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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita Nos. 1613 To 1615/Chny/2025 िनधा"रणवष"/Assessment Years: 2018-19 & 2019-20

bogus purchases. Consequent to the rejection of books of accounts and estimation of Consequent to the rejection of books of accounts and estimation of Consequent to the rejection of books of accounts and estimation of profits, the Ld. CIT(A) deleted all other separate disallowance(s)/ profits, the Ld. CIT(A) deleted all other separate disallowance(s)/ profits

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

bogus purchases. Consequent to the rejection of books of accounts and estimation of Consequent to the rejection of books of accounts and estimation of Consequent to the rejection of books of accounts and estimation of profits, the Ld. CIT(A) deleted all other separate disallowance(s)/ profits, the Ld. CIT(A) deleted all other separate disallowance(s)/ profits

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

purchaser and developer of the land of 196.97 Acres. However, the assessee accepted the receipts of interest for Rs35 Crores as per the agreement made dated 29.12.2006 which was calculated on pro rata basis. But in connection with this interest income, the assessee claimed it as a capital receipt and hence it should not be treated as revenue receipt

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

purchaser and developer of the land of 196.97 Acres. However, the assessee accepted the receipts of interest for Rs35 Crores as per the agreement made dated 29.12.2006 which was calculated on pro rata basis. But in connection with this interest income, the assessee claimed it as a capital receipt and hence it should not be treated as revenue receipt

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

purchaser and developer of the land of 196.97 Acres. However, the assessee accepted the receipts of interest for Rs35 Crores as per the agreement made dated 29.12.2006 which was calculated on pro rata basis. But in connection with this interest income, the assessee claimed it as a capital receipt and hence it should not be treated as revenue receipt

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

purchaser and developer of the land of 196.97 Acres. However, the assessee accepted the receipts of interest for Rs35 Crores as per the agreement made dated 29.12.2006 which was calculated on pro rata basis. But in connection with this interest income, the assessee claimed it as a capital receipt and hence it should not be treated as revenue receipt

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

Section 153C.\nThe power to undertake such an assessment would stand confined to\nthose years to which the material may relate or is likely to influence.\nAbsent any material that may either cast a doubt on the estimation of\ntotal income for a particular year or years, the AO would not be justified\n:: 41 ::\nITA Nos.1254, 1255, 1258, 1260/Chny/2025

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

bogus purchases. Apart from the gus purchases. Apart from the ITA Nos.1254, 1255, 1258, 1260 1254, 1255, 1258, 1260/Chny/2025 & ITA Nos.1233, 1235, 1237, 1238 1233, 1235, 1237, 1238/Chny/2025 (AYs 2014 s 2014-15 to 2017-18) Southern Agrifurane Industries Pvt. Ltd. M/s. Southern Agrifurane Industries Pvt :: 4 :: foregoing, the AO is also noted to have made addition(s)/disallowance

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

bogus purchases. Apart from the gus purchases. Apart from the ITA Nos.1254, 1255, 1258, 1260 1254, 1255, 1258, 1260/Chny/2025 & ITA Nos.1233, 1235, 1237, 1238 1233, 1235, 1237, 1238/Chny/2025 (AYs 2014 s 2014-15 to 2017-18) Southern Agrifurane Industries Pvt. Ltd. M/s. Southern Agrifurane Industries Pvt :: 4 :: foregoing, the AO is also noted to have made addition(s)/disallowance

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 153C.\nThe power to undertake such an assessment would stand confined to\nthose years to which the material may relate or is likely to influence.\nAbsent any material that may either cast a doubt on the estimation of\ntotal income for a particular year or years, the AO would not be justified\n:: 41 ::\nITA Nos.1254, 1255, 1258, 1260/Chny/2025

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 14A(2) of the Act. We find force in the arguments of the ld. Counsel for the assessee that the disallowance under Rule 8D(2)(iii) has to be restricted at 0.5% of investments, which has actually yielded exempt income during the year after reducing suo motu disallowance made by the assessee and not the average of investments

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 14A(2) of the Act. We find force in the arguments of the ld. Counsel for the assessee that the disallowance under Rule 8D(2)(iii) has to be restricted at 0.5% of investments, which has actually yielded exempt income during the year after reducing suo motu disallowance made by the assessee and not the average of investments

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

14A of the Act before introduction of Rule 8D of Income-tax Rules, 1962 at 2%. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee. 63. We have heard Shri G. Baskar, the Ld.counsel for the assessee, also. It is not in dispute that Rule 8D is not applicable for the year under consideration

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

14A of the Act before introduction of Rule 8D of Income-tax Rules, 1962 at 2%. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee. 63. We have heard Shri G. Baskar, the Ld.counsel for the assessee, also. It is not in dispute that Rule 8D is not applicable for the year under consideration

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

14A of the Act before introduction of Rule 8D of Income-tax Rules, 1962 at 2%. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee. 63. We have heard Shri G. Baskar, the Ld.counsel for the assessee, also. It is not in dispute that Rule 8D is not applicable for the year under consideration

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

14A of the Act before introduction of Rule 8D of Income-tax Rules, 1962 at 2%. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee. 63. We have heard Shri G. Baskar, the Ld.counsel for the assessee, also. It is not in dispute that Rule 8D is not applicable for the year under consideration

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

14A of the Act before introduction of Rule 8D of Income-tax Rules, 1962 at 2%. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee. 63. We have heard Shri G. Baskar, the Ld.counsel for the assessee, also. It is not in dispute that Rule 8D is not applicable for the year under consideration

M/S. STERLITE INDUSTRIES (INDIA) LTD.,MADURAI vs. ADDITIONAL CIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

14A of the Act before introduction of Rule 8D of Income-tax Rules, 1962 at 2%. Therefore, the CIT(Appeals) is not justified in allowing the claim of the assessee. 63. We have heard Shri G. Baskar, the Ld.counsel for the assessee, also. It is not in dispute that Rule 8D is not applicable for the year under consideration