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

sections": [ "139", "153C", "132", "143(2)", "143(3)", "145(3)", "271AAD", "144", "145", "40A(3)", "68", "69C", "29", "30", "43D" ], "issues": "Whether the addition made by the AO for bogus purchases

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

bogus purchases over ten years was not sustainable without further evidence. The Tribunal agreed with the CIT(A) that the books of account should be rejected and profits estimated. The Tribunal estimated the profit at 10% of the turnover.", "result": "Dismissed", "sections": [ "139", "153C", "132", "143(2)", "143(3)", "145(3)", "271AAD", "144", "29", "30", "43D", "68

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 old\nbottle purchases. (In\nRs.)\nAmount sustained\nas per the\ndiscussions\n(in Rs.)\nAmount to be\ndeleted\n(in Rs.)\n1\n2020-21\nRs.41,11,59,615\nRs.11,43,16,602/-\nRs.29,68,43,013/-\n(Rs.37,97,84,300 /-\n+\nRs.3,13,75,315/-)\n2\n2021-22\nRs.56,41,82,236/-\nRs.10,65,46,645/-\nRs.45

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

M/S AADHI ENTERPRISES PRIVATE LIMITED,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(1), CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.: 308/Chny/2023 िनधा"रण वष"/Assessment Year: 2016-17 Aadhi Enterprises Pvt. Ltd., The Acit, No.1-130, Perambur Barracks V. Central Circle-3(1), Road, Pattalam, Chennai. Chennai – 600 112. Pan: Aanca 0382P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri B. Ramakrishnan, Fca Shri S. Neelakantan, Fca Shri Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई क" तारीख/Date Of Hearing : 11.07.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.08.2023

bogus FDI and hence, in this assessment year, the AO added an amount of Rs.278,32,93,118/- as unexplained cash credit being source of funds utilized for purchase of land u/s.68 of the Act. For this, the AO concluded as under:- “19. From the above, it is evident that the M/s. Chennai Properties and Investment Limited had no business

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, TRICHY, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,713/- which comprised of the alleged bogus purchases of Rs.2,22,77,459/-. It is not in dispute that, in any trading / manufacturing transaction, a sale / manufacture of an article is possible only when there is a corresponding purchase. We find that, before the AO, the complete quantitative details of opening stock, purchases, sales and closing stock were furnished

DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,713/- which comprised of the alleged bogus purchases of Rs.2,22,77,459/-. It is not in dispute that, in any trading / manufacturing transaction, a sale / manufacture of an article is possible only when there is a corresponding purchase. We find that, before the AO, the complete quantitative details of opening stock, purchases, sales and closing stock were furnished

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. MS DAR PARADISE PVT. LTD., COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1106/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Dar Paradise Pvt. Ltd., Income Tax, V. 599, Raja Street, Corporate Circle -1, Coimbatore – 641 001. Coimbatore. [Pan: Aafcd-3066-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri. N. Arjun Raj, Ca सुनवाई क" तारीख/Date Of Hearing : 05.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 21.03.2024

bogus. Further, the Revenue has also not placed any material on record to demonstrate that the VAT return filed by the assessee before the Appropriate Authorities have been rejected by the Authorities. It is also a fact that the assessee is having only one source of income which is also not in dispute. Further the purchase of goods from which

ITO, NON CORPORATE WARD 1(4), , COIMBATORE vs. M/S SURABII GOLD , COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 372/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Income-Tax Officer, M/S. Surabii Gold, Non-Corporate Ward 1(4), V. 138, Karuppa Gounder Street, Aayakar Bhavan, K G Street, 63, Race Course Road, Coimbatore – 641 012. Coimbatore – 641 018. [Pan: Abufs-6503-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. D. Hema Bhupal, Jcit : Shri. S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 26.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.04.2024

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

V SATHYAMOORTHY&CO,ERODE vs. DCIT, CENTRAL CIRCLE -, COIMBATORE

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1024/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2 Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) & 2. आयकरअपील सं./ Ita No.1547/Chny/2024 (िनधा*रण वष* / Assessment Year: 2020-21) Dcit M/S. V. Sathyamoorthy & Co., बनाम/ Central Circle-2 41, Patel Road, Near Blood Bank, Vs. Coimbatore. Erode-638 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 17-10-2024 आदेश / O R D E R

Section 69 of the Act were not satisfied in the present case there by vitiating the addition made in this regard. 15. The CIT (Appeals) - 20, Chennai failed to appreciate that the excel sheet relied upon by the Assessing Officer should not be construed as 'incriminating seized material' and further ought to have appreciated that the contents of the seized

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

68,655/-. The assessee has produced the bank details for the source for having made the payment and also property registration document. However, second appeal is suggested to consider the case on merits. 6 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 8. The learned CIT(A) has deleted the additions made by the AO under purchase of copra from market

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

68,655/-. The assessee has produced the bank details for the source for having made the payment and also property registration document. However, second appeal is suggested to consider the case on merits. 6 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 8. The learned CIT(A) has deleted the additions made by the AO under purchase of copra from market

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

68,655/-. The assessee has produced the bank details for the source for having made the payment and also property registration document. However, second appeal is suggested to consider the case on merits. 6 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 8. The learned CIT(A) has deleted the additions made by the AO under purchase of copra from market

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

68,655/-. The assessee has produced the bank details for the source for having made the payment and also property registration document. However, second appeal is suggested to consider the case on merits. 6 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 8. The learned CIT(A) has deleted the additions made by the AO under purchase of copra from market

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIECLE-2, COIMBATORE, COIMBATORE vs. V SATHYAMOORTHY CO, ERODE

Section 69 of the Act were\nnot satisfied in the present case there by vitiating the addition made in this regard.\n15.\nThe CIT (Appeals) - 20, Chennai failed to appreciate that the excel sheet relied\nupon by the Assessing Officer should not be construed as 'incriminating seized material'\nand further ought to have appreciated that the contents of the seized

JCIT NON CORPORATE CIRCLE 2, COIMBATORE vs. TARA JEWELLERY, COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 276/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Joint Commissioner Of M/S. Tara Jewellery, Income-Tax, V. 61, West Bashyakaralu Road, Non-Corporate Circle -2, R S Puram, Aayakar Bhavan, Coimbatore – 641 002. 63, Race Course Road, [Pan: Aagft-2345-B] Coimbatore – 641 018. (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. D. Hema Bhupal, Jcit अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 25.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.04.2024

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

DCIT NON CORPORATE CIRCLE-4, COIMBATORE vs. NAVARATNA MAALIGAI, COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपीलसं./Ita No.: 801/Chny/2023 & Co No.: 48/Chny/2023 िनधा"रणवष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Navaratna Maaligai, Income Tax, V. No. 362, Raja Street, Non-Corporate Circle -4, Coimbatore – 641 001. Aayakar Bhavan, [Pan: Aaifn-6257-E] 63, Race Course Road, Coimbatore – 641 018. (अपीलाथ"/Appellant) (Respondent/Cross Objector) : Shri. P. Sajit Kumar, Jcit अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. T. Banusekar, Advocate सुनवाई क" तारीख/Date Of Hearing : 19.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.04.2024

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales