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

153C of the Act requiring it to\nsubmit a true and correct return of its total income for AY 2011-\n12. The aforesaid notice was followed by a communication dated 22\nDecember 2022 under Section 142(1) requiring the petitioner to\nproduce accounts and documents as per the annexure appended\nthereto. A follow-up notice under Section

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

153C of the Act requiring it to\nsubmit a true and correct return of its total income for AY 2011-\n12. The aforesaid notice was followed by a communication dated 22\nDecember 2022 under Section 142(1) requiring the petitioner to\nproduce accounts and documents as per the annexure appended\nthereto. A follow-up notice under Section

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 were identical in both the AYs 2018-19 & 2019 19 & 2019-20 impugned before us. Both the parties have Both the parties have also argued these appeals together. eals together. Hence, for the sake of convenience, Hence, for the sake of convenience, ITA Nos.1613 to 1615 1613 to 1615 /Chny/2025 & ITA Nos.1547 & 1548/Chny/2025 ITA Nos.1547 & 1548/Chny/2025

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 were identical in both the AYs 2018-19 & 2019 19 & 2019-20 impugned before us. Both the parties have Both the parties have also argued these appeals together. eals together. Hence, for the sake of convenience, Hence, for the sake of convenience, ITA Nos.1613 to 1615 1613 to 1615 /Chny/2025 & ITA Nos.1547 & 1548/Chny/2025 ITA Nos.1547 & 1548/Chny/2025

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 were identical in both the AYs 2018-19 & 2019 19 & 2019-20 impugned before us. Both the parties have Both the parties have also argued these appeals together. eals together. Hence, for the sake of convenience, Hence, for the sake of convenience, ITA Nos.1613 to 1615 1613 to 1615 /Chny/2025 & ITA Nos.1547 & 1548/Chny/2025 ITA Nos.1547 & 1548/Chny/2025

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 were identical in both the AYs 2018-19 & 2019 19 & 2019-20 impugned before us. Both the parties have Both the parties have also argued these appeals together. eals together. Hence, for the sake of convenience, Hence, for the sake of convenience, ITA Nos.1613 to 1615 1613 to 1615 /Chny/2025 & ITA Nos.1547 & 1548/Chny/2025 ITA Nos.1547 & 1548/Chny/2025

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. Apart from the\nforegoing, the AO is also noted to have made addition(s)/disallowance(s)\non account of deduction(s) claimed u/s 80G / 80GGB, disallowance u/s\n14A of the Act and disallowance of certain items of expenses.\n3. Aggrieved by the above order(s) of the AO, the assessee preferred\nappeal before

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. Apart from the\nforegoing, the AO is also noted to have made addition(s)/disallowance(s)\non account of deduction(s) claimed u/s 80G / 80GGB, disallowance u/s\n14A of the Act and disallowance of certain items of expenses.\n3.\nAggrieved by the above order(s) of the AO, the assessee preferred\nappeal before

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. Apart from the\n:: 4 ::\nITA Nos.1254, 1255, 1258, 1260/Chny/2025 &\nITA Nos.1233, 1235, 1237, 1238/Chny/2025\n(AYs 2014-15 to 2017-18)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\nforegoing, the AO is also noted to have made addition(s)/disallowance(s)\non account of deduction(s) claimed u/s 80G / 80GGB, disallowance u/s\n14A of the Act and 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

bogus purchases. Apart from the\n:: 3 ::\nITA Nos.1254, 1255, 1258, 1260/Chny/2025 &\nITA Nos.1233, 1235, 1237, 1238/Chny/2025\n(AYs 2014-15 to 2017-18)\nM/s. Southern Agrifurane Industries Pvt. Ltd.\nforegoing, the AO is also noted to have made addition(s)/disallowance(s)\non account of deduction(s) claimed u/s 80G / 80GGB, disallowance u/s\n14A of the Act and disallowance

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 for all years was not justified due to weak footing and lack of conclusive evidence. While acknowledging accounting deficiencies, the Tribunal agreed with the CIT(A) that a 10% estimation of profit on turnover was appropriate for the rejected books of accounts. The disallowance of CSR contributions was also deleted.", "result": "Partly Allowed", "sections": [ "139", "153C

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

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 across ten years was not justified. The Tribunal also noted that statements alone cannot be conclusive proof and that the suppliers were genuine. However, the Tribunal agreed with the rejection of books of accounts and estimated profit at 10% of turnover, partially allowing the appeal.", "result": "Partly Allowed", "sections": [ "139", "143(2)", "143(3)", "153C

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

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 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