NEELARAJ VINOTH,PERAMBALUR vs. ACIT, CC-2, , TRICHY

In the result, the appeal of the revenue is dismissed and the CO filed by the assessee is dismissed

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1982/Chny/2024 & C.O.No. 60/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of Neelaraj Vinoth, Income Tax, V. 274-C, Thuraiyur Road, Central Circle -2, Perambalur – 621 212, Trichy. Tamilnadu. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (Respondent/Cross Objector) आयकर अपील सं./Ita No.: 2119/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Neelaraj Vinoth, Assistant Commissioner Of 274-C, Thuraiyur Road, V. Income Tax, Perambalur – 621 212, Central Circle -2, Tamilnadu. Trichy. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained money u/s.69A of the Act, since the assessee has not satisfactorily explained the source for payment made to SEBI as bid money for purchase of immovable property in auction. The ld.DR submitted that the Ld.CIT(A) erred in holding that the letter received from SEBI seized in the premises of assessee's father cannot be treated as incriminating material

SRI ARUMUGA COTTSPIN PVT. LTD.,COIMBATORE vs. THE ACIT, CC-I,, COIMBATORE

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1098/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) M/S. Sri Arumuga Cottspin Pvt. Ltd. Acit बनाम Sf No.919/6, No.2, Pollachi Road, Central Circle-1, / Vs. Ramanathapuram, Coimbatore-642 104. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aajcs-5065-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld. Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024

unexplained money u/s 69A. The assessee received advance of Rs.95.55 Lacs from M/s Mahasakthi Mills Ltd. which was also added protectively in the hands of the assessee in similar manner u/s 69A. However, upon further appeal, Ld. CIT(A) has deleted the protective addition of Rs.95.55 Lacs and the same is not the subject matter of dispute before

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. NEELARAJ VINOTH, PERAMBALUR

In the result, the appeal of the assessee is dismissed

unexplained money u/s.69A of the Act, since the\nassessee has not satisfactorily explained the source for payment\nmade to SEBI as bid money for purchase of immovable property in\nauction. The Id.DR submitted that the Ld.CIT(A) erred in holding\nthat the letter received from SEBI seized in the premises of\nassessee's father cannot be treated as incriminating material

SRI MAHASAKTHI MILLS LIMITED,COIMBATORE vs. THE ACIT, CC-I,, COIMBATORE

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1059/Chny/2024 (िनधा)रण वष) / Assessment Year: 2017-18) Sri Mahasakthi Mills Limited Acit बनाम/ No.95/13, Vyshnav Building, Central Circle-1, Opp. Kg Cinemas, Race Course Road Coimbatore. Vs. Coimbatore-641 018. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcs-2111-C (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Venkata Raman (Ca) - Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-09-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-12-2024 आदेश / O R D E R

unexplained money. 2. That the Ld.CIT(A) erred in not appreciating that the provisions of section 69A of the Act are not applicable to the facts and circumstances of the case of the appellant and consequently not justified in not deleting the addition made by the Assessing Officer u/s.69A of the Act. 3. That

PALANICHAMY NANTHINI DEVI,CHENNAI vs. ITO, NCW-17(4), CHENNAI

In the result, the appeal filed by the assessee is partly allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 565/Chny/2025 िनधा"रण वष" / Assessment Year: 2019-20 Palanichamy Nanthini Devi, The Income Tax Officer, Staff Nurse Room Stanley Medical Vs. Non-Corporate Ward -17 (4), College, Chennai. Chennai – 600 001. [Pan: Axfpn-2460-F] (अपीलाथ"/Appellant) (""थ"/Respondent)

TDS statement of employer i.e. Govt. Stanley Hospital. In response to notice u/s.148 the assessee filed her return of income on 29.04.2023 declaring total income of Rs.1,88,100/-. Later the AO issued statutory notices to the assessee for scrutiny assessment and the assessee filed certain details. The assessee submitted that the salary income earned was Rs.6,11,976/- during

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. S R TRUST, MADURAI

In the result, the appeal filed by the revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1549/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of S R Trust, Income Tax, Vs. 1, Melur Road, Lake Area, Central Circle -1, Madurai – 625 107. Madurai. [Pan: Aacts-0376-F] (अपीलाथ"/Appellant) (""थ"/Respondent)

unexplained money Rs.1,75,14,608/- - Travel expenses disallowed Rs.54,48,077/- - Legal expenses disallowed Rs.1,12,50,000/- An appeal filed by the assessee, the ld. CIT(A) has deleted the above by passing an order 26.03.2024. The AO has disallowed the travelling expenses of Shri. Gurushankar, Smt. Kamini, Shri. K.Subramanian and Shri. Sachithanantha towards both foreign as well

VIDHIYASEKARAN PRADEEP MALLIRAJ,MADURAI vs. ITO,NON CORP WARD-1(6), MADURAI

In the result, the appeal stand partly allowed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

unexplained money. The order of the Assessing Officer is erroneous in law and against the principles of natural justice. The addition so made requires deletion, for the said sum, since duly reflected in the books of account of the appellant, is outside the scope of sec. 69A/68 of the Act, for the said section is applicable only when

M/S. AMBATTUR DEVELOPERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(1), CHENNAI

In the result the appeal of the assessee is allowed

TDS on transfer of immovable property (other than agricultural land) above\na prescribed threshold.\n• TCS on trading in coal, lignite, and iron ore.\n• Enhanced onus of proof on closely held companies for funds received\nfrom shareholders, and taxation of share premium in excess of fair\nmarket value.\n• Taxation of unexplained money

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained money under section 69A of the Act and prayed that the ground raised by the assessee may be dismissed. 28. We have heard both the sides, perused the materials available on record. It is an admitted fact that the assessee has entered into an agreement with Praj Industries Ltd. for setting up of distillery plant at Sivagangai and Pudukkottai

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained money under section 69A of the Act and prayed that the ground raised by the assessee may be dismissed. 28. We have heard both the sides, perused the materials available on record. It is an admitted fact that the assessee has entered into an agreement with Praj Industries Ltd. for setting up of distillery plant at Sivagangai and Pudukkottai

DCIT,NON CORPORATE CIRCLE-2,, COIMBATORE vs. M/S D GEM MOUNT, COIMBATORE

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.782/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of Vs. M/S. D. Gem Mount, Income Tax, No. 19, Vedapatti Road, Non-Corporate Circle 2, Aayakar Telungupalayam, Bhavan, 63, Race Course Road, Coimbatore 641 039. Coimbatore 641 018. [Pan:Aaffd8890G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 27.03.2024 घोषणा की तारीख /Date Of Pronouncement : 10.04.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi Dated 30.03.2023 For The Assessment Year 2017-18. 2. The Appeal Filed By The Revenue Is Delayed By 32 Days, For Which, The Dcit, Non Corporate Circle-2, Coimbatore Has Filed A Petition In The Form Of An Affidavit For Condonation Of The Delay Explaining The Cause For The Delay In Filing The Appeal & Prayed That 2

unexplained money under section 69A of the Act and added to the total income of the assessee and brought to tax under section 115BBE of the Act. 8. On appeal, the ld. CIT(A) has observed that the Assessing Officer has made addition solely on comparison basis. The Assessing Officer has not doubted the purchases made by the assessee anywhere

ACIT, TIRUNELVELI vs. T.CHINNARAMASIVAN, TIRUNELVELI

In the result, the Revenue’s appeal is treated as allowed for statistical

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

unexplained money in the hands of the assessee u/s. 69A and taxed the same on maximum marginal rate invoking section 115BBE. Aggrieved against the assessment order, the assessee filed an appeal before the CIT(A). The CIT(A)-3, Madurai, following the precedence in the assessee’s case held that it would be justified to estimate the income

JCR TRADERS,KEELAMATHUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1) TRICHY, TRICHY

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.333/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Jcr Traders, Vs. The Deputy Commissioner Of 2/117, Thittakudi Road, Income Tax, Keelamathur, Tamil Nadu 621 173. Circle 1(1), Trichy. [Pan:Aalfj6942K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Deeptha, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.08.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 93 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

unexplained money under section 69 of the Act. Not satisfied with the assessment order, the assessee preferred an appeal before the ld. CIT(A)/NFAC. The ld. CIT(A) dismissed the appeal of the assessee for want of prosecution. 4 I.T.A. No.333/Chny/25 Aggrieved by the order of the ld. CIT(A), the assessee is in appeal before the Tribunal

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

unexplained investments in properties for various years and addition for low drawings. In the hands of the assessee M/s. Shiv Sahai & Sons (India) 18. Ltd, apart from the disallowances/ additions of the nature mentioned in the preceding para there were additions for sundry debtors reflecting negative balance for want of confirmation, disallowance for VAT payment and an addition for under

SAHAI & SONS (I) LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

unexplained investments in properties for various years and addition for low drawings. In the hands of the assessee M/s. Shiv Sahai & Sons (India) 18. Ltd, apart from the disallowances/ additions of the nature mentioned in the preceding para there were additions for sundry debtors reflecting negative balance for want of confirmation, disallowance for VAT payment and an addition for under

ACIT CENTRAL CIRCLE 3(1), CHENNAI vs. SHIV SAHAI & SONS (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

unexplained investments in properties for various years and addition for low drawings. In the hands of the assessee M/s. Shiv Sahai & Sons (India) 18. Ltd, apart from the disallowances/ additions of the nature mentioned in the preceding para there were additions for sundry debtors reflecting negative balance for want of confirmation, disallowance for VAT payment and an addition for under

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

unexplained investments in properties for various years and addition for low drawings. In the hands of the assessee M/s. Shiv Sahai & Sons (India) 18. Ltd, apart from the disallowances/ additions of the nature mentioned in the preceding para there were additions for sundry debtors reflecting negative balance for want of confirmation, disallowance for VAT payment and an addition for under

ACIT, CIRCLE-1,, HOSUR vs. M/S. UTHANGRAI SRI VIDYA MANDIR EDUCATIONAL TRUST, KRISHNAGIRI

In the result, the appeals filed by the Revenue for the assessment years 2011-12 to 2017-18 in ITA Nos

Bench: Shri Mahavir Singhand Shri Manjunatha.Gआयकर अपील सं./Ita Nos.: 370, 371 & 372 /Chny/2020 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13 & 2013-14 & C.O Nos.3, 4 & 5/Chny/2021 [In I.T.A. Nos.370, 371 & 372/Chny/2020] The Assistant M/S. Uthangarai Sri Vidya Commissioner Of Income Vs. Mandir Educational Trust, Tax, No.115, Ramamurthy Nagar, Circle-1, Uthangarai, Hosur. Krishnagiri – 635 207. Pan: Aadts 6092D (अपीलाथ"/Appellant) (""यथ"/Respondent / Cross Objector) & आयकर अपील सं./Ita Nos.: 644, 645, 646 & 647/Chny/2020 िनधा"रण वष"/Assessment Years:2014-15, 2015-16, 2016-17 & 2017-18 M/S. Uthangarai Sri Vidya The Assistant Mandir Educational Trust, Vs. Commissioner Of Income No.115, Ramamurthy Nagar, Tax, Uthangarai, Circle-1, Krishnagiri – 635 207. Hosur. Pan: Aadts 6092D (अपीलाथ"/Appellant) (""यथ"/Respondent) &

TDS on the payment to these employees being salary payment and which is much more than the salary payment collated from the seized material by the AO. Hence, we have no alternative except to make an estimate disallowance and in our view, for any leakage we can estimate the disallowance to the extent of 10% of the total salary claimed