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24,548 tribunal orders from the Chennai bench.
Counted from the judgments of this bench on BharatTax. The figure is how many of them cite each decision.
When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.
An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.
An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.
Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.
When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.
Appellate authorities can consider new claims and additional grounds if the relevant facts are already on record. The purpose of assessment is to correctly determine tax liability, allowing both parties to raise issues.
Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.
In Section 153A proceedings, the scope of assessment extends to abated proceedings, enabling an assessee to raise fresh legal claims that could have been made in regular assessment proceedings.
A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.
Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.
Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).
No disallowance under Section 14A can be made in the absence of actual exempt income, as Section 14A relates to the earning of actual income, not notional or anticipated income, thereby declining to apply the CBDT Circular dated 11th May 2014 in such cases.
For assessments under Section 153C, a notice is legally unsustainable if there is no incriminating material correlated to the specific assessment years for which reassessment is sought.
Taxing statutes are presumed to operate prospectively unless a clear contrary intention for retrospective application is evident. The law applicable for determining tax liability is that which stands on the first day of the assessment year, following the principle that law looks forward, not backward (lex prospicit non respicit).
In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.
Section 14A cannot be invoked to disallow expenditure if the assessee has not earned any exempt income in the relevant assessment year. The Explanation to Section 14A is prospective in nature.
Late fees under section 234E are not applicable for periods prior to June 1, 2015, as the amendment to section 200A inserting clause (c) was effective from that date.
For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.
Tax must be deducted at source from payments made to a non-resident under Section 195 only if such payment is chargeable to tax in India. The Assessing Officer bears the onus to establish that the payments made are indeed chargeable to tax under the Income Tax Act.
Most recent orders on record, from 2026.
The Tribunal held that the AO himself agreed that the assessee was involved in the money lending business, a fact also confirmed by the assessee in his statement under Section 131. The seized red notebooks contained details of money lending business transactions. The assessee admitted advancing cash loans to Shri Amit Kothari for the money lending business and voluntarily disclosed a sum of Rs. 5,50,00,000/- as undisclosed income. The AO prepared a table showing interest received by the assessee from FY 2018-19 to FY 2021-22 amounting to Rs. 1,92,70,203/-. The Tribunal noted that the assessee declared income under the head 'business' and the AO did not bring any new material to justify treating it as unexplained investment. Relying on the decision in O. Rm. Sp. Sv. Firm v. CIT, the Tribunal held that income falling under a specific head cannot be taxed under another head. The CIT(A) was justified in accepting the assessee's claim as the AO relied on materials except the assessee's claim about the head of income. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the grounds raised by the Revenue.
The Tribunal condoned the delay of 34 days in filing the Revenue's appeals for all assessment years, finding the reasons stated by the Revenue to be bonafide. For AY 2020-21 (lead case), the Tribunal held that the CIT(A)'s order restricting the disallowance to 5% was justified. The reasoning was that the CIT(A) had considered the additional income offered by the assessee and the specific disallowances sustained. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the Revenue's grounds. This finding was applied equally to AYs 2019-20, 2021-22, 2022-23, 2023-24, and 2024-25, as the facts and issues were similar. The Tribunal noted that for AY 2023-24, the CIT(A) sustained disallowances of Rs. 1,10,47,300 towards purchases and Rs. 3,15,63,806 towards subcontract expenditure, aggregating to Rs. 4,26,11,106, and deleted the balance additions, which was not disputed by either party. The ratio decidendi is that when the CIT(A) has provided a reasoned order restricting disallowances based on accepted principles and evidence, and such findings are not disputed by either party, the Tribunal should uphold the CIT(A)'s order.
The Tribunal condoned the delay of 34 days in filing the Revenue's appeals for all assessment years, finding the reasons stated by the Revenue to be bonafide. For AY 2020-21 (lead case), the Tribunal held that the CIT(A)'s order restricting the disallowance to 5% was justified. The reasoning was that the CIT(A) had considered the additional income offered by the assessee and the specific disallowances sustained. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the Revenue's grounds. This finding was applied equally to AYs 2019-20, 2021-22, 2022-23, 2023-24, and 2024-25, as the facts and issues were similar. The Tribunal noted that for AY 2023-24, the CIT(A) sustained disallowances of Rs. 1,10,47,300 towards purchases and Rs. 3,15,63,806 towards subcontract expenditure, aggregating to Rs. 4,26,11,106, and deleted the balance additions, which was not disputed by either party. The ratio decidendi is that when the CIT(A) has provided a reasoned order restricting disallowances based on accepted principles and evidence, and such findings are not disputed by either party, the Tribunal should uphold the CIT(A)'s order.
The Tribunal condoned the delay of 34 days in filing the Revenue's appeals for all assessment years, finding the reasons stated by the Revenue to be bonafide. For AY 2020-21 (lead case), the Tribunal held that the CIT(A)'s order restricting the disallowance to 5% was justified. The reasoning was that the CIT(A) had considered the additional income offered by the assessee and the specific disallowances sustained. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the Revenue's grounds. This finding was applied equally to AYs 2019-20, 2021-22, 2022-23, 2023-24, and 2024-25, as the facts and issues were similar. The Tribunal noted that for AY 2023-24, the CIT(A) sustained disallowances of Rs. 1,10,47,300 towards purchases and Rs. 3,15,63,806 towards subcontract expenditure, aggregating to Rs. 4,26,11,106, and deleted the balance additions, which was not disputed by either party. The ratio decidendi is that when the CIT(A) has provided a reasoned order restricting disallowances based on accepted principles and evidence, and such findings are not disputed by either party, the Tribunal should uphold the CIT(A)'s order.
The Tribunal held that the presumption under Section 132(4A) and Section 292C of the Act is applicable only to the person searched and cannot be applied to a third party. The seized notebook was not prepared by the assessee but by someone at the premises of the Saravana Group, an external party. This fact is critical as it undermines the presumption under Section 132(4A), which applies to documents found to 'belong to' the person searched. The presumption under Section 132(4A) is limited and rebuttable, and cannot, by itself, revoke a preposition against a third party for chargeability of tax. The Tribunal confirmed the order of the Ld. CIT(A) and the legal position in favour of the assessee, finding the Revenue's reliance on the jurisdictional High Court decision inapplicable. The grounds raised by the Revenue were dismissed.
The Tribunal condoned the delay of 34 days in filing the Revenue's appeals for all assessment years, finding the reasons stated by the Revenue to be bonafide. For AY 2020-21 (lead case), the Tribunal held that the CIT(A)'s order restricting the disallowance to 5% was justified. The reasoning was that the CIT(A) had considered the additional income offered by the assessee and the specific disallowances sustained. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the Revenue's grounds. This finding was applied equally to AYs 2019-20, 2021-22, 2022-23, 2023-24, and 2024-25, as the facts and issues were similar. The Tribunal noted that for AY 2023-24, the CIT(A) sustained disallowances of Rs. 1,10,47,300 towards purchases and Rs. 3,15,63,806 towards subcontract expenditure, aggregating to Rs. 4,26,11,106, and deleted the balance additions, which was not disputed by either party. The ratio decidendi is that when the CIT(A) has provided a reasoned order restricting disallowances based on accepted principles and evidence, and such findings are not disputed by either party, the Tribunal should uphold the CIT(A)'s order.
The Tribunal condoned the delay of 34 days in filing the Revenue's appeals for all assessment years, finding the reasons stated by the Revenue to be bonafide. For AY 2020-21 (lead case), the Tribunal held that the CIT(A)'s order restricting the disallowance to 5% was justified. The reasoning was that the CIT(A) had considered the additional income offered by the assessee and the specific disallowances sustained. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the Revenue's grounds. This finding was applied equally to AYs 2019-20, 2021-22, 2022-23, 2023-24, and 2024-25, as the facts and issues were similar. The Tribunal noted that for AY 2023-24, the CIT(A) sustained disallowances of Rs. 1,10,47,300 towards purchases and Rs. 3,15,63,806 towards subcontract expenditure, aggregating to Rs. 4,26,11,106, and deleted the balance additions, which was not disputed by either party. The ratio decidendi is that when the CIT(A) has provided a reasoned order restricting disallowances based on accepted principles and evidence, and such findings are not disputed by either party, the Tribunal should uphold the CIT(A)'s order.
The Tribunal condoned the delay of 34 days in filing the Revenue's appeals for all assessment years, finding the reasons stated by the Revenue to be bonafide. For AY 2020-21 (lead case), the Tribunal held that the CIT(A)'s order restricting the disallowance to 5% was justified. The reasoning was that the CIT(A) had considered the additional income offered by the assessee and the specific disallowances sustained. The Tribunal found no infirmity in the CIT(A)'s order and dismissed the Revenue's grounds. This finding was applied equally to AYs 2019-20, 2021-22, 2022-23, 2023-24, and 2024-25, as the facts and issues were similar. The Tribunal noted that for AY 2023-24, the CIT(A) sustained disallowances of Rs. 1,10,47,300 towards purchases and Rs. 3,15,63,806 towards subcontract expenditure, aggregating to Rs. 4,26,11,106, and deleted the balance additions, which was not disputed by either party. The ratio decidendi is that when the CIT(A) has provided a reasoned order restricting disallowances based on accepted principles and evidence, and such findings are not disputed by either party, the Tribunal should uphold the CIT(A)'s order.
The Tribunal held that the appeals had become infructuous due to the approval of the resolution plan by the NCLT on February 3, 2023, and the subsequent reduction of the tax demand for all years to nil on April 10, 2024. Consequently, the assessments for AYs 2013-14 to 2016-17 were considered concluded under the plan, and no effective relief could be granted to the assessee. The Tribunal reasoned that any adjudication on the merits of the grounds raised would be purely academic. The Tribunal clarified that it had not expressed any opinion on the merits of the additions and that this order would not preclude the assessee from pursuing reliefs before the CBDT or other appropriate authorities as referred by the NCLT. The Tribunal also noted that the assessee's grievance regarding tax determined had ceased to exist, and the claims for refunds and creation of losses fell outside the scope of the appeals and the Tribunal's jurisdiction. The appeals were dismissed as infructuous.
The Tribunal held that the appeals had become infructuous due to the approval of the resolution plan by the NCLT on February 3, 2023, and the subsequent reduction of the tax demand for all years to nil on April 10, 2024. Consequently, the assessments for AYs 2013-14 to 2016-17 were considered concluded under the plan, and no effective relief could be granted to the assessee. The Tribunal reasoned that any adjudication on the merits of the grounds raised would be purely academic. The Tribunal clarified that it had not expressed any opinion on the merits of the additions and that this order would not preclude the assessee from pursuing reliefs before the CBDT or other appropriate authorities as referred by the NCLT. The Tribunal also noted that the assessee's grievance regarding tax determined had ceased to exist, and the claims for refunds and creation of losses fell outside the scope of the appeals and the Tribunal's jurisdiction. The appeals were dismissed as infructuous.
The Tribunal held that while the Commissioner of Income Tax (Appeals) was correct in observing that he could not legislate or extend due dates beyond the Act's provisions, the core issue was not about extending the due date but about whether the assessee could be considered in default for the period during which the CBDT itself acknowledged difficulties in filing. The Tribunal noted that the TDS and TCS statements for the fourth quarter of FY 2020-21 are of the same character, relate to the same period, are filed on the same portal, and governed by Section 234E. The hardship caused by lockdowns, which led to CBDT extensions for TDS statements, applied equally to TCS statements. The extension granted for TDS statements until July 15, 2021, was a clear recognition by the CBDT that filing such statements could not reasonably be insisted upon during that period. Therefore, levying a fee on the assessee for the same period, merely because it was a TCS statement, would result in unequal treatment. The Tribunal ruled that, on the peculiar facts, the period from May 16, 2021, to July 15, 2021, should be excluded in computing the fee under Section 234E. The AO was directed to delete the fee of Rs. 12,200 for this period and recompute the demand. The fee for the undisputed period of delay was to stand.
The Tribunal held that the activities of the trust fall within the expression "relief of the poor" as defined in Section 2(15) of the Act. The trust's activities, such as motivating poor and marginalized women to form SHGs, nurturing them, educating them on financial literacy, and facilitating access to bank credit, are directed at improving their economic condition. Therefore, the proviso to Section 2(15), including the 20% receipt limit, is not attracted. The Tribunal further held that even if the activities were viewed under the residuary limb of general public utility, they are not in the nature of trade, commerce, or business. Relying on the Supreme Court decision in ACIT (Exemptions) v. Ahmedabad Urban Development Authority, the Tribunal noted that charging amounts at cost or with a nominal mark-up does not constitute business. The trust's deficit in FY 2021-22 and marginal surpluses in subsequent years, along with the fact that it does not charge beneficiaries, support this finding. The Tribunal found no material to show that service charges were significantly in excess of costs or that income was applied for trustees' benefit. The CIT(E) was not justified in rejecting the application. The order of the CIT(E) was set aside, and the CIT(E) was directed to grant registration under Section 12AB from AY 2027-28. The Revenue was granted liberty to examine income application in assessment proceedings.
The Tribunal held that the appeals had become infructuous due to the approval of the resolution plan by the NCLT on February 3, 2023, and the subsequent reduction of the tax demand for all years to nil on April 10, 2024. Consequently, the assessments for AYs 2013-14 to 2016-17 were considered concluded under the plan, and no effective relief could be granted to the assessee. The Tribunal reasoned that any adjudication on the merits of the grounds raised would be purely academic. The Tribunal clarified that it had not expressed any opinion on the merits of the additions and that this order would not preclude the assessee from pursuing reliefs before the CBDT or other appropriate authorities as referred by the NCLT. The Tribunal also noted that the assessee's grievance regarding tax determined had ceased to exist, and the claims for refunds and creation of losses fell outside the scope of the appeals and the Tribunal's jurisdiction. The appeals were dismissed as infructuous.
The Tribunal noted that there was no representation from the assessee before the Ld. CIT(A) and no compliance was made despite four notices issued. However, considering the undertaking given by the assessee's authorized representative to furnish all details and represent the case before the Ld. CIT(A) without fail, the Tribunal deemed it proper to remand the matter back to the Ld. CIT(A) for fresh consideration. The assessee was granted liberty to file evidence in support of its claims. Consequently, the order of the Ld. CIT(A) was set aside, and the grounds raised by the assessee were allowed for statistical purposes. The principle is that where an assessee undertakes to provide all necessary documentation and representation, and the revenue has no objection, a procedural lapse leading to an ex parte order can be rectified by remanding the matter for a fresh adjudication on merits.
The Tribunal, considering the concession made by the Revenue regarding the discrepancy in dates and in the interest of justice, decided to remand the matter back to the Ld. CIT(E). The Ld. CIT(E) is directed to re-examine the issue of delay in filing the application for registration under Section 12AB of the Act. The assessee is permitted to submit evidence supporting the reasons for the delay and the merits of the application. The Ld. CIT(E) is to pass a fresh order in accordance with law, considering the reasons for delay and, if delay is condoned, decide the grant of registration on merits. The ratio decidendi is that procedural irregularities and factual discrepancies, especially when conceded by the revenue, warrant a remand for fresh consideration to ensure justice and proper adjudication on merits.
The Tribunal condoned the delay of 99 days in filing the appeal, finding the reasons provided by the assessee to be bona fide. Regarding the substantive issue, the Tribunal noted that the assessee was not afforded an opportunity to present its case before the Ld. CIT(A) during the first appellate proceedings. The assessee undertook to represent its case before the Ld. CIT(A) without fail. In the interest of justice, the Tribunal decided to remand the matter to the file of the Ld. CIT(A) for fresh consideration. The assessee was granted liberty to file evidence in support of its claim. The Tribunal directed that if the assessee fails to represent its case, the Ld. CIT(A) may pass an order based on available material. The order of the Ld. CIT(A) was set aside, and the grounds raised by the assessee were allowed for statistical purposes. No specific issue was left undecided.
The Tribunal held that the assessee failed to provide sufficient cause for the inordinate delay of 1065 days in filing the appeal before the CIT(A). The Tribunal noted that the assessee's sole reason, the Covid-19 Pandemic, was not applicable to the assessment year and the period of delay. The Tribunal emphasized that while a liberal and justice-oriented approach is sometimes adopted, it should not be used to disregard the substantial law of limitation. Citing the Supreme Court's decision in Guruswamy & ors. Vs. A. Krishnaiah, the Tribunal stated that reasons must satisfy the authorities that the assessee was prevented by a sufficient cause. In the absence of a satisfactory explanation, condoning the delay would amount to violating statutory provisions. The Tribunal found no infirmity in the CIT(A)'s rejection of the condonation petition. Consequently, the grounds raised by the assessee challenging the CIT(A)'s order on this point were dismissed, rendering the grounds on merits infructuous.
The Tribunal held that the appeals had become infructuous due to the approval of the resolution plan by the NCLT on February 3, 2023, and the subsequent reduction of the tax demand for all years to nil on April 10, 2024. Consequently, the assessments for AYs 2013-14 to 2016-17 were considered concluded under the plan, and no effective relief could be granted to the assessee. The Tribunal reasoned that any adjudication on the merits of the grounds raised would be purely academic. The Tribunal clarified that it had not expressed any opinion on the merits of the additions and that this order would not preclude the assessee from pursuing reliefs before the CBDT or other appropriate authorities as referred by the NCLT. The Tribunal also noted that the assessee's grievance regarding tax determined had ceased to exist, and the claims for refunds and creation of losses fell outside the scope of the appeals and the Tribunal's jurisdiction. The appeals were dismissed as infructuous.
The Tribunal held that the matter required fresh examination at the level of the Assessing Officer (AO). The Tribunal admitted the MOU dated 01.01.2022 as additional evidence. It observed that the AO and CIT(A) had not independently examined the nature of the transaction and had restricted TDS credit solely based on income offered in the return. The Tribunal clarified that if the assessee's plea under Section 47(v) is accepted, the tax deducted would be excess tax, entitling the assessee to a refund under Section 237. Conversely, if any part of the receipt is found to be chargeable to tax, credit for the corresponding TDS would be given. The Tribunal set aside the order of the CIT(A) and restored the issue to the file of the AO with directions to examine the applicability of Section 47(v), verify the TDS deduction and deposit, reconcile the shortfall in credit, and allow TDS credit in accordance with law. The AO was also directed to recompute consequential interest and pass a speaking order. The Tribunal expressed no opinion on the merits of the applicability of Section 47(v) or the taxability of the receipt.
The Tribunal found the reasons explained by the assessee for the 87-day delay to be satisfactory. The Tribunal noted that the assessee had shown sufficient cause that prevented him from filing the appeal within the prescribed time, a fact that the CIT(A) had overlooked. Therefore, in the interest of justice, the Tribunal decided to remand the matter back to the CIT(A). The CIT(A) was directed to reconsider the application for condonation of delay, condone the delay, and then adjudicate the issues raised in Form No. 35 on merits. The assessee was granted liberty to file any further evidence. The order of the CIT(A) was set aside, and the grounds of appeal were allowed for statistical purposes.
The Tribunal condoned the delay of 953 days in filing the appeal before it, finding the assessee's reasons to be bona fide and preventing timely filing. Regarding the delay before the CIT(A), the Tribunal noted the assessee's explanation of a serious accident on 5.12.2019, 70% disability, and lack of financial support. The Tribunal found these reasons reasonable and likely to have prevented timely filing. Consequently, the Tribunal set aside the order of the CIT(A) and remanded the matter back to the CIT(A) for fresh consideration of the application for condonation of delay and for adjudication of the issues on merits. The assessee was granted liberty to file supporting evidence. The grounds raised by the assessee were allowed for statistical purposes.
The Tribunal held that the assessee had discharged the burden of explaining the nature and source of investments through documentary evidence, including registered sale deeds, sale agreements, bank statements, ledger accounts, and confirmations. The Tribunal noted that the identity of persons concerned, genuineness of transactions, and nature/source of investments were not disputed by the Revenue. The Tribunal found that the Revenue had not adequately rebutted the explanation furnished by the assessee and had not brought any cogent material to discredit the explanation or establish that the investments represented unexplained income. The Tribunal observed that the AO had not made further inquiries, such as issuing summons under Section 131, despite the material furnished by the assessee. The Tribunal also acknowledged that the CIT(A) had correctly excluded an amount of Rs. 30,00,000/- pertaining to FY 2011-12. Therefore, the Tribunal set aside the findings of the CIT(A) sustaining the addition of Rs. 1,95,98,160/- and directed the AO to delete the said addition. The grounds raised by the assessee were allowed.
The Tribunal held that the return filed in ITR No. 7 was a defective return under Section 139(9) due to the apparent mismatch with the prescribed form. The Tribunal directed the Assessing Officer (AO) to accept the correct return in ITR No. 5. It was also held that a technical glitch regarding the Tax Audit Report in Form No. 10B should not be fatal to the exemption claim. Regarding the late filing of the return, the Tribunal directed the assessee to file an application under Section 119(2)(b) before the prescribed authority for condonation of delay. If the delay is condoned, the exemption is to be restored. Furthermore, the Tribunal noted that the assessee had incurred a deficit of Rs. 82,21,859/- (expenditure of Rs. 3,73,96,149/- against receipts of Rs. 2,91,74,290/-). Therefore, even if exemption was denied, only the real accounting surplus/deficit should be considered, not the entire gross receipt. The CPC was directed to consider this deficit along with any order of delay condonation. The appeal was allowed for statistical purposes, and the delay in filing the appeal before the Tribunal was condoned with a cost of Rs. 25,000/- to be deposited with the Tamil Nadu State Legal Service Authority.
The Tribunal noted that the figures of turnover and the liability to get accounts audited under Section 44AB were not under challenge. The sole issue was the applicability of Section 273B, which provides that no penalty shall be imposed if the assessee proves there was a reasonable cause for the failure. The Tribunal referred to judicial decisions, including the jurisdictional High Court's ruling in P. Senthil Kumar v. PCIT, which held that penalty can be waived if reasonable cause is demonstrated. The Tribunal observed that the assessee's submissions formed a reasonable cause for the purposes of Section 273B, but these submissions were not supported by any evidence. Therefore, the matter was restored to the AO with a direction to examine the assessee's case in light of Section 273B, providing an opportunity of being heard. The assessee was directed to be vigilant and cooperative, providing relevant evidence to establish a bonafide and reasonable cause. The grounds raised by the assessee were allowed for statistical purposes.
The Tribunal held that the assessee had not established a sustainable legal basis for annulling the consequential assessment passed under Section 153A read with Section 263, as there was no material demonstrating that the revision order under Section 263 had ceased to operate. The Tribunal found that the warrant of authorization, panchanama, seized Tally entries, Annexure III, and corroborative statements provided an evidentiary basis for the impugned addition. The addition of Rs. 19,50,000/- was supported by material found during the search and was not liable to be deleted simply because the assessment year was unabated. The assessee failed to furnish a satisfactory explanation regarding the nature and source of the cash credits. The Tribunal also held that the assessee had not established the requisite nexus between the impugned cash receipts and the additional income considered in settlement proceedings to warrant telescoping. The Tribunal rejected the assessee's reliance on decisions like Abhisar Buildwell and Ajitabh Agro Farms Pvt. Ltd. The CIT(A)'s order confirming the addition of Rs. 19,50,000/- under Section 68 was upheld, and both grounds of appeal were dismissed. The appeals for AY 2016-17 in ITA Nos. 3320, 3321, and 3322/Chny/2025 were also dismissed, applying the findings from the lead case.