S.SATHYANARAYANAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao]

Unexplained investment in Bank : 3,00,000/- Long Term Capital Gain : 10,92,758/- The Assessing Officer initiated penalty proceedings

S.SATHYANARAYANAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao]

Unexplained investment in Bank : 3,00,000/- Long Term Capital Gain : 10,92,758/- The Assessing Officer initiated penalty proceedings

S.SATHYANARAYANAN,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Rao]

Unexplained investment in Bank : 3,00,000/- Long Term Capital Gain : 10,92,758/- The Assessing Officer initiated penalty proceedings

M.KIRAN KUMAR,CHENNAI vs. ACIT CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunatha

unexplained credit and accordingly made additions towards long term capital gain to the taxable income. 9.2 The assessee preferred an appeal before the CIT(A) but could not succeed. The Ld. CIT(A) for the detailed reasons recorded in his appellate order confirmed the addition made by the AO by holding that long term capital gain derived from sale

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

unexplained investment under section 69 of the Act. On perusal of the ld. CIT(A)’s order at page 11 & 12 of the impugned order, we find that the ld. CIT(A) held that the assessee failed to prove the nexus between the source of fund and the date on which the payment in cash towards investment in flat

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

unexplained investment under section 69 of the Act. On perusal of the ld. CIT(A)’s order at page 11 & 12 of the impugned order, we find that the ld. CIT(A) held that the assessee failed to prove the nexus between the source of fund and the date on which the payment in cash towards investment in flat

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

unexplained investment under section 69 of the Act. On perusal of the ld. CIT(A)’s order at page 11 & 12 of the impugned order, we find that the ld. CIT(A) held that the assessee failed to prove the nexus between the source of fund and the date on which the payment in cash towards investment in flat

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

unexplained investment under section 69 of the Act. On perusal of the ld. CIT(A)’s order at page 11 & 12 of the impugned order, we find that the ld. CIT(A) held that the assessee failed to prove the nexus between the source of fund and the date on which the payment in cash towards investment in flat

CHANDRA BHAVANI SANKAR,CHENNAI vs. ITO, NON CORP WARD 16(2), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.101/Chny/2024 िनधा"रण वष"/Assessment Year: 2012-13 V. Shri Chandra Bhavani Sankar, The Ito, 1/3A, Vinayakar Koil Street, Ncw-16(2), Thalambur, Chennai. Chennai-600 130. [Pan: Aeypb 1764 J] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Capital Gain (hereinafter in short "LTCG") of Rs.4,14,479/- and losses of current year at Rs.1,25,080/- and after claiming deduction under Chapter–VIA of Rs.1 lakh, the total income was arrived at Rs.31,70,459/-. Later, the RoI was selected for scrutiny under CASS, and the AO completed the assessment on 30.03.2015 by making following additions: • LTCG

DR.E.S.KRISHNAMOORTHY,CHENNAI vs. ITO NON CORPORATE WARD 1(4), CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2529/Chny/2017 िनधा"रण वष" /Assessment Year: 2012-13 Dr.E.S.Krishnamoorthy, V. The Income Tax Officer, No.3, South Mada Street, Non-Corporate Ward-I(4), Srinagar Colony, Saidapet, Chennai. Chennai-600 015. [Pan: Alwpk 0134 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained at Rs.7,15,893/- in his case. (Addition: Credit Card payments Rs.7,15,893/-) DEPRECIATION ON MOTOR CAR The assessee has claimed an amount of Rs.1,12,955/- as Depreciation on Car. To cover the personal usage, 20% of the above i.e. Rs.22,590/-is disaliowed and added to the income. (Addition: Rs.22,590/-) 6. Being aggrieved the Assessment

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

unexplained or unsubstantiated credits found in the books of\naccount, for which the assessee fails to offer a satisfactory explanation. It\ncannot be invoked where the nature of the transaction is otherwise governed\nby specific charging provisions of the Act, such as capital gains, or where the\nreceipt itself is exempt by statute. The Ld.AR submitted that judicial principles\nconsistently

BHAGWANDAS H.JUMANI ,CHENNAI vs. ITO NON CORPORATE WARD 10(1), CHENNAI

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

Bench: Shri Mahavir Singh, Vice- & Shri Arun Khodpiaआयकर अपीलसं./I.T.A.Nos.2701, 774 & 2253/Chny/2018 (िनधा"रणवष" / Assessment Years: 2003-04, 2004-05 & 2005-06) Vs The Income Tax Officer, Mr. Bhagwandas H.Jumani Flat 2B, 2Nd Floor, Tatvam, Non-Corporate Ward-10(1) 118, A.K.Samy Nagar, 9Th Street, Chennai-600 034. Kilpauk, Chennai-600 010. Pan : Ablpj 0980A (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained investment and added as income from other sources. The Assessing Officer also required to explain investments made in the name of Mr. Vishwambar Jumani, Mrs. A.Sumathi and assessee himself Mr.Bagwandas Jumani amounting to Rs.21,75,390/-, 1,09,594/- and Rs.22,97,846/- respectively aggregating to Rs.45,82,830/-. The assessee before the Assessing Officer contended that the assessee

BHAGWANDAS H JUMANI,CHENNAI vs. ITO N.C. WARD 10(1), CHENNAI

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

Bench: Shri Mahavir Singh, Vice- & Shri Arun Khodpiaआयकर अपीलसं./I.T.A.Nos.2701, 774 & 2253/Chny/2018 (िनधा"रणवष" / Assessment Years: 2003-04, 2004-05 & 2005-06) Vs The Income Tax Officer, Mr. Bhagwandas H.Jumani Flat 2B, 2Nd Floor, Tatvam, Non-Corporate Ward-10(1) 118, A.K.Samy Nagar, 9Th Street, Chennai-600 034. Kilpauk, Chennai-600 010. Pan : Ablpj 0980A (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained investment and added as income from other sources. The Assessing Officer also required to explain investments made in the name of Mr. Vishwambar Jumani, Mrs. A.Sumathi and assessee himself Mr.Bagwandas Jumani amounting to Rs.21,75,390/-, 1,09,594/- and Rs.22,97,846/- respectively aggregating to Rs.45,82,830/-. The assessee before the Assessing Officer contended that the assessee

BHAGWANDAS H.JUMANI,CHENNAI vs. ITO NON CORPORATE WARD 10(1), CHENNAI

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

Bench: Shri Mahavir Singh, Vice- & Shri Arun Khodpiaआयकर अपीलसं./I.T.A.Nos.2701, 774 & 2253/Chny/2018 (िनधा"रणवष" / Assessment Years: 2003-04, 2004-05 & 2005-06) Vs The Income Tax Officer, Mr. Bhagwandas H.Jumani Flat 2B, 2Nd Floor, Tatvam, Non-Corporate Ward-10(1) 118, A.K.Samy Nagar, 9Th Street, Chennai-600 034. Kilpauk, Chennai-600 010. Pan : Ablpj 0980A (अपीलाथ"/Appellant) (""यथ"/Respondent)

unexplained investment and added as income from other sources. The Assessing Officer also required to explain investments made in the name of Mr. Vishwambar Jumani, Mrs. A.Sumathi and assessee himself Mr.Bagwandas Jumani amounting to Rs.21,75,390/-, 1,09,594/- and Rs.22,97,846/- respectively aggregating to Rs.45,82,830/-. The assessee before the Assessing Officer contended that the assessee

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. RAMASAMY RAJASEHAR, PERAMBALUR

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

unexplained investment is unsustainable in law. We accordingly endorse the finding of the Ld.CIT(A) in deleting the said protective addition. 39. Our aforesaid view stands fortified by the decisions of the Coordinate Benches of this Tribunal, wherein it has been consistently held that a protective addition cannot be sustained in the hands of an assessee unless a substantive assessment

DCIT, CHENNAI vs. M/S. A.P. SRIDHAR (HUF), CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.2735/Chny/2016 िनधा"रण वष" /Assessment Year: 2011-12

capital gains’ is an income from unexplained sources. The assessee had also challenged the disallowance of exemption claimed u/s.54 of the Act and also Sec.54EC of the Act towards payment made for purchase of another residential flat and investment

DCIT, CHENNAI vs. MS. A.P. SANDHYA, CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita Nos.2735/Chny/2016 िनधा"रण वष" /Assessment Year: 2011-12

capital gains’ is an income from unexplained sources. The assessee had also challenged the disallowance of exemption claimed u/s.54 of the Act and also Sec.54EC of the Act towards payment made for purchase of another residential flat and investment

DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

investments and brought to tax u/s.69 of the Act. While, the expenses of DMK conference shown in the loose sheets have been treated as unexplained expenditure u/s,69C of the Act and brought to tax. In this regard, let us examine the relevance of the contents of the diary, note book, loose sheets and the retrieved data from