M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

1 ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 11 :: appended to it. Therefore, it is noteworthy that, the fourth proviso to section 153A bars the AO to issue notice u/s. 153A/153C of the Act for the assessment or reassessment of the 7th - 10th AY's unless

ACIT, CHENNAI vs. M/S. S & P FOUNDATION P. LTD., CHENNAI

In the result, the appeal filed by the Revenue is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.2084/Chny/2013 िनधा"रण वष"/Assessment Years: 2006-07 The Assistant Commissioner Of M/S. S & P Foundation P. Ltd., Income Tax, Central Circle Iv(2), Vs. Old No. 27, New No. 38, Madley Road, 46, Nungambakkam High Road, T. Nagar, Chennai 600 017. Chennai. [Pan: Aaics0224K] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Johnson, Addl. Cit : ""थ" की ओर से/Respondent By Shri G. Baskar, Advocate & : Shri I Dinesh, Advocate सुनवाई की तारीख/ Date Of Hearing 02.12.2021 : घोषणा की तारीख /Date Of Pronouncement : 16.12.2021 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) Ii, Chennai, Dated 05.12.2012 Relevant To The Assessment Year 2006-07 In Pursuance To The Order Of The Assessing Officer In Levying Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

153A of the Act was only after search conducted by the Department, otherwise, the assessee would not have disclosed the above income and thus, the disclosure made by the assessee 10 I.T.A. No. 2084/Chny/13 amounts to clear concealment of income thereby levied penalty under section 271(1)(c) of the Act on the entire income

ACIT, CHENNAI vs. M/S. S & P FOUNDATION P. LTD., CHENNAI

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue stands allowed

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 382/Chny/2013 िनधा"रण वष"/Assessment Year: 2007-08 M/S. S&P Foundations Pvt. Ltd., The Assistant Commissioner Of Madley Road, T. Nagar, Vs. Income Tax, Chennai 600 017. Central Circle Iv(2), [Pan:Aaics0224K] Chennai - 34. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 2085/Chny/2013 िनधा"रण वष"/Assessment Year: 2007-08 The Assistant Commissioner Of M/S. S&P Foundations Pvt. Ltd., Income Tax, Central Circle Iv(2), Madley Road, T. Nagar, Vs. Chennai - 34. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri G. Baskar, Advocate Shri J. Pavithran Kumar, Jcit Department By : सुनवाई की तारीख/ Date Of Hearing : 15.10.2019 घोषणा की तारीख /Date Of Pronouncement : 28.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) Ii, Chennai, Dated 05.12.2012 Relevant To The Assessment Year 2007-08 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

TDS. Moreover, while filing return under section 153A of the Act, the assessee has failed to add the statutory disallowances applicable as per law, thereby the assessee has furnished inaccurate particulars warranting levy of penalty. Under these facts and circumstances, we are of the considered opinion that the Assessing Officer has rightly levied penalty under section 271(1

S & P FOUNDATIONS PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue stands allowed

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 382/Chny/2013 िनधा"रण वष"/Assessment Year: 2007-08 M/S. S&P Foundations Pvt. Ltd., The Assistant Commissioner Of Madley Road, T. Nagar, Vs. Income Tax, Chennai 600 017. Central Circle Iv(2), [Pan:Aaics0224K] Chennai - 34. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 2085/Chny/2013 िनधा"रण वष"/Assessment Year: 2007-08 The Assistant Commissioner Of M/S. S&P Foundations Pvt. Ltd., Income Tax, Central Circle Iv(2), Madley Road, T. Nagar, Vs. Chennai - 34. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri G. Baskar, Advocate Shri J. Pavithran Kumar, Jcit Department By : सुनवाई की तारीख/ Date Of Hearing : 15.10.2019 घोषणा की तारीख /Date Of Pronouncement : 28.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) Ii, Chennai, Dated 05.12.2012 Relevant To The Assessment Year 2007-08 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

TDS. Moreover, while filing return under section 153A of the Act, the assessee has failed to add the statutory disallowances applicable as per law, thereby the assessee has furnished inaccurate particulars warranting levy of penalty. Under these facts and circumstances, we are of the considered opinion that the Assessing Officer has rightly levied penalty under section 271(1

M.PALANISAMY,COIMBATORE vs. DCIT, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

DCIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

DCIT, COIMBATORE vs. M/S. SENTHIL BUILDING MATERIAL MANUFACTURING CO. (P) LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153A, the A.O. has brought to tax sumson account of cash deposits made in the bank account declared in the regular books of account without any incriminating material found during the course of search. Once this is the position the issue is clearly covered in favour of assessee and against the Revenue by the decision of Hon’ble Bombay High