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

sections": [ "139", "153C", "132", "143(2)", "143(3)", "145(3)", "271AAD", "145", "144", "30", "43D", "29", "68", "69", "69C" ], "issues": "Whether the additions made by the AO towards alleged 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

sections": [ "139", "153C", "132", "143(2)", "143(3)", "145(3)", "271AAD", "144", "145", "40A(3)", "68", "69C", "29", "30", "43D" ], "issues": "Whether the addition made by the AO for 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

purchases were bogus was not sustainable. The Tribunal upheld the CIT(A)'s decision to reject the books of accounts and estimate profits at 10% of turnover, also dismissing the addition on CSR contributions.", "result": "Dismissed", "sections": [ "139", "153C", "132", "143(2)", "143(3)", "145(3)", "271AAD", "144

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

bogus purchases over ten years was not sustainable without further evidence. The Tribunal agreed with the CIT(A) that the books of account should be rejected and profits estimated. The Tribunal estimated the profit at 10% of the turnover.", "result": "Dismissed", "sections": [ "139", "153C", "132", "143(2)", "143(3)", "145(3)", "271AAD", "144

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

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

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

144 (Bombay) wherein\nthe Hon'ble high Court held that “A plain reading of section 153A(1)(b)\nshows that Commissioner having jurisdiction under the said section is\nempowered to assess or reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment

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

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

144 (Bombay) wherein\nthe Hon'ble high Court held that “A plain reading of section 153A(1)(b)\nshows that Commissioner having jurisdiction under the said section is\nempowered to assess or reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment

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

144 (Bombay) wherein\nthe Hon'ble high Court held that “A plain reading of section 153A(1)(b)\nshows that Commissioner having jurisdiction under the said section is\nempowered to assess or reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment

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

144 (Bombay) wherein\nthe Hon'ble high Court held that “A plain reading of section 153A(1)(b)\nshows that Commissioner having jurisdiction under the said section is\nempowered to assess or reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

bogus or untraceable creditors\nin the books. There are no mismatches between purchase entries and\npayment trails. There are no GST discrepancies or phantom outward tax\nliabilities arising from non-existent inward supplies. The cash book does\nnot show negative balances at any point. The complete absence of such\nanomalies conclusively demonstrates that unbilled cash purchases were\nnever recorded

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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or Section 153A(1)(b) states that the assessing officer shall assess or reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income

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

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

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

144 (Bombay) wherein\nthe Hon'ble high Court held that \"A plain reading of section 153A(1)(b)\nshows that Commissioner having jurisdiction under the said section is\nempowered to assess or reassess the total income of six years\nimmediately preceding the assessment year relevant to the previous\nyear in which the search was conducted and for the relevant assessment