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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

bogus purchases, which is over and above the disallowances of 12% on alleged bogus purchases voluntarily returned by the appellant in ROI u/s.148 for the impugned AY 2019-20. 3.2 On the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals)-19, Chennai erred in enhancing the disallowances over and above the voluntary disallowance, without appreciating

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, 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

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

In the result, the appeal of the assessee is allowed

116. Equally important is the requirement of "transfer" of such capital asset. Section 2(47) of the Act defines the term "transfer" in an inclusive and expansive manner so as to bring within its fold various modes by which ownership or enjoyment of a capital asset is relinquished. Sale, exchange, or relinquishment of an asset squarely fall within the ambit

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

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

116 taxmann.com 151(SC) has held that the Assessing Officer is not allowed to alter his reasons, which must be considered only based on their recordings. In our considered view, this ratio decidendi of the Hon'ble Supreme Court is applicable with equal force to the satisfaction note prepared by the AO for assuming jurisdiction to issue notice under section

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

116 taxmann.com 151(SC) has held that the Assessing Officer is not allowed to alter his reasons, which must be considered only based on their recordings. In our considered view, this ratio decidendi of the Hon'ble Supreme Court is applicable with equal force to the satisfaction note prepared by the AO for assuming jurisdiction to issue notice under section

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

116 taxmann.com 151(SC) has held that the Assessing Officer is not allowed to alter his reasons, which must be considered only based on their recordings. In our considered view, this ratio decidendi of the Hon'ble Supreme Court is applicable with equal force to the satisfaction note prepared by the AO for assuming jurisdiction to issue notice under section

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

116 taxmann.com 151(SC) has held that the Assessing Officer is not allowed to alter his reasons, which must be considered only based on their recordings. In our considered view, this ratio decidendi of the Hon'ble Supreme Court is applicable with equal force to the satisfaction note prepared by the AO for assuming jurisdiction to issue notice under section

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

116 taxmann.com 151(SC) has held that the Assessing Officer is not allowed to alter his reasons, which must be considered only based on their recordings. In our considered view, this ratio decidendi of the Hon'ble Supreme Court is applicable with equal force to the satisfaction note prepared by the AO for assuming jurisdiction to issue notice under section

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

In the result, appeals filed by the assessee(s) are allowed

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

116 taxmann.com 151(SC) has held that the Assessing Officer is not allowed to alter his reasons, which must be considered only based on their recordings. In our considered view, this ratio decidendi of the Hon'ble Supreme Court is applicable with equal force to the satisfaction note prepared by the AO for assuming jurisdiction to issue notice under section

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

purchase of a land and the approval was obtained for the same purpose, ₹50,00,00,000/- received from Pacatolus was invested in Sanklacha Infra Projects Private Limited, which is a I.T.A. No.308/CHNY/2023 22 related concern. Thus, the fund was not utilised towards the purpose for which it was obtained. 8. The AO noted that one Mr. Jamie Williams Tamuara

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

bogus nor rejected by Revenue. All these, in our opinion indicate that credits in bullion margin money account could have been part of sale consideration. ITA Nos. 1447, 1448, 1988, :- 49 -: 1989, 1449 to 1455, 1485 to 1491/17. Section 68 of the Act is which apposite here is reproduced 54. hereunder:- ‘’Where any sum is found credited in the books

ACIT CENTRAL CIRCLE 3(1), CHENNAI vs. SHIV SAHAI & SONS (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

bogus nor rejected by Revenue. All these, in our opinion indicate that credits in bullion margin money account could have been part of sale consideration. ITA Nos. 1447, 1448, 1988, :- 49 -: 1989, 1449 to 1455, 1485 to 1491/17. Section 68 of the Act is which apposite here is reproduced 54. hereunder:- ‘’Where any sum is found credited in the books

SAHAI & SONS (I) LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

bogus nor rejected by Revenue. All these, in our opinion indicate that credits in bullion margin money account could have been part of sale consideration. ITA Nos. 1447, 1448, 1988, :- 49 -: 1989, 1449 to 1455, 1485 to 1491/17. Section 68 of the Act is which apposite here is reproduced 54. hereunder:- ‘’Where any sum is found credited in the books

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

bogus nor rejected by Revenue. All these, in our opinion indicate that credits in bullion margin money account could have been part of sale consideration. ITA Nos. 1447, 1448, 1988, :- 49 -: 1989, 1449 to 1455, 1485 to 1491/17. Section 68 of the Act is which apposite here is reproduced 54. hereunder:- ‘’Where any sum is found credited in the books

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

PURCHASE BULLION PURCHASE BULLION 13750.00 ITA Nos.1178 to 1182/Chny/2025 to 1182/Chny/2025 & ITA Nos.1393 ITA Nos.1393 to 1397/Chny/2025 (AYs: 2017 : 2017-18 to 2021-22) M/s. Mohanlal Jewellers Pvt. Ltd M/s. Mohanlal Jewellers Pvt. Ltd ::29 :: (13750X99.5%) (13750X99.5%) ALLOY =91.70% ALLOY =91.70% 1169.57 Gold + Alloy Gold + Alloy 14919.57 GOLD WT (13750.00 X99.5) GOLD WT (13750.00 X99.5) 13681.25 BALANCE WT GHAT

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

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

Section 132(4A) of the Act and hence these notings on stand-alone basis would have entailed substantial tax liabilities on him. However, according to the Ld. AR, what Shri CPA did not foresee was that he would be faced with consequences under other regulations such as PMLA, FEMA violations etc. as well. The Ld. AR submitted that, the Revenue

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

Section\n132(4A) of the Act and hence these notings on stand-alone basis would\nhave entailed substantial tax liabilities on him. However, according to the\nLd. AR, what Shri CPA did not foresee was that he would be faced with\nconsequences under other regulations such as PMLA, FEMA violations etc.\nas well. The Ld. AR submitted that, the Revenue

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

Section\n132(4A) of the Act and hence these notings on stand-alone basis would\nhave entailed substantial tax liabilities on him. However, according to the\nLd. AR, what Shri CPA did not foresee was that he would be faced with\nconsequences under other regulations such as PMLA, FEMA violations etc.\nas well. The Ld. AR submitted that, the Revenue