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

142(1) of the Act dated 14 ct dated 14-01- 2023 in the course of assessment proceedings conducted u/s 153C of the 2023 in the course of assessment proceedings conducted u/s 153C of the 2023 in the course of assessment proceedings conducted u/s 153C of the Act and pointed out that, the AO had identified the specific seized

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

142(1) of the Act dated 14 ct dated 14-01- 2023 in the course of assessment proceedings conducted u/s 153C of the 2023 in the course of assessment proceedings conducted u/s 153C of the 2023 in the course of assessment proceedings conducted u/s 153C of the Act and pointed out that, the AO had identified the specific seized

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 CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Section 142(1) of the Act was\nthereafter issued on 01 February 2023. It is alleged by the\nrespondents that since the petitioner did not respond to the aforesaid\ncommunications, they were constrained to issue notices under\nSection 144 of the Act and which were dated 22 February 2023 and\n03 March 2023. In response to the aforesaid, the petitioner

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

Section 142(1) of the Act was\nthereafter issued on 01 February 2023. It is alleged by the\nrespondents that since the petitioner did not respond to the aforesaid\ncommunications, they were constrained to issue notices under\nSection 144 of the Act and which were dated 22 February 2023 and\n03 March 2023. In response to the aforesaid, the petitioner

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

142(1) of the Act were issued to the assessee calling for details of cash deposits during demonetization period. In response to notices, the assessee filed the details through e-proceedings. In support of the demonetization deposits the assessee submitted sales ledger, cash book, stock and VAT returns along with detailed statement of month wise cash deposits to the bank

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

142. The Ld. CIT(A) has elaborately discussed this aspect in paras 6.6.4 to 6.6.7 of his order. Accordingly, the deletion of the additions made under section 69A of Rs. 39,22,000, section 69C of Rs. 42,30,000, and Rs. 81,230 under section 69A is upheld, and the corresponding grounds of appeal filed by the Revenue

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

142. The Ld. CIT(A) has elaborately discussed this aspect in paras 6.6.4 to 6.6.7 of his order. Accordingly, the deletion of the additions made under section 69A of Rs. 39,22,000, section 69C of Rs. 42,30,000, and Rs. 81,230 under section 69A is upheld, and the corresponding grounds of appeal filed by the Revenue

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 is Rs.4,41,70,464/- for the F.Y 2017-18 (From July\n2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for\nthe F.Y. 2019-20 (up to 4.8.2019).\nThe above seized materials were handed over to the undersigned on\n18.06.2021. On perusal of the seized material I am satisfied that

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 is Rs.4,41,70,464/- for the F.Y 2017-18 (From July\n2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for\nthe F.Y. 2019-20 (up to 4.8.2019).\nThe above seized materials were handed over to the undersigned on\n18.06.2021. On perusal of the seized material I am satisfied that

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 is Rs.4,41,70,464/- for the F.Y 2017-18 (From July\n2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for\nthe F.Y. 2019-20 (up to 4.8.2019).\nThe above seized materials were handed over to the undersigned on\n18.06.2021. On perusal of the seized material I am satisfied that

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 is Rs.4,41,70,464/- for the F.Y 2017-18 (From July\n2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for\nthe F.Y. 2019-20 (up to 4.8.2019).\nThe above seized materials were handed over to the undersigned on\n18.06.2021. On perusal of the seized material I am satisfied that

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

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

142 has\nbeen issued to him, or\n(b) a return of income has been furnished by such other person\nbut no notice under sub-section (2) of section 143 has been\nserved and limitation of serving the notice under sub-section\n(2) of section 143 has expired, or\n(c) assessment or reassessment, if any, has been made

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

142 has been issued to him, or (b) a return of income has been furnished by such other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date

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

142 has been issued to him, or (b) a return of income has been furnished by such other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date

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

142 has been issued to him, or (b) a return of income has been furnished by such other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date

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

142 has been issued to him, or (b) a return of income has been furnished by such other person but no notice under sub-section (2) of section 143 has been served and limitation of serving the notice under sub-section (2) of section 143 has expired, or (c) assessment or reassessment, if any, has been made, before the date