ADP INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

section 142(1) of the Act dated 19.10.2019 was also issued on the assessee. ITA Nos.2670 to 2672 & 2698/Chny/2024 6. On perusal of the depreciation

ADP INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), CHENNAI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

section 142(1) of the Act dated 19.10.2019 was also issued on the assessee. ITA Nos.2670 to 2672 & 2698/Chny/2024 6. On perusal of the depreciation

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

Bench: This Tribunal.

depreciation in the sum of Rs.1,05,84,885/- for AY 2007-2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

depreciation in the sum of Rs.1,05,84,885/- for AY 2007- 2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

depreciation in the sum of Rs.1,05,84,885/- for AY 2007- 2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

depreciation in the sum of Rs.1,05,84,885/- for AY 2007- 2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

depreciation in the sum of Rs.1,05,84,885/- for AY 2007- 2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

depreciation in the sum of Rs.1,05,84,885/- for AY 2007- 2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

depreciation in the sum of Rs.1,05,84,885/- for AY 2007- 2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

JOTHI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(2), CHENNAI

depreciation in the sum of Rs.1,05,84,885/- for AY 2007-2008 and Rs.9,50,75,091/- for AY 2008-2009. The Assessing Officer (AO) acted on the report of Special Audit ordered in the case of DSL under Section 142

M. NATESAN,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

P. NALLUSAMY,KARUR vs. ITO, WARD-1, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

K. SADASIVAM,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

K. KATHIRVEL,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

S. ARAVIND,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

K. BASKAR,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

RAMASAMY PALANISAMY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections

R.EASWARAMOORTHY,KARUR vs. ITO, WARD-1,, KARUR

In the result, all the appeals t, all the appeals stand allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in he case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant this section and in sections