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

36,677 1,29,61,697 3 Addition on a/c of unaccounted sale of Addition on a/c of unaccounted sale of NA 42,94,341 42,94,341 42,94,341 scrap 4 Addition on a/c of bogus CSR contribution of bogus CSR contribution NA 4,00,00,000 4,00,00,000 NA 3. It is noted 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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36 ::\nof Section 153A(1) of the Act. In the present case, having regard to the\nyear of search i.e. AY 2023-24, the six year block period is AYs 2017-18\nto 2022-23. However, the fourth proviso to Section 153A(1) of the Act\nproscribes issuance of any notice for assessment or reassessment in\nrespect of a relevant

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

36,677 1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341 42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ\n4,00,00,000\nNA\n3.\nIt is noted that the reasoning given by the AO for making the\naboveadditions/disallowances were verbatim same across all AYs. Hence,\nforthe sake

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

36,677 1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341 42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ\n4,00,00,000\nNA\n3.\nIt is noted that the reasoning given by the AO for making the\naboveadditions/disallowances were verbatim same across all AYs. Hence,\nforthe sake

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

1,87,02,100/-; & Rs. 40,00,000/- Disallowance u/s 36 of the Act on :- 16 -: ITA Nos.1881, 1882 & 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. account of Inflated handling charges at port of Rs. 75,00,000/-; Disallowance u/s 37 of the Act on account of Bogus purchases of Rs. 3,89,98,710/-, Unexplained money

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

1,87,02,100/-; & Rs. 40,00,000/- Disallowance u/s 36 of the Act on :- 16 -: ITA Nos.1881, 1882 & 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. account of Inflated handling charges at port of Rs. 75,00,000/-; Disallowance u/s 37 of the Act on account of Bogus purchases of Rs. 3,89,98,710/-, Unexplained money

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

36,677\n1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341\n42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ\n4,00,00,000\nNA\n3.\nIt is noted that the reasoning given by the AO for making the\naboveadditions/disallowances were verbatim same across all AYs. Hence,\nforthe sake

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

36,677\n1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341\n42,94,341\n4\nAddition on a/c of bogus CSR contribution\nNA\n4,00,00,000\nNA\n3. It is noted that the reasoning given by the AO for making the\naboveadditions/disallowances were verbatim same across all AYs. Hence,\nforthe sake

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

36,677\n1,29,61,697\n3\nAddition on a/c of unaccounted sale of\nscrap\nNA\n42,94,341\n42,94,341\n4\nAddition on a/c of bogus CSR contribution\nΝΑ\n4,00,00,000\nNA\n\n3. It is noted that the reasoning given by the AO for making the\naboveadditions/disallowances were verbatim same across all AYs. Hence,\nforthe

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

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

36 of the Act on\n:- 16 -:\nITA Nos.1881, 1882 & 1883/Chny/2025\nITA Nos.1874, 1876 & 1879/Chny/2025\nIntegrated Service Point Ltd.\naccount of Inflated handling charges at port of Rs.75,00,000/-;\nDisallowance u/s 37 of the Act on account of Bogus purchases of\nRs.3,89,98,710/-, Unexplained money u/s 69A of the Act of Rs.\n39,22,000/-, Unexplained expenditure

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

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

bogus\npurchases as against appellant's voluntary disallowance of 12% in\nROI u/s 148.\n3.1 On facts and under the circumstances of the case, the learned\nCommissioner of Income Tax (Appeals)-19, Chennai erred in\nadjudicating the disallowances at 20% of the alleged bogus\npurchases, which is over and above the disallowances of 12% on\nalleged bogus purchases voluntarily returned