ACIT, NCC-2, , COIMBATORE vs. PSR & SONS, COIMBATORE

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 934/Chny/2019 िनधा"रण वष" / Assessment Year: 2009-10 Assistant Commissioner Of P.S.R. Silk Sarees India Pvt Income-Tax, V. Ltd., Corporate Circle -2, No. 942, Psr House, Cross Cut No. 63-A, Race Course Road, Road, Gandhipuram, Coimbatore. Coimbatore – 641 012. [Pan: Aaecp-7548-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 1639/Chny/2019 & Co No: 77/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of P.S.R. Silk Sarees India Pvt Income-Tax, V. Ltd., Corporate Circle -2, No. 942, Psr House, Cross Cut No. 63-A, Race Course Road, Road, Gandhipuram, Coimbatore. Coimbatore – 641 012. [Pan: Aaecp-7548-M] (अपीलाथ"/Appellant) (Cross Objector) आयकर अपील सं./Ita No.: 3257/Chny/2018 & Co No: 11/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of M/S. P.S.R. & Sons, Income-Tax, V. No. 942, Cross Cut Road, Corporate Circle -2, Gandhipuram, No. 67-A, Race Course Road, Coimbatore – 641 012. Coimbatore. [Pan: Aadfp-6903-E] (अपीलाथ"/Appellant) (Cross Objector)

u/s 133A. I have also gone through the Survey file requisitioned from the Assessing Officer, in order to appreciate the facts better first-hand. 5.2 There was a survey in this case on 20.03.2014. It appears that during the Survey, the Survey team made an inventory of the physical stock and arrived at a value of the physical stock

ACIT NON CORPORATE CIRCLE-2, COIMBATORE vs. PSR MARKETING COMPANY, COIMBATORE

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 934/Chny/2019 िनधा"रण वष" / Assessment Year: 2009-10 Assistant Commissioner Of P.S.R. Silk Sarees India Pvt Income-Tax, V. Ltd., Corporate Circle -2, No. 942, Psr House, Cross Cut No. 63-A, Race Course Road, Road, Gandhipuram, Coimbatore. Coimbatore – 641 012. [Pan: Aaecp-7548-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 1639/Chny/2019 & Co No: 77/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of P.S.R. Silk Sarees India Pvt Income-Tax, V. Ltd., Corporate Circle -2, No. 942, Psr House, Cross Cut No. 63-A, Race Course Road, Road, Gandhipuram, Coimbatore. Coimbatore – 641 012. [Pan: Aaecp-7548-M] (अपीलाथ"/Appellant) (Cross Objector) आयकर अपील सं./Ita No.: 3257/Chny/2018 & Co No: 11/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of M/S. P.S.R. & Sons, Income-Tax, V. No. 942, Cross Cut Road, Corporate Circle -2, Gandhipuram, No. 67-A, Race Course Road, Coimbatore – 641 012. Coimbatore. [Pan: Aadfp-6903-E] (अपीलाथ"/Appellant) (Cross Objector)

u/s 133A. I have also gone through the Survey file requisitioned from the Assessing Officer, in order to appreciate the facts better first-hand. 5.2 There was a survey in this case on 20.03.2014. It appears that during the Survey, the Survey team made an inventory of the physical stock and arrived at a value of the physical stock

ACIT CORPORATE CIRCLE 2, COIMBATORE vs. PSR SILK SAREES INDIA PRIVATE LIMITED, COIMBATORE

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 934/Chny/2019 िनधा"रण वष" / Assessment Year: 2009-10 Assistant Commissioner Of P.S.R. Silk Sarees India Pvt Income-Tax, V. Ltd., Corporate Circle -2, No. 942, Psr House, Cross Cut No. 63-A, Race Course Road, Road, Gandhipuram, Coimbatore. Coimbatore – 641 012. [Pan: Aaecp-7548-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 1639/Chny/2019 & Co No: 77/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of P.S.R. Silk Sarees India Pvt Income-Tax, V. Ltd., Corporate Circle -2, No. 942, Psr House, Cross Cut No. 63-A, Race Course Road, Road, Gandhipuram, Coimbatore. Coimbatore – 641 012. [Pan: Aaecp-7548-M] (अपीलाथ"/Appellant) (Cross Objector) आयकर अपील सं./Ita No.: 3257/Chny/2018 & Co No: 11/Chny/2019 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of M/S. P.S.R. & Sons, Income-Tax, V. No. 942, Cross Cut Road, Corporate Circle -2, Gandhipuram, No. 67-A, Race Course Road, Coimbatore – 641 012. Coimbatore. [Pan: Aadfp-6903-E] (अपीलाथ"/Appellant) (Cross Objector)

u/s 133A. I have also gone through the Survey file requisitioned from the Assessing Officer, in order to appreciate the facts better first-hand. 5.2 There was a survey in this case on 20.03.2014. It appears that during the Survey, the Survey team made an inventory of the physical stock and arrived at a value of the physical stock

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

survey u/s 133A of the Act was carried out at the business premises of the assesse on 21.09.2017, in the course of which purchase ledgers were impounded vide Annexure-GS/PE/S/IMP/ANN 1 to 7. The AO is noted to have extensively reproduced sample purchase ledgers in the assessment order and observed that, there are entries for payments through cheques

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

survey u/s 133A of the Act was carried out at the business premises of the assesse on 21.09.2017, in the course of which purchase ledgers were impounded vide Annexure-GS/PE/S/IMP/ANN 1 to 7. The AO is noted to have extensively reproduced sample purchase ledgers in the assessment order and observed that, there are entries for payments through cheques

S.P.MANI AND MOHAN DAIRY,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, both the appeals filed by assessee and revenue are allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

bogus purchases introduced in books of accounts or these purchases are paid in cash out of the undisclosed income of the assessee which are not recorded in books of accounts of the assessee. The AO had observed that in some cases old purchases are outstanding for more than a year and there are no transactions by assessee with these milk

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

u/s 153C of period which could be reopened u/s 153C of the Act. In the present case, the Act. In the present case, as noted earlier, the date of receipt of books the date of receipt of books of accounts/ documents/ assets of accounts/ documents/ assets was 18-06-2021 (AY 2022 (AY 2022-23). Accordingly, ordinarily

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

u/s 153C of period which could be reopened u/s 153C of the Act. In the present case, the Act. In the present case, as noted earlier, the date of receipt of books the date of receipt of books of accounts/ documents/ assets of accounts/ documents/ assets was 18-06-2021 (AY 2022 (AY 2022-23). Accordingly, ordinarily

DCIT, CENTRAL CIT-2(4), CHENNAI vs. A GANDHIMATHI, KANCHEEPURAM

In the result, appeals filed by the Revenue in ITA Nos

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.13-15/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 To 2014-15 The Dy. Commissioner Of- V. Smt. A. Gandhimathi, Income Tax, Prop: East West Gandhimathi Central Circle-2(4), Combined Industries, Investigation Building, Survey No.503/2A2A, Chennai. Mambakkam Salai, Echankadu, Kayar, Kancheepuram District. [Pan: Agupa 2409 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Department By : Mr.Guru Bashyam, Cit-Dr Assessee By : Mr.Philip George, Adv. सुनवाई क" तारीख/Date Of Hearing : 11.07.2022 घोषणा क" तारीख /Date Of Pronouncement : 10.10.2022

bogus purchases and accordingly disallowed. 5. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee challenged the assessment order passed by the AO u/s.143(3) r.w.s.153C of the Act, on the ground that the conditions precedent for invoking provisions of Sec.153C of the Act, are not satisfied. Because

DCIT, CENTRAL CIT-2(4), CHENNAI vs. A GANDHIMATHI, KANCHEEPURAM

In the result, appeals filed by the Revenue in ITA Nos

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.13-15/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 To 2014-15 The Dy. Commissioner Of- V. Smt. A. Gandhimathi, Income Tax, Prop: East West Gandhimathi Central Circle-2(4), Combined Industries, Investigation Building, Survey No.503/2A2A, Chennai. Mambakkam Salai, Echankadu, Kayar, Kancheepuram District. [Pan: Agupa 2409 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Department By : Mr.Guru Bashyam, Cit-Dr Assessee By : Mr.Philip George, Adv. सुनवाई क" तारीख/Date Of Hearing : 11.07.2022 घोषणा क" तारीख /Date Of Pronouncement : 10.10.2022

bogus purchases and accordingly disallowed. 5. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee challenged the assessment order passed by the AO u/s.143(3) r.w.s.153C of the Act, on the ground that the conditions precedent for invoking provisions of Sec.153C of the Act, are not satisfied. Because

DCIT, CENTRAL CIT-2(4), CHENNAI vs. A GANDHIMATHI, KANCHEEPURAM

In the result, appeals filed by the Revenue in ITA Nos

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.13-15/Chny/2019 िनधा"रण वष" /Assessment Years: 2012-13 To 2014-15 The Dy. Commissioner Of- V. Smt. A. Gandhimathi, Income Tax, Prop: East West Gandhimathi Central Circle-2(4), Combined Industries, Investigation Building, Survey No.503/2A2A, Chennai. Mambakkam Salai, Echankadu, Kayar, Kancheepuram District. [Pan: Agupa 2409 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) Department By : Mr.Guru Bashyam, Cit-Dr Assessee By : Mr.Philip George, Adv. सुनवाई क" तारीख/Date Of Hearing : 11.07.2022 घोषणा क" तारीख /Date Of Pronouncement : 10.10.2022

bogus purchases and accordingly disallowed. 5. Being aggrieved by the assessment order, the assessee preferred an appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee challenged the assessment order passed by the AO u/s.143(3) r.w.s.153C of the Act, on the ground that the conditions precedent for invoking provisions of Sec.153C of the Act, are not satisfied. Because

ARUNRAJ,ERODE vs. ACIT, CENTRAL CIRC 3, CBE, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

SUNDARASAMY KOHILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

VADIAPPAN SENTHILMURUGAN,ERODE vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

SEETHADEVI,ERODE vs. ACIT, CENTRAL CIRCLE-3, , COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

EVERYEADY SPINNING MILLS PRIVATE LIMITED,TRIUPUR vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

In the result, all the appeals of the assessee are allowed

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before the Tribunal against the order of the CIT(A). The assessee raised various grounds contending the addition made on merits. The assessee also raised additional ground vide letter dated 01.12.2025 contending that the notice issued u/s. 153C

MIDAS GOLDEN DISTILLERIES P. LTD ,SRIPERUMBUDUR vs. OFFICE OF THE DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM

In the result, the appeal of the assessee is dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.2955/Chny/2024, Assessment Years: 2014-15

bogus purchases were siphoned off from the system and in turn handed over to the assessee Company in lieu of over invoicing of sales done to the assessee apparently collected by him / his employees/ business concerns so as to meet certain incidental expenses which are peculiar to this line of business. Shri K.Karthikeyan also furnished the quantitative details of bottles