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

39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether the income\ngenerated by booking 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

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

39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether the income\ngenerated by booking 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

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

39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether the income\ngenerated by booking 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

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

39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18\nNow the issue before the under signed is whether the income\ngenerated by booking 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

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

39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether the income\ngenerated by booking 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

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

39 ::\nfor AYs 2014-15 to 2016-17 to be impermissible in law, by holding as\nunder:-\n\"6.3.18 Now the issue before the under signed is whether the income\ngenerated by booking 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

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

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

Bogus purchases Unexplained money u/S Nil 39,22,000 39,22,000 69A and unexplained 42,30,000 42,30,000 expenditure u/S 69C Income on account of 1,97,03,000 Nil 1,97,03,000 Palakol land sale Misc. income on sale of 11,12,270 81,230 11,93,500 scrap, car, candy and pulp Total

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

Bogus purchases Unexplained money u/S Nil 39,22,000 39,22,000 69A and unexplained 42,30,000 42,30,000 expenditure u/S 69C Income on account of 1,97,03,000 Nil 1,97,03,000 Palakol land sale Misc. income on sale of 11,12,270 81,230 11,93,500 scrap, car, candy and pulp Total

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

1% to 6% and the profits\nreported by the assessee ranged between AYs 2019-20 to 2022-23\nranged from 5.38% to 7.69%. The Ld. AR further pleaded that, there was\n::31 ::\nITA Nos.1817 to 1819/Chny/2025 &\nITA Nos.1550 to 1552 /Chny/2025\n(AYs 2020-21 to 2022-23)\nM/s.Southern Agrifurane Industries Pvt. Ltd.\na significant reduction in profit margins

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

1% to 6% and the profits\nreported by the assessee ranged between AYs 2019-20 to 2022-23\nranged from 5.38% to 7.69%. The Ld. AR further pleaded that, there was\n::31 ::\nITA Nos.1817 to 1819/Chny/2025 &\nITA Nos.1550 to 1552 /Chny/2025\n(AYs 2020-21 to 2022-23)\nM/s.Southern Agrifurane Industries Pvt. Ltd.\na significant reduction in profit margins

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

1% to 6% and the profits\nreported by the assessee ranged between AYs 2019-20 to 2022-23\nranged from 5.38% to 7.69%. The Ld. AR further pleaded that, there was\n::31 ::\nITA Nos.1817 to 1819/Chny/2025 &\nITA Nos.1550 to 1552 /Chny/2025\n(AYs 2020-21 to 2022-23)\nM/s.Southern Agrifurane Industries Pvt. Ltd.\na significant reduction in profit margins

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

1% to 6% and the profits\nreported by the assessee ranged between AYs 2019-20 to 2022-23\nranged from 5.38% to 7.69%. The Ld. AR further pleaded that, there was\n\n::31 ::\nITA Nos.1817 to 1819/Chny/2025 &\nITA Nos.1550 to 1552 /Chny/2025\n(AYs 2020-21 to 2022-23)\nM/s.Southern Agrifurane Industries Pvt. Ltd.\n\na significant reduction

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 expenditure.\nThe income already disclosed in the return under section 148 of Rs.\n53,25,720/- was considered, and the remaining balance of Rs.\n3,89,98,710/- was brought to tax under section 37(1).\n45. The seized Excel sheet also reflected a cash transaction of Rs.\n39,22,000/- in the name of Shri B. Sivaprasad

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

section 37(1) of the Act, without\nconsidering the additional income admitted in the revised computation.\nThe assessee strongly contended that the expenses were incurred\nwholly and exclusively for business purposes and that the AO's\nreliance solely on the statement of Shri Stanley Babu-which was\nsubsequently retracted—was inappropriate and unsupported by\ncorroborative evidence.\n:- 33 -:\nITA Nos.1881

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-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

Section 37(1) of the Act, without\nconsidering the additional income admitted in the revised computation.\nThe assessee strongly contended that the expenses were incurred\nwholly and exclusively for business purposes and that the AO's\nreliance solely on the statement of Shri Stanley Babu-which was\nsubsequently retracted—was inappropriate and unsupported by\ncorroborative evidence.\n67. While adjudicating

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

section 37(1) of the Act, without\nconsidering the additional income admitted in the revised computation.\nThe assessee strongly contended that the expenses were incurred\nwholly and exclusively for business purposes and that the AO's\nreliance solely on the statement of Shri Stanley Babu—which was\nsubsequently retracted—was inappropriate and unsupported by\ncorroborative evidence.\n- : 34 -:\nITA Nos.1881