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

139 of the Act declaring total income of Rs.53,36,75,280/ the Act declaring total income of Rs.53,36,75,280/-, Rs.47,04,60,043/ , Rs.47,04,60,043/- and Rs.34,98,31,681/- respectively. It is noted that, a search action was respectively. It is noted that, a search action was conducted upon SNJ Group on 06 ducted

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\nassessee are dismissed

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

1 to\nSection 153A(1) of the Act, the Revenue can travel back ten years from\nthe end of the assessment year relevant to the previous year in which\nthe search under Section 132 was conducted or a requisition under\nSection 132A of the Act was made. Plainly, the said controversy is\nrequired to be addressed by referring to Section

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\nassessee are dismissed

Section 153A of the Act.\nSection 153A(1) of the Act is set out below:.......\n12. It is apparent from the above that Section 153A of the Act refers to\ntime periods within which the assessments could be reopened. In terms\nof Section 153A(1) of the Act, the assessments can be reopened for a\nblock of six years preceding

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

DCIT, CENTRAL CIRCLE 2(2), CHENNAI vs. N RAMASAMY, CHENNAI

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपील सं./I.T.A Nos.127 & 128/Chny/2019 िनधा"रण वष" /Assessment Years : 2015-2016 & 2016-2017 The Deputy Commissioner Of Vs. Shri. N. Ramasamy, Income Tax, No.14/19, Saraswathi Street, Central Circle 2(2), Mahaingapuram, Nungambakkam High Road, Chennai 600 034. Chennai 600 034. [Pan Adupr 8003P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Nilay Baran Som, Irs, Cit. ""यथ" क" ओर से /Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 18.12.2023. घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023 आदेश / O R D E R Per Mahavir Singh:

bogus. Under such circumstances, when the search proceedings have not revealed anything contrary or adverse with regard to the genuineness of the expenses, the addition made of Rs.3.36 Crores and 1.07 Crores are incorrect and therefore directed to be deleted. Accordingly, the corresponding Grounds of appeal are allowed’’. Aggrieved, now the Revenue is in appeal before us. We have heard

DCIT, CENTRAL CIRCLE 2(2), CHENNAI vs. N RAMASAMY, CHENNAI

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपील सं./I.T.A Nos.127 & 128/Chny/2019 िनधा"रण वष" /Assessment Years : 2015-2016 & 2016-2017 The Deputy Commissioner Of Vs. Shri. N. Ramasamy, Income Tax, No.14/19, Saraswathi Street, Central Circle 2(2), Mahaingapuram, Nungambakkam High Road, Chennai 600 034. Chennai 600 034. [Pan Adupr 8003P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Nilay Baran Som, Irs, Cit. ""यथ" क" ओर से /Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 18.12.2023. घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023 आदेश / O R D E R Per Mahavir Singh:

bogus. Under such circumstances, when the search proceedings have not revealed anything contrary or adverse with regard to the genuineness of the expenses, the addition made of Rs.3.36 Crores and 1.07 Crores are incorrect and therefore directed to be deleted. Accordingly, the corresponding Grounds of appeal are allowed’’. Aggrieved, now the Revenue is in appeal before us. We have heard

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

139 of\nthe Act declaring total income of Rs.53,36,75,280/-, Rs.47,04,60,043/-\nand Rs.34,98,31,681/- respectively. It is noted that, a search action was\nconducted upon SNJ Group on 06-08-2019 and in connection with the\nsame, the business premises of M/s Crystal Bottles was also searched\nwhere incriminating material relating

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

139 of\nthe Act declaring total income of Rs.53,36,75,280/-, Rs.47,04,60,043/-\nand Rs.34,98,31,681/- respectively. It is noted that, a search action was\nconducted upon SNJ Group on 06-08-2019 and in connection with the\nsame, the business premises of M/s Crystal Bottles was also searched\nwhere incriminating material relating

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

139 of\nthe Act declaring total income of Rs.53,36,75,280/-, Rs.47,04,60,043/-\nand Rs.34,98,31,681/- respectively. It is noted that, a search action was\nconducted upon SNJ Group on 06-08-2019 and in connection with the\nsame, the business premises of M/s Crystal Bottles was also searched\nwhere incriminating material relating

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

139 of\nthe Act declaring total income of Rs.53,36,75,280/-, Rs.47,04,60,043/-\nand Rs.34,98,31,681/- respectively. It is noted that, a search action was\nconducted upon SNJ Group on 06-08-2019 and in connection with the\nsame, the business premises of M/s Crystal Bottles was also searched\nwhere incriminating material relating

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

139 of\nthe Act declaring total income of Rs.53,36,75,280/-, Rs.47,04,60,043/-\nand Rs.34,98,31,681/- respectively. It is noted that, a search action was\nconducted upon SNJ Group on 06-08-2019 and in connection with the\nsame, the business premises of M/s Crystal Bottles was also searched\nwhere incriminating material relating

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 Unexplained money u/S Nil 39,22,000 39,22,000 69A and unexplained 42,30,000 42,30,000 expenditure u/S 69C Income on account of 1,97,03,000 Nil 1,97,03,000 Palakol land sale Misc. income on sale of 11,12,270 81,230 11,93,500 scrap, car, candy and pulp Total

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 Unexplained money u/S Nil 39,22,000 39,22,000 69A and unexplained 42,30,000 42,30,000 expenditure u/S 69C Income on account of 1,97,03,000 Nil 1,97,03,000 Palakol land sale Misc. income on sale of 11,12,270 81,230 11,93,500 scrap, car, candy and pulp Total