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

149(1)(b) of the new regime, at the stage of issuance of notice\nunder section 148 of the new regime i.e. 30.03.2023. Having regard to\nthe legal principles, as already discussed elaborately while adjudicating\nthe Revenue's appeal for AY 2013-14, we are required to first ascertain\nwhether AYs 2014-15 to 2016-17 could have been reopened

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

149(1)(b) of the new regime, at the stage of issuance of notice\nunder section 148 of the new regime i.e. 30.03.2023. Having regard to\nthe legal principles, as already discussed elaborately while adjudicating\nthe Revenue's appeal for AY 2013-14, we are required to first ascertain\nwhether AYs 2014-15 to 2016-17 could have been reopened

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

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

149(1)(b) of the new regime, at the stage of issuance of notice\nunder section 148 of the new regime i.e. 30.03.2023. Having regard to\nthe legal principles, as already discussed elaborately while adjudicating\nthe Revenue's appeal for AY 2013-14, we are required to first ascertain\nwhether AYs 2014-15 to 2016-17 could have been reopened

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

149(1)(b) of the new regime, at the stage of issuance of notice\nunder section 148 of the new regime i.e. 30.03.2023. Having regard to\nthe legal principles, as already discussed elaborately while adjudicating\nthe Revenue's appeal for AY 2013-14, we are required to first ascertain\nwhether AYs 2014-15 to 2016-17 could have been reopened

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

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

b) bogus supplies wherein\nonly invoices were recorded without GRN because there was no actual\nmovement of goods. In support of this inference, the AO also undertook\nextensive analysis of hologram utilization across the years and relied\nupon the statement(s) obtained from the key persons of these vendors in\nthe course of the search/survey action conducted upon them

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

b) bogus supplies wherein\nonly invoices were recorded without GRN because there was no actual\nmovement of goods. In support of this inference, the AO also undertook\nextensive analysis of hologram utilization across the years and relied\nupon the statement(s) obtained from the key persons of these vendors in\nthe course of the search/survey action conducted upon them

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

b) bogus supplies wherein\nonly invoices were recorded without GRN because there was no actual\nmovement of goods. In support of this inference, the AO also undertook\nextensive analysis of hologram utilization across the years and relied\nupon the statement(s) obtained from the key persons of these vendors in\nthe course of the search/survey action conducted upon them

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

b) bogus supplies wherein\nonly invoices were recorded without GRN because there was no actual\nmovement of goods. In support of this inference, the AO also undertook\nextensive analysis of hologram utilization across the years and relied\nupon the statement(s) obtained from the key persons of these vendors in\nthe course of the search/survey action conducted upon them

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

b) bogus supplies wherein\nonly invoices were recorded without GRN because there was no actual\nmovement of goods. In support of this inference, the AO also undertook\nextensive analysis of hologram utilization across the years and relied\nupon the statement(s) obtained from the key persons of these vendors in\nthe course of the search/survey action conducted upon them

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

B. Sivaprasad (B.S. Prasad). With respect to the proposed addition under section 69A, the assessee clarified that these funds were mobilized through Shri B.S. Prasad and were not a personal loan granted by him. Shri B.S. Prasad acted merely as a facilitator or mediator to mobilize funds due to business exigencies. The assessee further drew attention to the deposition

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

B. Sivaprasad (B.S. Prasad). With respect to the proposed addition under section 69A, the assessee clarified that these funds were mobilized through Shri B.S. Prasad and were not a personal loan granted by him. Shri B.S. Prasad acted merely as a facilitator or mediator to mobilize funds due to business exigencies. The assessee further drew attention to the deposition

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

149, section 151 and section 153,\nwhere the Assessing Officer is satisfied that -\n(a) any money, bullion, Jewellery or other valuable article or thing\nseized or requisitioned, \"belongs to, or\n(b) any books of account or documents, seized or requisitioned, pertains\nor pertain to, or any information contained therein, relates to,\na person other than the person referred

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

149, section 151 and section 153,\nwhere the Assessing Officer is satisfied that -\n(a) any money, bullion, Jewellery or other valuable article or thing\nseized or requisitioned, “belongs to, or\n(b) any books of account or documents, seized or requisitioned, pertains\nor pertain to, or any information contained therein, relates to,”\na person other than the person referred

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

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

149, section 151 and section 153, in\nthe case of a person where a search is initiated under section\n:- 8 -:\n132 or books of account, other documents or any assets are\nrequisitioned under section 132A after the 31st day of May,\n2003, the Assessing Officer shall—\n(a) issue notice to such person requiring him to furnish within\nsuch