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

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

13. Thus, the information in the seized materials and other evidences available with the undersigned, unambiguously evidenced that the assessee had booked bogus old bottle purchase expenses with the connivance of the five old bottle vendors thereby generating unaccounted cash which clearly suggests that income represented in the form of asset has escaped assessment, and exceeds more than

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 | The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit Assessee By : Mr. N. Arjun Raj, Advocate सुनवाईकीतारीख/Date Of Hearing : 08.10.2025 घोषणाकीतारीख / Date Of Pronouncement : 21.11.2025

13. Thus, the information in the seized materials and other evidences available with the undersigned, unambiguously evidenced that the assessee had booked bogus old bottle purchase expenses with the connivance of the five old bottle vendors thereby generating unaccounted cash which clearly suggests that income represented in the form of asset has escaped assessment, and exceeds more than

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] V. The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

13. Thus, the information in the seized materials and other evidences available with the undersigned, unambiguously evidenced that the assessee had booked bogus old bottle purchase expenses with the connivance of the five old bottle vendors thereby generating unaccounted cash which clearly suggests that income represented in the form of asset has escaped assessment, and exceeds more than

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit Assessee By : Mr. N. Arjun Raj, Advocate सुनवाईकीतारीख/Date Of Hearing : 08.10.2025 घोषणाकीतारीख / Date Of Pronouncement : 21.11.2025

13. Thus, the information in the seized materials and other evidences available with the undersigned, unambiguously evidenced that the assessee had booked bogus old bottle purchase expenses with the connivance of the five old bottle vendors thereby generating unaccounted cash which clearly suggests that income represented in the form of asset has escaped assessment, and exceeds more than

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 Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

13. Thus, the information in the seized materials and other evidences available with the undersigned, unambiguously evidenced that the assessee had booked bogus old bottle purchase expenses with the connivance of the five old bottle vendors thereby generating unaccounted cash which clearly suggests that income represented in the form of asset has escaped assessment, and exceeds more than

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

13. Thus, the information in the seized materials and other evidences available with the undersigned, unambiguously evidenced that the assessee had booked bogus old bottle purchase expenses with the connivance of the five old bottle vendors thereby generating unaccounted cash which clearly suggests that income represented in the form of asset has escaped assessment, and exceeds more than

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

bogus claim of refund of fees, all clearly proved diversion of funds to specified persons and Section 13(1) (c) of the Act stood attracted. Viz-a-viz, alleged specific instances falling within Section 22. 13(1) (c) of the Act, arguments taken by the ld. Departmental Representative are summarized here under:- (i) As for the payment of advance

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

bogus claim of refund of fees, all clearly proved diversion of funds to specified persons and Section 13(1) (c) of the Act stood attracted. Viz-a-viz, alleged specific instances falling within Section 22. 13(1) (c) of the Act, arguments taken by the ld. Departmental Representative are summarized here under:- (i) As for the payment of advance

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

bogus claim of refund of fees, all clearly proved diversion of funds to specified persons and Section 13(1) (c) of the Act stood attracted. Viz-a-viz, alleged specific instances falling within Section 22. 13(1) (c) of the Act, arguments taken by the ld. Departmental Representative are summarized here under:- (i) As for the payment of advance

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

bogus claim of refund of fees, all clearly proved diversion of funds to specified persons and Section 13(1) (c) of the Act stood attracted. Viz-a-viz, alleged specific instances falling within Section 22. 13(1) (c) of the Act, arguments taken by the ld. Departmental Representative are summarized here under:- (i) As for the payment of advance

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

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

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

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

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 Shuklaआयकर अपीलसं./Ita Nos.1817 To 1819/Chny/2025 निर्धारण वर्ष/Assessment Years: 2020-21 To 2022-23 The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1550 To 1552/Chny/2025 निर्धारणवर्ष/Assessment Years: 2020-21 To 2022-23 M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai – 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख / Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025 ::2 ::

1 to 66. It is noted that, this excel file comprised of five(5)sheets which comprised of data relating to purchase of old bottles for three-month period in the year 2020. The AO is noted to have tabulated sample data from this excel file at Para 4.1.4 of the assessment order. It is seen that, this data comprised