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 transactions.  Handling of SAP entries Handling of SAP entries to process invoices without valid supporting to process invoices without valid supporting documentation (e.g., missing GRN, no purchase orders). documentation (e.g., missing GRN, no purchase orders).  Failure to comply with stand Failure to comply with standard accounting procedures for genuine purchases.  The inability to substantiate purchases with proper documentation

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 transactions.  Handling of SAP entries Handling of SAP entries to process invoices without valid supporting to process invoices without valid supporting documentation (e.g., missing GRN, no purchase orders). documentation (e.g., missing GRN, no purchase orders).  Failure to comply with stand Failure to comply with standard accounting procedures for genuine purchases.  The inability to substantiate purchases with proper documentation

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 transactions.  Handling of SAP entries Handling of SAP entries to process invoices without valid supporting to process invoices without valid supporting documentation (e.g., missing GRN, no purchase orders). documentation (e.g., missing GRN, no purchase orders).  Failure to comply with stand Failure to comply with standard accounting procedures for genuine purchases.  The inability to substantiate purchases with proper documentation

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 transactions.\nHandling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\nFailure to comply with standard accounting procedures for genuine\npurchases.\nThe inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent books of accounts

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 transactions.\n➤ Handling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\n➤ Failure to comply with standard accounting procedures for genuine\npurchases.\n➤ The inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent

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 transactions.\n➤ Handling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\n➤ Failure to comply with standard accounting procedures for genuine\npurchases.\n➤ The inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent

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 transactions.\n➤ Handling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\n➤ Failure to comply with standard accounting procedures for genuine\npurchases.\n➤ The inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n6.2.25 Based on the above factors, the undersigned holds that the\ncurrent

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 transactions.\n➤ Handling of SAP entries to process invoices without valid supporting\ndocumentation (e.g., missing GRN, no purchase orders).\n➤ Failure to comply with standard accounting procedures for genuine\npurchases.\n➤ The inability to substantiate purchases with proper documentation,\nwhich significantly impacts the reliability of the accounts.\n\n6.2.25 Based on the above factors, the undersigned holds that

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

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

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

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

purchase expenses represent asset as per the\nExplanation 2 to section 153A of the Act.\n6.3.19\nAt this juncture, it is appropriate to analyse the Explanation 2\nto section 153A of the Act which describes the inclusions in the term\nAsset in the Act. The undersigned is of the view that an asset represents\nan economic resource, either immovable

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

purchase expenses represent asset as per the\nExplanation 2 to section 153A of the Act.\n6.3.19 At this juncture, it is appropriate to analyse the Explanation 2\nto section 153A of the Act which describes the inclusions in the term\nAsset in the Act. The undersigned is of the view that an asset represents\nan economic resource, either immovable