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)

dividend income during the year and not by factoring in the total amount of investment. 19. Respectfully following the order of the Delhi Special Bench of the Tribunal in the case of ACIT v. Vireet Investments Pvt. Ltd. (supra), we direct the Assessing Officer to restrict the disallowance under Rule IT(TP)A Nos.105 to 107/Chny/2024 & ITA No. 3113 & 3251/Chny/24

M/S AADHI ENTERPRISES PRIVATE LIMITED,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(1), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.: 308/Chny/2023 िनधा"रण वष"/Assessment Year: 2016-17 Aadhi Enterprises Pvt. Ltd., The Acit, No.1-130, Perambur Barracks V. Central Circle-3(1), Road, Pattalam, Chennai. Chennai – 600 112. Pan: Aanca 0382P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri B. Ramakrishnan, Fca Shri S. Neelakantan, Fca Shri Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई क" तारीख/Date Of Hearing : 11.07.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.08.2023

bogus nature as held by Hon’ble Delhi High Court in the case of PCIT Vs. NDR Promoters P Ltd - ITA No.49/2018 dated 17.01.2019. I.T.A. No.308/CHNY/2023 41 25. Alternatively, Ld CIT Dr argued that one of the grounds taken by the assessee before the ITAT that, the information received from the FT&TR was neither provided nor any explanation sought

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

deemed date of search viz., the date on which\nsatisfaction note was recorded i.e., 08.02.2021, the AO is noted to have\nexercised his jurisdiction to issue notices u/s 153C of the Act in respect of\nsix assessment years preceding the year of search i.e. AYs 2015-16 to\n2020-21. The AO is further noted to have exercised powers conferred

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

deemed date of search viz., the date on which satisfaction note was recorded i.e., 08.02.2021, the AO is noted to have exercised his jurisdiction to issue notices u/s 153C of the Act in respect of six assessment years preceding the year of search i.e. AYs 2015-16 to 2020-21. The AO is further noted to have exercised powers conferred

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

deemed date of search viz., the date on which satisfaction note was recorded i.e., 08.02.2021, the AO is noted to have exercised his jurisdiction to issue notices u/s 153C of the Act in respect of six assessment years preceding the year of search i.e. AYs 2015-16 to 2020-21. The AO is further noted to have exercised powers conferred

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

deemed date of search viz., the date on which satisfaction note was recorded i.e., 08.02.2021, the AO is noted to have exercised his jurisdiction to issue notices u/s 153C of the Act in respect of six assessment years preceding the year of search i.e. AYs 2015-16 to 2020-21. The AO is further noted to have exercised powers conferred

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

deemed date of search viz., the date on which satisfaction note was recorded i.e., 08.02.2021, the AO is noted to have exercised his jurisdiction to issue notices u/s 153C of the Act in respect of six assessment years preceding the year of search i.e. AYs 2015-16 to 2020-21. The AO is further noted to have exercised powers conferred

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MOHANLAL JEWELLERS PRIVATE LIMITED, CHENNAI

In the result, all the all the appeals filed by the assessee is is partly allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

deem it fit to adjudicate each of the common issues across adjudicate each of the common issues across all AYs before us together. all AYs before us together. 5. As noted above, the first five (5) issues are common across all the As noted above, the first five (5) issues are common across all the As noted above, the first

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

bogus bills from our suppliers of gift articles to generate unaccounted cash. However, we received back one third of the invoice value on an average in the form of cash from our gift article suppliers. Since this amounts to inflation of the expenditure in our books of account, we undertake to withdraw of claim towards expenditure in the respective years

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

bogus bills from our suppliers of gift articles to generate unaccounted cash. However, we received back one third of the invoice value on an average in the form of cash from our gift article suppliers. Since this amounts to inflation of the expenditure in our books of account, we undertake to withdraw of claim towards expenditure in the respective years

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MOHANLAL JEWELLERS PRIVATE LIMITED, CHENNAI

deem it fit to\nadjudicate each of the common issues across all AYs before us together.\n\n5. As noted above, the first five (5) issues are common across all the\nAYs before us and therefore with the consent of both the parties, we take\nup and discuss the facts relating to AY 2017-18 as the lead case