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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

1, which were written by him and having the details of cash collected from old details of cash collected from old bottle suppliers. This established that bottle suppliers. This established that M/s SAFL received back cash M/s SAFL received back cash from the old bottle suppliers. g) From the statement of Shri. Augustine Paulraj, it was gathered that From

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 from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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 from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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 from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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 from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

bogus purchases from\nvendors of old liquor bottles and transportation & logistics services.\nConsequently, the case of the assessee was reopened and notice(s) u/s\n148 of the Act dated 30-03-2023 was issued to the assessee for the\nrelevant AYs 2013-14 to 2016-17. The details of the return(s) of income\nfiled in response to notice

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

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

iii) the purchases without GRNs lacked proper\ndocumentation, and therefore on these counts sustain the action of the\nLd. CIT(A) in rejecting the books of accounts and estimating the profits of\nthe assessee. The relevant findings of Ld.CIT(A) as partly countenanced\nby us supra, are as under:-\n\"6.2.19 During the course of the appellate proceedings

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

iii) the purchases without GRNs lacked proper\ndocumentation, and therefore on these counts sustain the action of the\nLd. CIT(A) in rejecting the books of accounts and estimating the profits of\nthe assessee. The relevant findings of Ld.CIT(A) as partly countenanced\nby us supra, are as under:-\n"6.2.19 During the course of the appellate proceedings

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

iii) the purchases without GRNs lacked proper\ndocumentation, and therefore on these counts sustain the action of the\nLd. CIT(A) in rejecting the books of accounts and estimating the profits of\nthe assessee. The relevant findings of Ld.CIT(A) as partly countenanced\nby us supra, are as under:-\n\"6.2.19 During the course of the appellate proceedings

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

iii) the purchases without GRNs lacked proper\ndocumentation, and therefore on these counts sustain the action of the\nLd. CIT(A) in rejecting the books of accounts and estimating the profits of\nthe assessee. The relevant findings of Ld.CIT(A) as partly countenanced\nby us supra, are as under:-\n\n\"6.2.19 During the course of the appellate proceedings

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

iii) the purchases without GRNs lacked proper\ndocumentation, and therefore on these counts sustain the action of the\nLd. CIT(A) in rejecting the books of accounts and estimating the profits of\nthe assessee. The relevant findings of Ld.CIT(A) as partly countenanced\nby us supra, are as under:-\n\"6.2.19 During the course of the appellate proceedings

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

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

bogus claim of refund of fees, all clearly proved diversion of funds to specified persons and Section 13(1) (c) of the Act stood attracted. Viz-a-viz, alleged specific instances falling within Section 22. 13(1) (c) of the Act, arguments taken by the ld. Departmental Representative are summarized here under:- (i) As for the payment of advance

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

bogus claim of refund of fees, all clearly proved diversion of funds to specified persons and Section 13(1) (c) of the Act stood attracted. Viz-a-viz, alleged specific instances falling within Section 22. 13(1) (c) of the Act, arguments taken by the ld. Departmental Representative are summarized here under:- (i) As for the payment of advance