DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

MIDAS GOLDEN DISTILLERIES P. LTD ,SRIPERUMBUDUR vs. OFFICE OF THE DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM

In the result, the appeal of the assessee is dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.2955/Chny/2024, Assessment Years: 2014-15

Section 133A would not automatically bind upon the assessee, we do not see any reason to interfere with the order of the Tribunal….” 7.0 We have noted that the statements recorded during the search proceedings have been duly compared with the incriminating documents found from the assessee’s premises. Thus, it is not a case of mere reliance upon

DCIT, OOTY vs. N.PURUSHOTHAMAN, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

disallowed under section 40A(3) of the Income Tax Act, 1961. The Assessing Officer states that certain ledgers not produced at the time of survey under section 133A

N.PURUSHOTHAMAN,COIMBATORE vs. DCIT, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

disallowed under section 40A(3) of the Income Tax Act, 1961. The Assessing Officer states that certain ledgers not produced at the time of survey under section 133A

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

Disallowance of interest expenditure Allowed (i.e., addition under Section 36(1)(iii) of the Act deleted) 14. Aggrieved by the above order of the Ld.CIT(A), the present cross appeals and cross objections are filed before us. :-8-: ITA Nos.:1339, 1616/Chny/2025 & C.O.No.66/Chny/2025 15. The Ld.AR, appearing on behalf of the assessee vehemently argued and filed the written submission

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

Disallowance of interest expenditure Allowed (i.e., addition under Section 36(1)(iii) of the Act deleted) 14. Aggrieved by the above order of the Ld.CIT(A), the present cross appeals and cross objections are filed before us. :-8-: ITA Nos.:1339, 1616/Chny/2025 & C.O.No.66/Chny/2025 15. The Ld.AR, appearing on behalf of the assessee vehemently argued and filed the written submission

DEPUTY COMMISSIONER OF INCOME TAX, INCOME TAX OFFICE, TRICHY vs. RAMASAMY SIVAPRAKASAM, KARUR

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 260A of the Act, as a matter of routine." ITA Nos.1266 & 1267/Chny/2025 (AYs 2014-15 & 2016-17) Ramasamy Sivaprakasam :: 11 :: 11. In the present case also, if the impugned purchases are disallowed, it would result in an abnormal gross profit rate of 41.55% and a distorted net profit rate of 25.45% in a regular textile export business

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

section 260A of the Act, as a matter of routine." ITA Nos.1266 & 1267/Chny/2025 (AYs 2014-15 & 2016-17) Ramasamy Sivaprakasam :: 11 :: 11. In the present case also, if the impugned purchases are disallowed, it would result in an abnormal gross profit rate of 41.55% and a distorted net profit rate of 25.45% in a regular textile export business

SELVA GOLD COVERING P LTD.,CHENNAI vs. DCIT, COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita No.3262/Mds/2016 "नधा"रण वष" / Assessment Year : 2012-13 M/S Selva Gold Covering Pvt. Ltd., C/O Shri S. Sridhar, The Deputy Commissioner Of Sh. A.S. Sriraman, Advocate , V. Income Tax, New No.14, Old No.82, Flat No.5, Corporate Circle – 2, 1St Avenue, Indira Nagar, Adyar, Coimbatore. Chennai - 600 020. Pan : Aadcs 0688 Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed under Section 40A(3) of the Act in view of the statutory provision, it cannot be said that the assessee has furnished inaccurate particulars or concealed any part of its income. Therefore, according to the Ld. counsel, it is not a case for levy of penalty under Section 271(1)(c) of the Act. 5. The Ld.counsel

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

133A. (b) His next submission was that in any event, during the survey, no incriminating material was found which may have led the revenue to exercise power under section 153C read with section 153A. 4. He contended that even when assessment is made on the basis of a search under section 132 or a requisition made under section 132A

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

133A. (b) His next submission was that in any event, during the survey, no incriminating material was found which may have led the revenue to exercise power under section 153C read with section 153A. 4. He contended that even when assessment is made on the basis of a search under section 132 or a requisition made under section 132A

M/S. LEO FASTENERS,,CHENNAI vs. ADDL. CIT,, PONDICHERRY

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

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.736/Mds/2012 "नधा"रण वष"/Assessment Year:2008-09 M/S. Leo Fasteners, The Additional Commissioner Of Rep. By Its Partner, Vs. Income Tax, Pondicherry Range, A-27A, Industrial Estate, Pondicherry. Thattanchavady, Pondicherry 605 009. [Pan:Aabfl0652J] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Smt. G. Vardhini Karthick, Advocate ""यथ" क" ओर से/Respondent By : Shri Ashish Tripathi, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 02.08.2017 घोषणा क" तार"ख /Date Of Pronouncement : 31.08.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) Xii, Chennai, Dated 23.03.2012 Relevant To The Assessment Year 2008-09, Wherein, The Assessee Has Challenged Confirmation Of Disallowance Of Deductions Claimed Under Section 80Ib As Well As 80Ia Of The Income Tax Act, 1961 [“Act” In Short].

disallowance of deductions claimed under section 80IB as well as 80IA of the Income Tax Act, 1961 [“Act” in short]. 2 I.T.A. Nos.736/M/12 2. Brief facts of the case are that the assessee is engaged in the business of power generation and manufacturing and selling of fasteners. The assessee filed its return of income on 19.09.2008 admitting NIL income

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. TAMILNADU ARYA SAMAJ EDUCATIONAL SOCIETY, CHENNAI

In the result, the appeal of the Revenue is allowed for statistical purposes

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1261/Chny/2025 Assessment Years: 2020-21 Assistant Commissioner Of Income Tamil Nadu Arya Samaj Educational Tax(Exemption), Society, Chennai No.182, Avvai Shanmugam Salai, Gopalapuram, Chennai-600 086, [Pan: Aaaat0081F]

Section 133A cannot be sole basis for making an addition or disallowance without corroborating evidence. In this case, the authorities

K BABU,CHENNAI vs. ACIT, CIRCLE-1, CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.181/Chny/2019 िनधा"रण वष"/Assessment Year:2005-06 Shri K. Babu, The Assistant Commissioner Of No.12, M G Thennavan Street, Vs. Income Tax, Pon Gabriel Nagar, Nagalkeni, Circle 1, Chrompet, Chennai. Tambaram. [Pan:Aafpb8597G] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Guru Bashyam, Jcit सुनवाई की तारीख/ Date Of Hearing : 26.06.2019 घोषणा की तारीख /Date Of Pronouncement : 19.07.2019 आदेश /O R D E R Per Duvvuru Rl Reddy:

disallowance made under section 40A(3) of the Income Tax Act, 1961 [“Act” in short] towards payments made in cash exceeding ₹.20,000/-. 2 I.T.A. No.181/Chny/19 2. Brief facts of the case are that the assessee filed its return of income for the assessment year 2005-06 on 31.10.2005 declaring a total income of ₹.2,71,030/-. The return

TRISHUL SHELTERS PVT LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, the appeal of the Revenue is allowed “

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

disallowance. o It is therefore submitted that the action of the learned Assessing Officer in applying the provisions of section 69C to inventory is not in accordance with law. Submission with reference to adjusting the opening stock of next year: o It is submitted that whenever, the value of the closing stock is increased in the assessment, by making addition

K.V.VIJAYARAGHAVAN,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.456/Chny/2014 िनधा"रण वष"/Assessment Year:2005-06 Shri K.V. Vijayaraghavan, The Deputy Commissioner Of C/O. Shri T.N. Seetharaman, Vs. Income Tax, Advocate, # 384 (Old No. 196), Company Circle I(1), Lloyds Road, Chennai 600 086. Chennai. [Pan:Aclpv6440Q] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.N. Seetharaman, Advocate ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.09.2018 घोषणा की तारीख /Date Of Pronouncement : 29.10.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) I, Chennai Dated 22.11.2013 Relevant To The Assessment Year 2005-06. The Only Effective Ground Raised In The Appeal Of The Assessee Is That The Ld. Cit(A) Has Erred In Confirming The Addition Of ₹.7,34,750/- Made As “Unexplained Investment” Under Section 69 Of The Income Tax Act, 1961 [“Act” In Short].

section 133A of the Act on 07.08.2009, a sheet, vide impounded documents in ANN/LS/BS/IMP-2, shows the cost of flat as ₹.24,91,250/- with the title 'Final Statement' given by M/s. Aadhlthiya Constructions was taken from the business premises of M/s. Ambika Appalam Co. Pvt. Ltd. The assessee has not agreed with the statement of M/s. Aadhithiya Constructions, since

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

133A of the Act on 25.02.2019 stating that the trust activities were limited to sale of books, notebooks and uniforms, which clearly supports the items which are placed under "direct income" in the income and expenditure statement at page 114 of the paper book. Therefore, we hold that no new tangible information has reached the Assessing officer vide statement recorded