MIDAS GOLDEN DISTILLERIES P. LTD ,SRIPERUMBUDUR vs. OFFICE OF THE DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM

In the result, the appeal of the assessee is dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.2955/Chny/2024, Assessment Years: 2014-15

bogus purchases were siphoned off from the system and in turn handed over to the assessee Company in lieu of over invoicing of sales done to the assessee apparently collected by him / his employees/ business concerns so as to meet certain incidental expenses which are peculiar to this line of business. Shri K.Karthikeyan also furnished the quantitative details of bottles

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

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

ARUNRAJ,ERODE vs. ACIT, CENTRAL CIRC 3, CBE, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

EVERYEADY SPINNING MILLS PRIVATE LIMITED,TRIUPUR vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

SEETHADEVI,ERODE vs. ACIT, CENTRAL CIRCLE-3, , COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

VADIAPPAN SENTHILMURUGAN,ERODE vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

SUNDARASAMY KOHILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

133A, other than under sub-section (2A) or sub- section (5) of that section, on or after the 1st day of April, 2021, in the case of the assessee; or (iii) the Assessing Officer is satisfied, with the prior approval of the Principal Commissioner or Commissioner, that any money, bullion, jewellery or other valuable article or thing, seized or requisitioned

PRAMILA PATEL,,CHENNAI vs. ITO, NCW - 10 (3),, CHENNAI

In the result, the appeal filed by the assessee stands

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. No.1827/Chny/2019. "नधा"रण वष" /Assessment Year : 2009-2010. Vs. The Income Tax Officer, Pramila Patel, No.27, Gnt Road, Non Corporate Ward 10(3) Puzhal, Chennai. Chennai 600 066. [Pan Aeipp 1044H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

133A was conducted in the premises of Smt. Leela Surana on 26/11/2009 and she admitted that she received cash payments from the appellant. She also clearly mentioned the date and amount for which bogus contract notes were issued. These details are mentioned in the assessment order. Appellant claimed income from Long Term Capital Gains which are exempt under section

S.P.MANI AND MOHAN DAIRY,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, both the appeals filed by assessee and revenue are allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

Section 41(1)(a) of the 1961 Act mainly on the allegation that the assessee has inflated purchases in its books of accounts wherein bogus purchases were introduced by assessee in its books of accounts or else payments were made to creditors for milk supplies out of undisclosed income of the assessee which did not get routed through books

DEPUTY COMMISSIONER OF INCOME-TAX, COIMBATORE vs. MS VISWA AND DEVJI DIAMONDS PVT LTD, COIMBATORE

In the result, appeal filed by the Revenue stands dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.327/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-2018. The Deputy Commissioner Viswa & Devji Diamonds Pvt Ltd, Of Income Tax, Vs. New No.16,Old No.239, Corporate Circle 1, T.V.Swamy Road (East) Coimbatore R.S. Puram, Coimbatore 641 002. Pan: Aaccv 4942M

section 69A of the IT Act 1961, where in any financial year the assessee is found to be the owner of any money, bullion, jewelry or other valuable article and such money, bullion, jewelry or valuable article is not recorded in the books of account, if any, maintained by him for any source of income, and the assessee offers

SELVA GOLD COVERING P LTD.,CHENNAI vs. DCIT, COIMBATORE

In the result, the appeal filed by the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita No.3262/Mds/2016 "नधा"रण वष" / Assessment Year : 2012-13 M/S Selva Gold Covering Pvt. Ltd., C/O Shri S. Sridhar, The Deputy Commissioner Of Sh. A.S. Sriraman, Advocate , V. Income Tax, New No.14, Old No.82, Flat No.5, Corporate Circle – 2, 1St Avenue, Indira Nagar, Adyar, Coimbatore. Chennai - 600 020. Pan : Aadcs 0688 Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

bogus purchase in its accounts and suppressed sales, according to the Ld. D.R., the Assessing Officer has rightly levied penalty under Section 271(1)(c) of the Act which was also confirmed by the CIT(Appeals). 7. We have considered the rival submissions on either side and perused the relevant material available on record. The assessee is engaged

DCIT,NCC 7(1),, CHENNAI vs. RAJU SARAVANAN, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.272/Chny/2021 िनधा'रण वष' /Assessment Year: 2017-18 The Dy. Commissioner Of Shri Raju Saravanan, Income Tax, No.8, G-3 Santham Apts., Thamarai Nagar, 2Nd Street, Non Corporate Circle-7(1), Vs. Chennai. Thirumullaivoyal, Chennai – 600 062. [Pan: Bbcps-8286-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ) की ओर से/ Assessee By : Shri G. Baskar, Advocate & Shri I. Dinesh, Advocate +,थ) की ओर से /Revenue By : Shri Arv Sreenivasan, Addl. Cit : 08.06.2023 सुनवाई क" तारीख/Date Of Hearing घोषणा क" तारीख /Date Of Pronouncement : 28.06.2023 आदेश / O R D E R Per Manomohan Das, J.M: This Appeal Filed By The Revenue Is Directed Against The Order Of The Learned Commissioner Of Income Tax (Appeals), Chennai [Cit(A) Dated 18-09-2020 & Pertains To Assessment Year (Ay) 2017-18. The Revenue Has Raised The Following Ground Of Appeal:- “The Learned Cit-A Has Erred In Not Providing An Opportunity To The Ao Under Rule 46A As New Evidence Was Submitted By The Assessee During The Course Of The Appellate Proceedings.” :- 2 -: 2. The Brief Facts Of The Case Are That The Assessee Is An Individual

Section 133A of the Act does not empower the Authorized Officer to record statement on oath. The object of the survey is to collect evidence and not confessional statement as the survey proceeding is different from the search proceeding. In this connection, the assessee relied on the judgment of the Hon’ble Kerala High Court. Regarding the cash deposit

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. LIFE LINE AUTO FINANCE, KARUR

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1630/Chny/2025 निर्धारण वर्ष / Assessment Year: 2013-14 Acit, Central Circle-2, Trichy. Vs. Life Line Auto Finance, 306-B1, First Floor, Bharathi Nagar, Mahatma Gandhi Road, Karur - 639 002. [Pan:Aaefl-7071-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. R. Venkata Raman, C.A. प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, C.I.T. सुनवाई की तारीख/Date Of Hearing : 11.11.2025 घोषणा की तारीख/Date Of Pronouncement : 20.01.2026 आदेश /Order Per S. R. Raghunatha, Am: The Present Appeal Of The Revenue Is Directed Against The Order Dated 21.03.2015 Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [Hereinafter Referred To As “The Ld.Cit(A)”], Arising Out Of The Assessment Order Dated 31.03.2022 Passed By The Deputy Commissioner Of Income Tax, Central Circle-2, Trichy (Hereinafter Referred To As “The Ao”] U/S.143(3) R.W.S 153C Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year 2013–14. :-2-:

133A, it may, in any proceeding under this Act, be presumed – (ii) that the contents of such books of account and other documents are true. 3. The Ld.CIT(A) erred in giving relief to the assessee by observing that material found in a third party premise was not in the handwriting of the assessee thereby ignoring section

DCIT, CENTRAL CIT-2(4), CHENNAI vs. A GANDHIMATHI, KANCHEEPURAM

In the result, appeals filed by the Revenue in ITA Nos

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.13-15/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 To 2014-15 The Dy. Commissioner Of- V. Smt. A. Gandhimathi, Income Tax, Prop: East West Gandhimathi Central Circle-2(4), Combined Industries, Investigation Building, Survey No.503/2A2A, Chennai. Mambakkam Salai, Echankadu, Kayar, Kancheepuram District. [Pan: Agupa 2409 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Department By : Mr.Guru Bashyam, Cit-Dr Assessee By : Mr.Philip George, Adv. सुनवाई क" तारीख/Date Of Hearing : 11.07.2022 घोषणा क" तारीख /Date Of Pronouncement : 10.10.2022

bogus purchases and accordingly disallowed. 5. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee challenged the assessment order passed by the AO u/s.143(3) r.w.s.153C of the Act, on the ground that the conditions precedent for invoking provisions of Sec.153C of the Act, are not satisfied. Because

DCIT, CENTRAL CIT-2(4), CHENNAI vs. A GANDHIMATHI, KANCHEEPURAM

In the result, appeals filed by the Revenue in ITA Nos

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.13-15/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 To 2014-15 The Dy. Commissioner Of- V. Smt. A. Gandhimathi, Income Tax, Prop: East West Gandhimathi Central Circle-2(4), Combined Industries, Investigation Building, Survey No.503/2A2A, Chennai. Mambakkam Salai, Echankadu, Kayar, Kancheepuram District. [Pan: Agupa 2409 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Department By : Mr.Guru Bashyam, Cit-Dr Assessee By : Mr.Philip George, Adv. सुनवाई क" तारीख/Date Of Hearing : 11.07.2022 घोषणा क" तारीख /Date Of Pronouncement : 10.10.2022

bogus purchases and accordingly disallowed. 5. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee challenged the assessment order passed by the AO u/s.143(3) r.w.s.153C of the Act, on the ground that the conditions precedent for invoking provisions of Sec.153C of the Act, are not satisfied. Because