ACIT CORPORATE CIRCLE 2, COIMBATORE vs. P.S.R.SILK SAREES INDIA PVT. LTD., 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, 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

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

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/A

bogus purchases was upheld, by observing\nas under:-\n\n\"10. Considering the submissions made by learned advocate\nMr.Sanghani as well as the finding of facts recorded by the CIT(A) and\nthe Tribunal, it appears that so far as the Question No.1 is concerned,\nthe CIT(A) has noted the fact that the Assessing Officer while making\naddition

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

bogus purchases was upheld, by observing\nas under:-\n\n\"10. Considering the submissions made by learned advocate\nMr.Sanghani as well as the finding of facts recorded by the CIT(A) and\nthe Tribunal, it appears that so far as the Question No.1 is concerned,\nthe CIT(A) has noted the fact that the Assessing Officer while making\naddition

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\n(अपीलार्थी/Appellant)\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

purchases ought to be assessed to tax. Coming to the issue of\nestimation of the profits, on the given facts according to us, the Ld.\nCIT(A) has rightly estimated it at 17% of the value of purchase, which is\nfound to be fair & reasonable and therefore, no further addition was\nwarranted in this regard.\n\n8.14\nFor the reasons

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

purchases ought to be assessed to tax. Coming to the issue of\nestimation of the profits, on the given facts according to us, the Ld.\nCIT(A) has rightly estimated it at 17% of the value of purchase, which is\nfound to be fair & reasonable and therefore, no further addition was\nwarranted in this regard.\n\n8.14\nFor the reasons

RADIANCE REALTY DEVELOPERS INDIA LIMITED,CHENNAI vs. DCIT CENTRAL CIRCLE 2(1), CHENNAI

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

purchases ought to be assessed to tax. Coming to the issue of\nestimation of the profits, on the given facts according to us, the Ld.\nCIT(A) has rightly estimated it at 17% of the value of purchase, which is\nfound to be fair & reasonable and therefore, no further addition was\nwarranted in this regard.\n\n8.14 For the reasons

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

bogus purchases was upheld, by observing\nas under:-\n\n\"10. Considering the submissions made by learned advocate\nMr.Sanghani as well as the finding of facts recorded by the CIT(A) and\nthe Tribunal, it appears that so far as the Question No.1 is concerned,\nthe CIT(A) has noted the fact that the Assessing Officer while making\naddition

RADIANCE REALTY DEVELOPERS INDIA LIMITED,CHENNAI vs. DCIT CENTRAL CIRCLE 2(1), CHENNAI

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

purchases ought to be assessed to tax. Coming to the issue of\nestimation of the profits, on the given facts according to us, the Ld.\nCIT(A) has rightly estimated it at 17% of the value of purchase, which is\nfound to be fair & reasonable and therefore, no further addition was\nwarranted in this regard.\n\n8.14 For the reasons

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

In the result, all the appeals of the Revenue and the assessee as\nwell as the Cross-Objections of the assessee are dismissed

Bench: SHRI ABY T. VARKEY, JUDICIAL MEMBER AND\nSHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nITA Nos.2978 - 2984/Chny/2024\n&\nCO Nos.11-17/Chny/2025\nनिर्धारण वर्ष/Assessment Years: 2016-17 to 2022-23\n\nThe DCIT,\nCentral Circle-2(1),\nChennai.\nM/s Radiance Realty-\nDevelopers India Ltd.,\nRadiance Towers, 1st Floor,\n33 Feet Road, Anna Salai,\nGuindy, Chennai – 600 032.\n[PAN: AACCN5152H]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent/Cross\nObjector)\n\nITA Nos.2971 - 2972/Chny/2024\nनिर्धारणवर्ष/

bogus purchases was upheld, by observing\nas under:-\n\n\"10. Considering the submissions made by learned advocate\nMr.Sanghani as well as the finding of facts recorded by the CIT(A) and\nthe Tribunal, it appears that so far as the Question No.1 is concerned,\nthe CIT(A) has noted the fact that the Assessing Officer while making\naddition

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

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, 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