ACIT, NUNGAMBAKKAM 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. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (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 Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (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 : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

4) is final and wholly persuasive is, therefore, unsustainable. Ground No. 7 of the Revenue is dismissed. Ground No. 2: 94. Ground No. 2, in a combined manner, challenges all the relief granted by the Ld. CIT(A) and relates to the addition of inflated transportation expenses amounting to Rs.2,28,02,100/- and unaccounted income of Rs.75

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 -:

4) is final and wholly persuasive is, therefore, unsustainable. Ground No. 7 of the Revenue is dismissed. Ground No. 2: 94. Ground No. 2, in a combined manner, challenges all the relief granted by the Ld. CIT(A) and relates to the addition of inflated transportation expenses amounting to Rs.2,28,02,100/- and unaccounted income of Rs.75

DCIT , CENTRAL CIRCLE - 3, COIMBATORE vs. SHRI D VIJAY MOHAN, COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

purchase of property, which has been added by the AO and confirmed by the Ld. CIT(A). From the facts available before us, it is not in dispute that, the notings denotes that the sum of Rs.96 lacs was due and it nowhere suggests that it had been later on paid by the assessee. It is also not the Revenue

VIJAY MOHAN,COIMBAORE vs. DCIT, CENTRAL CIRCLE-(3)(I/C), COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

purchase of property, which has been added by the AO and confirmed by the Ld. CIT(A). From the facts available before us, it is not in dispute that, the notings denotes that the sum of Rs.96 lacs was due and it nowhere suggests that it had been later on paid by the assessee. It is also not the Revenue

VANITHA MOHAN,COIMBATORE vs. DCIT CENTRAL CIRCLE-3, COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

purchase of property, which has been added by the AO and confirmed by the Ld. CIT(A). From the facts available before us, it is not in dispute that, the notings denotes that the sum of Rs.96 lacs was due and it nowhere suggests that it had been later on paid by the assessee. It is also not the Revenue

DCIT , CENTRAL CIRCLE - 3, COIMBATORE vs. SMT.VANITHA MOHAN, COIMBATRE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

purchase of property, which has been added by the AO and confirmed by the Ld. CIT(A). From the facts available before us, it is not in dispute that, the notings denotes that the sum of Rs.96 lacs was due and it nowhere suggests that it had been later on paid by the assessee. It is also not the Revenue

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

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

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

SUBBAIAH VAIRAMANI,MADURAI vs. ACIT, CORPORATE CIRCLE-1, MADURAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2380/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Subbaiah Vairamani, Vs. The Assistant Commissioner Of 134, North Market Street, Income Tax, Madurai 625 001. Corporate Circle 1, [Pan:Abrpv9397H] Madurai 625 002. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Venkata Raman, C.A. & Shri R.S. Lakshmi Narayana, Advocate ""थ" की ओर से/Respondent By : Shri C. Murugesan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.02.2025 घोषणा की तारीख /Date Of Pronouncement : 07.03.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 24 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

134, North Market Street, Income Tax, Madurai 625 001. Corporate Circle 1, [PAN:ABRPV9397H] Madurai 625 002. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri R. Venkata Raman, C.A., & Shri R.S. Lakshmi Narayana, Advocate ""थ" की ओर से/Respondent by : Shri C. Murugesan, Addl. CIT सुनवाई की तारीख/ Date of hearing : 06.02.2025 घोषणा की तारीख /Date

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

134,29,66,360/-\n2019-20 ₹139,74,81,200/-\n2020-21 ₹188,82,39,920/-\n2021-22 ₹286,51,12,790/-\n3. Search u/s 132 of the Income Tax Act, 1961 (hereinafter referred to\nas \"the Act\") was conducted in the group cases of the assessee,\nM/s.Lalithaa Jewellery Mart Pvt Ltd. (in short ‘LJMPL’), on 04-03-2021\nthereby

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

4) of the Act that, he did not have any business transactions with Shri Gobi and that he was his personal friend, who simply happened to be distant relative of the assessee. He invited our attention to the answer given by Shri CPA at Q No. 19 of his statement dated 02.07.2016 that, he had got some favors/promotion/transfer work

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

section 47(xiv) have been fulfilled by the assessee. The Ld.AR has contended that the same is not affected by the provisions of section 49(1)(iii)(e) of the Act. In this view of the matter, the issue is that of interpretation of the proviso to section 47(xiv) of the Act. The revenue has filed this appeal

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

4 to 8 Ground Nos. 4 to 8 stands allowed. 4.28 Since on merits, we have decided the issue in favour of the Since on merits, we have decided the issue in favour of the Since on merits, we have decided the issue in favour of the assessee, the Ground N Ground Nos.1 to 3 raised challenging the legal validity

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

4 to 8 Ground Nos. 4 to 8 stands allowed. 4.28 Since on merits, we have decided the issue in favour of the Since on merits, we have decided the issue in favour of the Since on merits, we have decided the issue in favour of the assessee, the Ground N Ground Nos.1 to 3 raised challenging the legal validity

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

4 to 8 Ground Nos. 4 to 8 stands allowed. 4.28 Since on merits, we have decided the issue in favour of the Since on merits, we have decided the issue in favour of the Since on merits, we have decided the issue in favour of the assessee, the Ground N Ground Nos.1 to 3 raised challenging the legal validity

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

4) of the Act that,\nhe did not have any business transactions with Shri Gobi and that he was\nhis personal friend, who simply happened to be distant relative of the\nassessee. He invited our attention to the answer given by Shri CPA at Q\nNo. 19 of his statement dated 02.07.2016 that, he had got some\nfavors/promotion/transfer work