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

3, 13,75,315/- & Rs. 37,97,84,300/ & Rs. 37,97,84,300/- for the AY 2020-21 and Rs.56,41,82,236/ 21 and Rs.56,41,82,236/- & Rs. 58,23,45,992/-for the AY(s) 2021 for the AY(s) 2021-22 & 2022-23 being the bogus purchases as income of being the bogus purchases

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

3, 13,75,315/- & Rs. 37,97,84,300/ & Rs. 37,97,84,300/- for the AY 2020-21 and Rs.56,41,82,236/ 21 and Rs.56,41,82,236/- & Rs. 58,23,45,992/-for the AY(s) 2021 for the AY(s) 2021-22 & 2022-23 being the bogus purchases as income of being the bogus purchases

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

3, 13,75,315/- & Rs. 37,97,84,300/ & Rs. 37,97,84,300/- for the AY 2020-21 and Rs.56,41,82,236/ 21 and Rs.56,41,82,236/- & Rs. 58,23,45,992/-for the AY(s) 2021 for the AY(s) 2021-22 & 2022-23 being the bogus purchases as income of being the bogus purchases

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

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

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

purchases are wholly bogus and should be disallowed is rejected. Additions under Sections 69A and 69C: 133. Regarding the additions made under sections 69A and 69C, the assessee has demonstrated that all such amounts are fully explained in the cash flow statement. All heads of income, other than the :- 55 -: ITA Nos.1881, 1882 & 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service

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

purchases are wholly bogus and should be disallowed is rejected. Additions under Sections 69A and 69C: 133. Regarding the additions made under sections 69A and 69C, the assessee has demonstrated that all such amounts are fully explained in the cash flow statement. All heads of income, other than the :- 55 -: ITA Nos.1881, 1882 & 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service

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

purchases are wholly bogus and should be\ndisallowed is rejected.\nAdditions under Sections 69A and 69C:\n133. Regarding the additions made under sections 69A and 69C, the\nassessee has demonstrated that all such amounts are fully explained\nin the cash flow statement. All heads of income, other than the\nestimated profits offered for taxation, which surfaced as a result

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

purchases are wholly bogus and should be\ndisallowed is rejected.\nAdditions under Sections 69A and 69C:\n133. Regarding the additions made under sections 69A and 69C, the\nassessee has demonstrated that all such amounts are fully explained\nin the cash flow statement. All heads of income, other than the\n:- 54 -:\nITA Nos.1881, 1882 & 1883/Chny/2025\nITA Nos.1874, 1876 & 1879/Chny/2025\nIntegrated

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

purchases are wholly bogus and should be\ndisallowed is rejected.\nAdditions under Sections 69A and 69C:\n133. Regarding the additions made under sections 69A and 69C, the\nassessee has demonstrated that all such amounts are fully explained\nin the cash flow statement. All heads of income, other than the\n- : 55 -:\nITA Nos.1881, 1882 & 1883/Chny/2025\nITA Nos.1874, 1876 & 1879/Chny/2025\nIntegrated

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

purchases are wholly bogus and should be\ndisallowed is rejected.\nAdditions under Sections 69A and 69C:\n133. Regarding the additions made under sections 69A and 69C, the\nassessee has demonstrated that all such amounts are fully explained\nin the cash flow statement. All heads of income, other than the\n:- 54 -:\nITA Nos.1881, 1882 & 1883/Chny/2025\nITA Nos.1874, 1876 & 1879/Chny/2025\nIntegrated

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

section 40A(3) of the Act. Thus, the ground raised by the Revenue is dismissed for all the assessment year under appeal. 12. With regard to bogus purchase of copra, in the assessment for the assessment year 2013-14, the Assessing Officer has observed as under: 7. Bogus Purchase of copra: On verification, it is found that Shri.Shajahan has played

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

section 40A(3) of the Act. Thus, the ground raised by the Revenue is dismissed for all the assessment year under appeal. 12. With regard to bogus purchase of copra, in the assessment for the assessment year 2013-14, the Assessing Officer has observed as under: 7. Bogus Purchase of copra: On verification, it is found that Shri.Shajahan has played

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

section 40A(3) of the Act. Thus, the ground raised by the Revenue is dismissed for all the assessment year under appeal. 12. With regard to bogus purchase of copra, in the assessment for the assessment year 2013-14, the Assessing Officer has observed as under: 7. Bogus Purchase of copra: On verification, it is found that Shri.Shajahan has played

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

section 40A(3) of the Act. Thus, the ground raised by the Revenue is dismissed for all the assessment year under appeal. 12. With regard to bogus purchase of copra, in the assessment for the assessment year 2013-14, the Assessing Officer has observed as under: 7. Bogus Purchase of copra: On verification, it is found that Shri.Shajahan has played