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

Section 153C of the Act. Taking us through the . Taking us through the satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note for both the years and that

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

Section 153C of the Act. Taking us through the . Taking us through the satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note for both the years and that

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

Section 153C of the Act. Taking us through the . Taking us through the satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note(s), he pointed out that, the AO had recorded a common satisfaction note for both the years and 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

section of SAP.\nd) Based on the clarifications provided by Shri.S.Varatharaj on the\nevidences found, vide his sworn statement recorded u/s 132(4) of the\nAct at the business premises of M/s SAFL, it is gathered that there were\nno purchase orders raised for bogus purchases and as per the direction\nof Shri. Augustine Paulraj, the bogus invoices were directly

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

section of SAP.\nd) Based on the clarifications provided by Shri.S.Varatharaj on the\nevidences found, vide his sworn statement recorded u/s 132(4) of the\nAct at the business premises of M/s SAFL, it is gathered that there were\nno purchase orders raised for bogus purchases and as per the direction\nof Shri. Augustine Paulraj, the bogus invoices were directly

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 of SAP.\nd) Based on the clarifications provided by Shri.S.Varatharaj on the\nevidences found, vide his sworn statement recorded u/s 132(4) of the\nAct at the business premises of M/s SAFL, it is gathered that there were\nno purchase orders raised for bogus purchases and as per the direction\nof Shri. Augustine Paulraj, the bogus invoices were directly

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 of SAP.\nd) Based on the clarifications provided by Shri.S.Varatharaj on the\nevidences found, vide his sworn statement recorded u/s 132(4) of the\nAct at the business premises of M/s SAFL, it is gathered that there were\nno purchase orders raised for bogus purchases and as per the direction\nof Shri. Augustine Paulraj, the bogus invoices were directly

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

section of SAP.\n\nd) Based on the clarifications provided by Shri.S.Varatharaj on the\nevidences found, vide his sworn statement recorded u/s 132(4) of the\nAct at the business premises of M/s SAFL, it is gathered that there were\nno purchase orders raised for bogus purchases and as per the direction\nof Shri. Augustine Paulraj, the bogus invoices were

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

bogus purchases as against appellant’s voluntary disallowance of 12% in ROI u/s 148. 3.1 On facts and under the circumstances of the case, the learned Commissioner of Income Tax (Appeals)-19, Chennai erred in adjudicating the disallowances at 20% of the alleged bogus purchases, which is over and above the disallowances of 12% on alleged bogus purchases voluntarily returned

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

bogus purchases as against appellant’s voluntary disallowance of 12% in ROI u/s 148. 3.1 On facts and under the circumstances of the case, the learned Commissioner of Income Tax (Appeals)-19, Chennai erred in adjudicating the disallowances at 20% of the alleged bogus purchases, which is over and above the disallowances of 12% on alleged bogus purchases voluntarily returned

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

11 -:\nport-handling expenses, treating the entire gross receipts of Rs.3.02\ncrores as income. The AO noted that the offer of income at 8% was\nmade only in the revised statement of income and therefore could not\nbe considered.\n44. Regarding the alleged bogus purchases involving Zaheer Abbas\nand Sreedhar, the AO observed that these invoices were not\nsupported

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, 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

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

DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 260A of the Act, as a matter of routine." ITA Nos.1266 & 1267/Chny/2025 (AYs 2014-15 & 2016-17) Ramasamy Sivaprakasam :: 11 :: 11. In the present case also, if the impugned purchases are disallowed, it would result in an abnormal gross profit rate of 41.55% and a distorted net profit rate of 25.45% in a regular textile export business

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 260A of the Act, as a matter of routine." ITA Nos.1266 & 1267/Chny/2025 (AYs 2014-15 & 2016-17) Ramasamy Sivaprakasam :: 11 :: 11. In the present case also, if the impugned purchases are disallowed, it would result in an abnormal gross profit rate of 41.55% and a distorted net profit rate of 25.45% in a regular textile export business

V SATHYAMOORTHY&CO,ERODE vs. DCIT, CENTRAL CIRCLE -, COIMBATORE

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1024/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2 Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.1547/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) Dcit M/S. V. Sathyamoorthy & Co., बनाम/ Central Circle-2 41, Patel Road, Near Blood Bank, Vs. Coimbatore. Erode-638 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 17-10-2024 आदेश / O R D E R

bogus purchases is wholly unjustified and not sustainable both on facts and in law. 8. The CIT (Appeals) failed to appreciate that the Appellant had suo-moto disallowed the purchases pertaining to the seized excel sheet with respect to parties from whom money were received back in its return of income filed in response to the notice issued u/s 153A

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/A

bogus for\nbeing non-verifiable. The AO accordingly rejected the book results and\nestimated the income of the assessee at a much higher sum. On appeal,\nthe Hon'ble High Court held that, even if the purchases were not\nverifiable, it was not in dispute that the assessee had indeed carried out\ncivil construction and therefore would have made purchases