ACIT, NUNAGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

purchases as expenditure not incurred for business purposes and disallowed it under section 37(1). 128. Applying the same principles of evidence under section 132(4A) read with section 292C, and supported by decisions in Navjivan Oil Mills (supra) and Indeo Airways (P.) Ltd. (supra), and considering that the seized records confirm the money received back from the vendors

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

purchases as expenditure not incurred for business purposes and disallowed it under section 37(1). 128. Applying the same principles of evidence under section 132(4A) read with section 292C, and supported by decisions in Navjivan Oil Mills (supra) and Indeo Airways (P.) Ltd. (supra), and considering that the seized records confirm the money received back from the vendors

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

purchases as expenditure not incurred for business purposes and disallowed it under section 37(1). 128. Applying the same principles of evidence under section 132(4A) read with section 292C, and supported by decisions in Navjivan Oil Mills (supra) and Indeo Airways (P.) Ltd. (supra), and considering that the seized records confirm the money received back from the vendors

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CC-2(4), CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Pvt. Ltd.,) Vs. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषण की तारीख / Date Of Pronouncement : 13.10.2025 : 30.12.2025 :- 2 -:

purchases & held in favour of revenue. 6. The Ld. LD.CIT(A) erred in deleting the addition made on account of disallowances for Expenses without taking into consideration the fact that the expenses per se were bogus in nature 7. The Ld. LD.CIT(A) has not taken cognizance of the decision of the Hon'ble Madras High Court in the case

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Chennai. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

purchases & held in favour of revenue. 6. The Ld. LD.CIT(A) erred in deleting the addition made on account of disallowances for Expenses without taking into consideration the fact that the expenses per se were bogus in nature. 7. The Ld. LD.CIT(A) has not taken cognizance of the decision of the Hon'ble Madras High Court in the case

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- Industries Pvt Ltd Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

bogus purchases is Rs.4,41,70,464/- for the F.Y 2017-18 (From July 2017), Rs.5,69,70,130/- for the F.Y 2018-19 and Rs.2,95,16,955/- for the F.Y. 2019-20 (up to 4.8.2019). The above seized materials were handed over to the undersigned on 18.06.2021. 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 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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- V. The Dcit, Industries Pvt Ltd Central Circle-2(2), Chennai. Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

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

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

Section\n132(4A) of the Act and hence these notings on stand-alone basis would\nhave entailed substantial tax liabilities on him. However, according to the\nLd. AR, what Shri CPA did not foresee was that he would be faced with\nconsequences under other regulations such as PMLA, FEMA violations etc.\nas well. The Ld. AR submitted that, the Revenue

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

Section 132(4A) of the Act and hence these notings on stand-alone basis would have entailed substantial tax liabilities on him. However, according to the Ld. AR, what Shri CPA did not foresee was that he would be faced with consequences under other regulations such as PMLA, FEMA violations etc. as well. The Ld. AR submitted that, the Revenue

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

Section\n132(4A) of the Act and hence these notings on stand-alone basis would\nhave entailed substantial tax liabilities on him. However, according to the\nLd. AR, what Shri CPA did not foresee was that he would be faced with\nconsequences under other regulations such as PMLA, FEMA violations etc.\nas well. The Ld. AR submitted that, the Revenue

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

Section\n132(4A) of the Act and hence these notings on stand-alone basis would\nhave entailed substantial tax liabilities on him. However, according to the\nLd. AR, what Shri CPA did not foresee was that he would be faced with\nconsequences under other regulations such as PMLA, FEMA violations etc.\nas well. The Ld. AR submitted that, the Revenue

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

Section\n132(4A) of the Act and hence these notings on stand-alone basis would\nhave entailed substantial tax liabilities on him. However, according to the\nLd. AR, what Shri CPA did not foresee was that he would be faced with\nconsequences under other regulations such as PMLA, FEMA violations etc.\nas well. The Ld. AR submitted that, the Revenue

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, INCOME TAX OFFICE, TRICHY vs. LIFE LINE AUTO FINANCE, KARUR

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1630/Chny/2025 निर्धारण वर्ष / Assessment Year: 2013-14 Acit, Central Circle-2, Trichy. Vs. Life Line Auto Finance, 306-B1, First Floor, Bharathi Nagar, Mahatma Gandhi Road, Karur - 639 002. [Pan:Aaefl-7071-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. R. Venkata Raman, C.A. प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, C.I.T. सुनवाई की तारीख/Date Of Hearing : 11.11.2025 घोषणा की तारीख/Date Of Pronouncement : 20.01.2026 आदेश /Order Per S. R. Raghunatha, Am: The Present Appeal Of The Revenue Is Directed Against The Order Dated 21.03.2015 Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [Hereinafter Referred To As “The Ld.Cit(A)”], Arising Out Of The Assessment Order Dated 31.03.2022 Passed By The Deputy Commissioner Of Income Tax, Central Circle-2, Trichy (Hereinafter Referred To As “The Ao”] U/S.143(3) R.W.S 153C Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year 2013–14. :-2-:

bogus loans and advances by the firm & the loose sheets and admission based on that clearly proved that there was investment of Rs.10 crores (which is more than 50 lakhs as stipulated as a pre condition). 7. For these grounds and any other ground including amendment of grounds that may be raised during the course of appeal proceedings, the order

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

292C(1)(i) of the Act which provides that it belongs to the person from whom the said assets/documents was found. In other words, whenever an asset/document is found from a person who is being searched, the normal presumption is that the said asset/document belongs to that person. It is for the Assessing Officer to rebut that presumption and come

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

292C(1)(i) of the Act which provides that it belongs to the person from whom the said assets/documents was found. In other words, whenever an asset/document is found from a person who is being searched, the normal presumption is that the said asset/document belongs to that person. It is for the Assessing Officer to rebut that presumption and come

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

292C(1)(i) of the Act which provides that it belongs to the person from whom the said assets/documents was found. In other words, whenever an asset/document is found from a person who is being searched, the normal presumption is that the said asset/document belongs to that person. It is for the Assessing Officer to rebut that presumption and come

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

292C(1)(i) of the Act which provides that it belongs to the person from whom the said assets/documents was found. In other words, whenever an asset/document is found from a person who is being searched, the normal presumption is that the said asset/document belongs to that person. It is for the Assessing Officer to rebut that presumption and come