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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

1 to 66. It is noted that, this excel file comprised of five( comprised of five(5)sheets which comprised of data relating to which comprised of data relating to purchase of old bottles for ttles for three-month period in the year 2020 month period in the year 2020. The AO is noted to have tabulated sample data from

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 132 of the Act is conducted\nor requisition is made under Section 132A of the Act as well as the\nrelevant assessment year or years.\n13. As is apparent from the plain language of Section 153A(1) of the\nAct, the AO has the jurisdiction to issue a notice in respect of each of\nthe assessment years falling within

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 132 was conducted or a requisition under\nSection 132A of the Act was made. Plainly, the said controversy is\nrequired to be addressed by referring to Section 153A of the Act.\nSection 153A(1) of the Act is set out below:.......\n12. It is apparent from the above that Section 153A of the Act refers to\ntime periods within

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Section 153A of the Act.\nSection 153A(1) of the Act is set out below:.......\n12. It is apparent from the above that Section 153A of the Act refers to\ntime periods within which the assessments could be reopened. In terms\nof Section 153A(1) of the Act, the assessments can be reopened for a\nblock of six years preceding

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

1 to\nSection 153A(1) of the Act, the Revenue can travel back ten years from\nthe end of the assessment year relevant to the previous year in which\nthe search under Section 132 was conducted or a requisition under\nSection 132A of the Act was made. Plainly, the said controversy is\nrequired to be addressed by referring to Section

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

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

1 to 66. It is noted that, this excel file excel file comprised of five(5) Sheets which comprised of data relating to purchase which comprised of data relating to purchase which comprised of data relating to purchase of old bottles for three-month period in the year 2020 month period in the year 2020. The AO is noted

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

1 to 66. It is noted that, this excel file excel file comprised of five(5) Sheets which comprised of data relating to purchase which comprised of data relating to purchase which comprised of data relating to purchase of old bottles for three-month period in the year 2020 month period in the year 2020. The AO is noted

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

1 to 66. It is noted that, this excel file excel file comprised of five(5) Sheets which comprised of data relating to purchase which comprised of data relating to purchase which comprised of data relating to purchase of old bottles for three-month period in the year 2020 month period in the year 2020. The AO is noted

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

1 to 66. It is noted that, this excel file excel file comprised of five(5) Sheets which comprised of data relating to purchase which comprised of data relating to purchase which comprised of data relating to purchase of old bottles for three-month period in the year 2020 month period in the year 2020. The AO is noted

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

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

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

bogus purchases is Rs.4,41,70,464/- for the F.Y 2017-18 (From July\n2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for\nthe F.Y. 2019-20 (up to 4.8.2019).\nThe above seized materials were handed over to the undersigned on\n18.06.2021. On perusal of the seized material I am satisfied that

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

bogus transactions.\nHandling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\nFailure to comply with standard accounting procedures for genuine\npurchases.\nThe inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent books of accounts

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

bogus transactions.\n➤ Handling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\n➤ Failure to comply with standard accounting procedures for genuine\npurchases.\n➤ The inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

bogus purchases is Rs.4,41,70,464/- for the F.Y 2017-18 (From July\n2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for\nthe F.Y. 2019-20 (up to 4.8.2019).\nThe above seized materials were handed over to the undersigned on\n18.06.2021. On perusal of the seized material I am satisfied that

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

bogus transactions.\n➤ Handling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\n➤ Failure to comply with standard accounting procedures for genuine\npurchases.\n➤ The inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent