INDUSTRIAL MINERAL CO, 100%EOU,TUTICORIN vs. ACIT,CENTRAL CIRCLE-1, MADURAI, MADURAI

In the result, the assessee’s appeal ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.390/Chny/2023 (िनधा(रण वष( / Assessment Year: 2012-13) M/S. Industrial Mineral Co. 100% Eou Acit बनाम/ 1/1C, Harbour Express Highway, Central Circle-(1), Vs. Thermal Nagar So, Tuticorin-628 006. Madurai "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaafi-9714-R (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकरअपील सं./ Ita No.529/Chny/2023 (िनधा(रण वष( / Assessment Year: 2012-13) Acit M/S. Industrial Mineral Co. 100% Eou बनाम/ Central Circle-(1), 1/1C, Harbour Express Highway, Vs. Madurai Thermal Nagar So, Tuticorin 628006 "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaafi-9714-R (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri N. Arjun Raj (Advocate) – Ld.Ar ""थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 26-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 21-05-2025 आदेश / O R D E R

Section 153A is limited to only undisclosed income on the basis of seized materials 3.2 The Ld.CIT(A) erred in failing to appreciate that on the issue of addition to be made in the assessments framed u/s.153A on the basis of seized materials, the SLP filed by the Revenue has been accepted the Hon'ble Apex Court in the case

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

Section 153A of the Act was issued to the Respondent Assessee, an entity created on demerger of rubber thread unit of Dharampal Satyapal Ltd. (DSL). The Assessee, in the return filed in response to the notice, declared a loss in each of the AYs. The Assessee claimed depreciation

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

153A of the Income Tax Act, 1961 (the Act) on the basis that there was\nno incriminating material qua the Assessee.\n4. The facts in brief are that a search was conducted on 21tJanuary, 2011 in\nDharampal Satyapal group of cases. Consequent thereto, a notice under Section\n153A of the Act was issued to the Respondent Assessee, an entity created

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

153A, and in the facts\nof the instant case, there exists no concealment in such return,\nsince the said additional income was not on the basis of any\nincriminating material found for the impugned assessment year\nduring the course of search at the premises of the assessee.\nAccordingly, we are of the considered view that the penalty\nsought

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

153A, and in the facts\nof the instant case, there exists no concealment in such return,\nsince the said additional income was not on the basis of any\nincriminating material found for the impugned assessment year\nduring the course of search at the premises of the assessee.\nAccordingly, we are of the considered view that the penalty\nsought

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

153A, and in the facts\nof the instant case, there exists no concealment in such return,\nsince the said additional income was not on the basis of any\nincriminating material found for the impugned assessment year\nduring the course of search at the premises of the assessee.\nAccordingly, we are of the considered view that the penalty\nsought

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

153A, and in the facts\nof the instant case, there exists no concealment in such return,\nsince the said additional income was not on the basis of any\nincriminating material found for the impugned assessment year\nduring the course of search at the premises of the assessee.\nAccordingly, we are of the considered view that the penalty\nsought

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

153A, and in the facts\nof the instant case, there exists no concealment in such return,\nsince the said additional income was not on the basis of any\nincriminating material found for the impugned assessment year\nduring the course of search at the premises of the assessee.\nAccordingly, we are of the considered view that the penalty\nsought

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

153A, and in the facts\nof the instant case, there exists no concealment in such return,\nsince the said additional income was not on the basis of any\nincriminating material found for the impugned assessment year\nduring the course of search at the premises of the assessee.\nAccordingly, we are of the considered view that the penalty\nsought

JESUDASON BIJI ,CHENNAI vs. OFFICE OF INCOME TAX OFFICER INT. TAXN WARD1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

depreciation allowance or any other allowance or deduction for such assessment year ( hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year). Explanation.—For the purposes of assessment or reassessment or recomputation under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

Section 68) are solely based on information already available in the return filed by the assessee and are not supported by any incriminating documents ITA Nos.1535 & 1801/Chny/2024 (AYs 2016-17 & 2015-16) Varadappan Natarajan/ V. Natarajan (Individual) :: 16 :: unearthed during the search. The CBDT Circular No. 24/2015 also clarifies that assessments u/s 153A should be based on seized material. Respectfully

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

Section 68) are solely based on information already available in the return filed by the assessee and are not supported by any incriminating documents ITA Nos.1535 & 1801/Chny/2024 (AYs 2016-17 & 2015-16) Varadappan Natarajan/ V. Natarajan (Individual) :: 16 :: unearthed during the search. The CBDT Circular No. 24/2015 also clarifies that assessments u/s 153A should be based on seized material. Respectfully

ACIT, CIRCLE-1,, HOSUR vs. M/S. UTHANGIRI SRI VIDHYA MANDIR EDUCATIONAL TRUST,, KRISHNAGIRI

In the result, the appeals filed by the Revenue for the assessment years 2011-12 to 2017-18 in ITA Nos

Bench: Shri Mahavir Singhand Shri Manjunatha.Gआयकर अपील सं./Ita Nos.: 370, 371 & 372 /Chny/2020 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13 & 2013-14 & C.O Nos.3, 4 & 5/Chny/2021 [In I.T.A. Nos.370, 371 & 372/Chny/2020] The Assistant M/S. Uthangarai Sri Vidya Commissioner Of Income Vs. Mandir Educational Trust, Tax, No.115, Ramamurthy Nagar, Circle-1, Uthangarai, Hosur. Krishnagiri – 635 207. Pan: Aadts 6092D (अपीलाथ"/Appellant) (""यथ"/Respondent / Cross Objector) & आयकर अपील सं./Ita Nos.: 644, 645, 646 & 647/Chny/2020 िनधा"रण वष"/Assessment Years:2014-15, 2015-16, 2016-17 & 2017-18 M/S. Uthangarai Sri Vidya The Assistant Mandir Educational Trust, Vs. Commissioner Of Income No.115, Ramamurthy Nagar, Tax, Uthangarai, Circle-1, Krishnagiri – 635 207. Hosur. Pan: Aadts 6092D (अपीलाथ"/Appellant) (""यथ"/Respondent) &

section 153A scope is to assess and reassess. 4. The Assessment u/s. 153A should be based on seized material is not accepted by the Department, and issue still before Apex Court. 5. Brief facts are that the assessee trust is running a school namely Sri Vidya Mandir Matriculation Higher Secondary School which was started in 1987. During the relevant period