 appeals before this Tribunal.

2.

Since, the facts are the identical across all the appeals / for all the assessment years, except for the nature of the additions / disallowances varying in few of the Assessment Year(s) before this Tribunal in the present batch of 6 appeals, the appeal arising from the A.Y. 2012-13 is being taken up as the lead case with the consent of the both the Ld. AR as well as the Departmental Representatives.

3.

The brief fact of the present case is that the assessee, Shri Thanushkodi Narayanan, is the Managing Director of M/s.Annai Builders Real Estates Pvt Ltd. The assessee filed his original return of income for the A.Y. 2012-13 on 27.09.2012 in declaring a total income of Rs.24,87,430/-.

4.

A search and seizure operation was carried out in terms of Section 13

The order continues below.

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