MADANRAJ HAMIRMAL SHAH,MUMBAI vs. ITO, ERODE

In the result the appeal of the assessee is partly allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं./Ita Nos.: 1334 & 1335/Chny/2024 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Madanraj Hamirmal Shah Income Tax Officer, C-405, Royal Samrat, Ward -1(2), S.V. Road,Goregoan West, V. Erode. Mumbai – 400 062. [Pan: Adwpm-2343-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/Appellant By : Shri. P.C. Jain, Advocate & Shri. Mohit Bangani, Advocate ""थ"कीओरसे/Respondent By : Shri. P. Vijaideepan, Jcit सुनवाई की तारीख/Date Of Hearing : 11.02.2025 घोषणा की तारीख/Date Of Pronouncement : 26.03.2025

69A made by the AO, which has been confirmed by the ld.CIT(A). 8. Per contra the ld. DR relied on the orders of the lower authorities and stated that the assessee has not furnished any of the documents / evidence in support of his claim before the lower authorities. Further the assessee has not proved with any evidence to show

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. VIJAY DAIRY AND FARM PRODUCTS PRIVATE LIMITED, MUSIRI , TRICHY

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

section 69A of the Act to treat the difference in stock as unaccounted purchase / unaccounted excess the difference in stock as unaccounted purchase / unaccounted excess the difference in stock as unaccounted purchase / unaccounted excess stock. Accordingly it is considered that the addition made by the AO stock. Accordingly it is considered that the addition made by the AO stock. Accordingly

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

gains. A search action under section 132 of the Act was conducted\nat the residential and business premises of the assessee on\n02/03.11.2022. During the course of search, the Respondent examined\nthe billing software \"S.S. Retail\" used by the assessee and found the\ndifference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as\nrepresenting \"actual sales

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

Capital Gain on\nsale of immovable property at T Nagar, Chennai\"\nThe assessment was completed u/s.143(3) r.w.s.147 of the Income\nTax Act, 1961, wherein the following additions were made for the\nΑ.Υ. 2013-14:\nSl.No Details\nAmount Rs.\nIncome admitted in return of income\n2,57,140\nAdditions:\n1\nUnexplained cash deposits u/s.69

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

Gain on\nsale of immovable property at T Nagar, Chennai\"\nThe assessment was completed u/s.143(3) r.w.s.147 of the Income\nTax Act, 1961, wherein the following additions were made for the\nΑ.Υ. 2013-14:\nSl.No Details\nAmount Rs.\nIncome admitted in return of income\n2,57,140\nAdditions:\n1\nUnexplained cash deposits u/s.69\n1,60,46,854\n2\nInterest

SARANGABANI KIRUBAKARAN,CHENNAI vs. DCIT, CIRCLE-1(2), CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1237/Chny/2023 (िनधा)रण वष) / Assessment Year: 2014-15) Shri Sarangabani Kirubakaran Dcit बनाम/ 17/6, First Pillayar Koil Street, Circle-1(2) Vs. Ekkatuthangal, Chennai-600 032. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bumpk-0892-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. T.V. Muthu Abirami (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 25-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 04-09-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of The Common Order Of Learned Commissioner Of Income Tax (Appeals)-18, Chennai, [Cit(A)] Dated 13-09-2023 In The Matter Of An Assessment Framed By The Ld. Ao U/S.153C R.W.S. 144 Of The Act On 31- 03-2022. The Grievance Of The Assessee Is Confirmation Of Addition U/S 69 For Rs.8.04 Lacs & Rs.5 Lacs. The Assessee Is Also Aggrieved By Computation Of Long-Term Capital Gains (Ltcg) Of Rs.157.45 Lacs. 2. The Ld Ar Advanced Arguments On Merits As Well As On Legal Grounds & Also Raised Additional Grounds Of Appeal. The Ld. Cit-Dr

capital gains. The first appellate authority found that the land was classified as agricultural land and as per revenue record the land squarely fell within the definition of agricultural land and therefore, allowed the claim of the assessee. The Tribunal reversed the stand of Ld. CIT(A). Upon further appeal by the assessee, Hon’ble High Court of Madras held

CHARLES MOPUR ,CHENNAI vs. ITO , INTERNATIONAL TAXATION WARD - 1 (1) , CHENNAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.1000/Chny/2022 िनधा(रण वष( /Assessment Year: 2012-13 Charles Mopur, The Income Tax Officer Old No.9, New No.27, Vs. (International Taxation), Lourdes Cottage, Railway Colony, Ward-I(1), Chennai. Chennai – 600 029. [Pan: Akjpc-6627-L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से /Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 07.11.2023 घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023

capital gains and Rs. 82,86,700/- as unexplained money under section 69A of the Act towards the total income

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

gains. A search action under section 132 of the Act was conducted\nat the residential and business premises of the assessee on\n02/03.11.2022. During the course of search, the Respondent examined\nthe billing software \"S.S. Retail\" used by the assessee and found the\ndifference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as\nrepresenting \"actual sales

GANAPATHY CHANDRASEKARAN,ERODE vs. DCIT, CIRCLE-1, ERODE

In the result, appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 776/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income Ganapathy Chandrasekaran, V. Tax, 93, Erode Main Road, Circle -1, Ganapathypalayam, Erode. Erode – 638 153. [Pan: Abrpc-3073-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. S. Sridhar, Advocate (Erode) ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 20.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 28.06.2024 आदेश /O R D E R Per S. R. Raghunatha:

capital gains. Later, the case was selected for scrutiny for the reason that there was cash deposits during the year. The Assessing Officer issued statutory notices to the assessee calling for the source for cash deposits in his bank accounts. The assessee brought to the notice of the Assessing Officer that assessee was in the business of Rice Mill

PAZHANIVEL THANGARASU,CUDDALORE vs. ITO, WARD-1,, CUDDALORE

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

section 69A are not invocable in the facts and circumstances of the case. 8. For that the Commissioner of Income Tax (Appeals) erred in not appreciating the explanation along with evidences furnished by the appellant regarding the source of cash deposit to the tune of Rs.40,00,250/-. 9. For that the Commissioner of Income Tax (Appeals) failed to consider

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

capital gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

capital gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, , CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

capital gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

capital gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

NEELARAJ VINOTH,PERAMBALUR vs. ACIT, CC-2, , TRICHY

In the result, the appeal of the revenue is dismissed and the CO filed by the assessee is dismissed

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1982/Chny/2024 & C.O.No. 60/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of Neelaraj Vinoth, Income Tax, V. 274-C, Thuraiyur Road, Central Circle -2, Perambalur – 621 212, Trichy. Tamilnadu. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (Respondent/Cross Objector) आयकर अपील सं./Ita No.: 2119/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Neelaraj Vinoth, Assistant Commissioner Of 274-C, Thuraiyur Road, V. Income Tax, Perambalur – 621 212, Central Circle -2, Tamilnadu. Trichy. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

69A of the Act for the AY 2017-18 on merits also. Aggrieved by the order of the ld.CIT(A) the revenue is before us. 7. The ld.DR assailing the action of the ld.CIT(A) stated that the order of the ld.CIT(A) is erroneous in deleting the addition of :-15-: ITA. No: 1982 & 2119/Chny/2024 CO No: 60/Chny/2024 Rs.17.01 Crores

SARANGABANI KIRUBAGARAN,CHENNAI vs. DCIT, CIRCLE-1(2), CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1236/Chny/2023 (िनधा)रण वष) / Assessment Year: 2013-14) Shri Sarangabani Kirubakaran Dcit बनाम/ 17/6, First Pillayar Koil Street, Circle-1(2) Vs. Ekkatuthangal, Chennai-600 032. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bumpk-0892-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms.T.V. Muthu Abirami (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 25-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 04-09-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2013-14 Arises Out Of The Common Order Of Learned Commissioner Of Income Tax (Appeals)-18, Chennai, [Cit(A)] Dated 13-09-2023 In The Matter Of An Assessment Framed By The Ld. Ao U/S.153C R.W.S. 153A R.W.S. 143(3) Of The Act On 31-03-2022. The Only Grievance Of The Assessee Is Confirmation Of Addition U/S 69 For Rs.30 Lacs & Assessment Of Short- Term Capital Gain (Stcg) For Rs.12.19 Lacs. 2. The Ld Ar Advanced Arguments & Submitted That Impugned Addition Of Rs.30 Lacs U/S 69 Represent Advance Received Through

Capital Gain (STCG) for Rs.12.19 Lacs. 2. The Ld AR advanced arguments and submitted that impugned addition of Rs.30 Lacs u/s 69 represent advance received through banking channels which could not be added u/s 69. This addition does not satisfy the ingredients of Sec.69 since this section is applicable for unexplained investments only. On the issue of assessment of STCG

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

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

Capital Gains' as provided under section 48 and this is the only\nmanner of understanding the words, 'income chargeable to tax under\nsection 149(1)(b) of I.T. Act.\n19. The contention of the Revenue that under section 149 what is required\nto be taken note of, is the 'income that has escaped assessment' being\nthe entirety of sale consideration

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2), , CHENNAI

In the result the appeal of the assessee is partly allowed

Section 36 of\nIncome Tax Act, 1961,\n“if any interest paid for the business purpose, the same has to\nbe allowed as business expenditure " as held in the cases of -\nThe DCIT, Cir. 1(1(1), Ahmedabad v. Applitech Solution Ltd. (/TAT\nAhmedabad B Bench) in ITA no.248/4hd/2020 pronounced on\n19/05/2023; and Vodafone India Ltd. vs. Additional Commissioner