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

2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren’t pendin weren’t pending before AO on the date of search, therefore, those years didn’t abate date of search, therefore, those years didn’t abate date of search, therefore, those years didn’t abate consequent

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

2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren’t pendin weren’t pending before AO on the date of search, therefore, those years didn’t abate date of search, therefore, those years didn’t abate date of search, therefore, those years didn’t abate consequent

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

2) of the Act had expired. Accordingly, the income-tax assessments for AYs assessments for AYs 2018-19 to 2019-20 weren’t pendin weren’t pending before AO on the date of search, therefore, those years didn’t abate date of search, therefore, those years didn’t abate date of search, therefore, those years didn’t abate consequent

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

2) of the Act and the\nassessment(s) were completed u/s 143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021

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

2) of the Act and the\nassessment(s) were completed u/s 143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021

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

2) of the Act and the\nassessment(s) were completed u/s 143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021

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

2) of the Act and the\nassessment(s) were completed u/s 143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n(in Rs.)\nSl\nNo\nParticulars\n2020-21\n2021

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

2) of the Act and the\nassessment(s) were completed u/s 143(3) assessing the total income for\nAYs 2020-21, 2021-22 & 2022-23 at Rs 95,03,99,772/-, Rs\n108,50,73,297/-, Rs 94,94,33,711/- respectively, after making the\nfollowing addition(s)/disallowance(s).\n\n(in Rs.)\nSI\nNo\nParticulars\n2020-21\n2021

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 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

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 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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2 (2), CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

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

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

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 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