DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

reopen six preceding assessment years preceding the searched assessment year and those AY's were years preceding the searched assessment year and those AY's were years preceding the searched assessment year and those AY's were AYs2014-15 to 2019-20. It is not in dispute that, the income 20. It is not in dispute that, the income

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

reopen six preceding assessment years preceding the searched assessment year and those AY's were years preceding the searched assessment year and those AY's were years preceding the searched assessment year and those AY's were AYs2014-15 to 2019-20. It is not in dispute that, the income 20. It is not in dispute that, the income

RASI SEEDS (P) LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

reopening of assessment, there is no allegation on the part of the assessee to disclose fully and truly all material facts necessary for assessment and further, notice u/s.148 has been issued without proper approval from the competent authority. The assessee had also challenged additions made by the Assessing Officer towards disallowance of bogus purchases

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

reopen the assessment for A.Y. 2016-17 based on the approval granted by the Member (Inv.), CBDT, New Delhi, instead of the Pr. CCIT, Chennai. ii) Enhancement of the profit percentage applied to the quantum of alleged bogus purchases

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

reopen the assessment for A.Y. 2016-17 based on the approval granted by the Member (Inv.), CBDT, New Delhi, instead of the Pr. CCIT, Chennai. ii) Enhancement of the profit percentage applied to the quantum of alleged bogus purchases

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee's appeals in ITA Nos.1881, 1882,\nand 1883/Chny/2025 for A.Ys.2016-17, 2019-20, and 2022-23 are\nallowed

reopened by issue\nof notice u/ 148, regular assessment for AY 2022-23 were concluded\nby passing the orders u/s 147 and 143(2) respectively on 30.03.2024,\nthe details of which are tabulated hereunder:\nΑ.Υ.\nReturned Income\nAssessed Income\nu/S 139(1)\n2016-17\n1,75,96,950\n4,12,56,380\n15,80,88,793\n2019

PRINCE GOLD & DIAMONDS INDIA P LTD,CHENNAI vs. DCIT,CC-1(4), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.427 & 428/Chny/2021 िनधा"रण वष"/Assessment Years: 2011-12 & 2012-13 M/S. Prince Gold & Diamonds India Vs. The Deputy Commissioner Of P. Ltd., 3, Nana Street, T. Nagar, Income Tax, Chennai 600 017. Central Circle 1(4), Chennai. [Pan: Aaecp1891R] (अपीलाथ" /Appellant) (""थ"/Respondent) Assessee By : Shri D. Palanivel, Advocate Department By : Ms. L. Jancy Elizabeth Rani, Jcit सुनवाई की तारीख/ Date Of Hearing 28.06.2022 : घोषणा की तारीख /Date Of Pronouncement : 03.08.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 31.08.2021 Relevant To The Assessment Years 2011-12 & 2012-13. Besides Challenging Reopening Of Assessment Under Section 147 Of The Income Tax Act, 1961 [“Act”], The Assessee Has Also Disputed The Confirmation Of Disallowance Of Purchase On Merits In Both The Assessment Years Under Consideration.

purchases to the extent of ₹.45,25,383/-. On appeal, 4 I.T.A. Nos. 427 & 428/Chny/21 the ld. CIT(A) confirmed the reassessment order for both the assessment years. 3. On being aggrieved, the assessee is in appeal before the Tribunal. The ld. Counsel for the assessee has submitted that the Assessing Officer issued notice under section

PRINCE GOLD & DIAMONDS INDIA P LTD,CHENNAI vs. DCIT, CC-1(4), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.427 & 428/Chny/2021 िनधा"रण वष"/Assessment Years: 2011-12 & 2012-13 M/S. Prince Gold & Diamonds India Vs. The Deputy Commissioner Of P. Ltd., 3, Nana Street, T. Nagar, Income Tax, Chennai 600 017. Central Circle 1(4), Chennai. [Pan: Aaecp1891R] (अपीलाथ" /Appellant) (""थ"/Respondent) Assessee By : Shri D. Palanivel, Advocate Department By : Ms. L. Jancy Elizabeth Rani, Jcit सुनवाई की तारीख/ Date Of Hearing 28.06.2022 : घोषणा की तारीख /Date Of Pronouncement : 03.08.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 31.08.2021 Relevant To The Assessment Years 2011-12 & 2012-13. Besides Challenging Reopening Of Assessment Under Section 147 Of The Income Tax Act, 1961 [“Act”], The Assessee Has Also Disputed The Confirmation Of Disallowance Of Purchase On Merits In Both The Assessment Years Under Consideration.

purchases to the extent of ₹.45,25,383/-. On appeal, 4 I.T.A. Nos. 427 & 428/Chny/21 the ld. CIT(A) confirmed the reassessment order for both the assessment years. 3. On being aggrieved, the assessee is in appeal before the Tribunal. The ld. Counsel for the assessee has submitted that the Assessing Officer issued notice under section

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reopening is issued is squashed by us, the Assessing Officer had no jurisdiction to make further additions in respect of any other items, which had come to his notice at the time of reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reopening is issued is squashed by us, the Assessing Officer had no jurisdiction to make further additions in respect of any other items, which had come to his notice at the time of reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reopening is issued is squashed by us, the Assessing Officer had no jurisdiction to make further additions in respect of any other items, which had come to his notice at the time of reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

reopening is issued is squashed by us, the Assessing Officer had no jurisdiction to make further additions in respect of any other items, which had come to his notice at the time of reassessment proceedings. In the light of the legal positions discussed above, other items of addition made by Assessing Officer cannot be sustained. Therefore, it is not necessary

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CC-2(4), CHENNAI

Accordingly, the assessee's appeals in ITA Nos.1881, 1882,\nand 1883/Chny/2025 for A.Ys.2016-17, 2019-20, and 2022-23 are\nallowed

bogus\npurchases as against appellant's voluntary disallowance of 12% in\nROI u/s 148.\n3.1 On facts and under the circumstances of the case, the learned\nCommissioner of Income Tax (Appeals)-19, Chennai erred in\nadjudicating the disallowances at 20% of the alleged bogus\npurchases, which is over and above the disallowances of 12% on\nalleged bogus purchases voluntarily returned

ACIT, NUNGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee's appeals in ITA Nos.1881, 1882,\nand 1883/Chny/2025 for A.Ys.2016-17, 2019-20, and 2022-23 are\nallowed

bogus\npurchases as against appellant's voluntary disallowance of 12% in\nROI u/s 148.\n3.1 On facts and under the circumstances of the case, the learned\nCommissioner of Income Tax (Appeals)-19, Chennai erred in\nadjudicating the disallowances at 20% of the alleged bogus\npurchases, which is over and above the disallowances of 12% on\nalleged bogus purchases voluntarily returned

ACIT, NUNAGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

bogus\npurchases as against appellant's voluntary disallowance of 12% in\nROI u/s 148.\n3.1 On facts and under the circumstances of the case, the learned\nCommissioner of Income Tax (Appeals)-19, Chennai erred in\nadjudicating the disallowances at 20% of the alleged bogus\npurchases, which is over and above the disallowances of 12% on\nalleged bogus purchases voluntarily returned

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

purchase basis' as well as on 'lease/rent basis', a reassessment notice issued after four years has been held not to suffer from any illegality as the same was based on the bona fide action of the competent authority to determine whether or not the vehicles in respect of which the petitioner had been claiming depreciation, were actually owned

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

purchase basis' as well as on 'lease/rent basis', a reassessment notice issued after four years has been held not to suffer from any illegality as the same was based on the bona fide action of the competent authority to determine whether or not the vehicles in respect of which the petitioner had been claiming depreciation, were actually owned

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

purchase basis' as well as on 'lease/rent basis', a reassessment notice issued after four years has been held not to suffer from any illegality as the same was based on the bona fide action of the competent authority to determine whether or not the vehicles in respect of which the petitioner had been claiming depreciation, were actually owned