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

11,59,615 56,41,82,236 56,41,82,236 58,23,45,992 2 Disallowance of data center expenses Disallowance of data center expenses 55,64,877 61,36,677 61,36,677 1,29,61,697 3 Addition on a/c of unaccounted sale of Addition on a/c of unaccounted sale

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

11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered to reopen any relevant assessment year within three (3)\nyears from the end of the relevant assessment year [Section 149(1)(a)].\nThe AO is also entitled to issue notice u/s 148 of the Act beyond three (3)\nyears but not more than ten (10) years

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

11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered to reopen any relevant assessment year within three (3)\nyears from the end of the relevant assessment year [Section 149(1)(a)].\nThe AO is also entitled to issue notice u/s 148 of the Act beyond three (3)\nyears but not more than ten (10) years

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

11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered to reopen any relevant assessment year within three (3)\nyears from the end of the relevant assessment year [Section 149(1)(a)].\nThe AO is also entitled to issue notice u/s 148 of the Act beyond three (3)\nyears but not more than ten (10) years

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

11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered to reopen any relevant assessment year within three (3)\nyears from the end of the relevant assessment year [Section 149(1)(a)].\nThe AO is also entitled to issue notice u/s 148 of the Act beyond three (3)\nyears but not more than ten (10) years

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

11 ::\n8. Reading of the above provision reveals that, the AO is ordinarily\nempowered to reopen any relevant assessment year within three (3)\nyears from the end of the relevant assessment year [Section 149(1)(a)].\nThe AO is also entitled to issue notice u/s 148 of the Act beyond three (3)\nyears but not more than ten (10) years

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

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

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

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

bogus purchases is Rs.4,41,70,464/- for the F.Y 2017-18 (From July 18 (From July 2017), Rs. 5,69,70,130/ 2017), Rs. 5,69,70,130/- for the F.Y 2018-19 and Rs. 2,95,16,955/ 95,16,955/- for the F.Y. 2019-20 (up 20 (up to 4.8.2019). The above seized materials were handed over

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

bogus purchases is Rs.4,41,70,464/- for the F.Y 2017-18 (From July 18 (From July 2017), Rs. 5,69,70,130/ 2017), Rs. 5,69,70,130/- for the F.Y 2018-19 and Rs. 2,95,16,955/ 95,16,955/- for the F.Y. 2019-20 (up 20 (up to 4.8.2019). The above seized materials were handed over

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

11,59,615 | 56,41,82,236 | 58,23,45,992\n2\nDisallowance of data center expenses\n55,64,877\n61,36,677 1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341 42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ

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

11,59,615\n56,41,82,236\n58,23,45,992\n2\nDisallowance of data center expenses\n55,64,877\n61,36,677\n1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341\n42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ

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

11,59,615 | 56,41,82,236 | 58,23,45,992\n2\nDisallowance of data center expenses\n55,64,877\n61,36,677 1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341 42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ

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

11,59,615\n56,41,82,236\n58,23,45,992\n2\nDisallowance of data center expenses\n55,64,877\n61,36,677\n1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341\n42,94,341\n4\nAddition on a/c of bogus CSR contribution

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

11,59,615\n56,41,82,236\n58,23,45,992\n2\nDisallowance of data center expenses\n55,64,877\n61,36,677\n1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341\n42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ