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)

17. We have heard rival contentions and gone through facts and circumstances of the case. The Assessing Officer, on verification of profit & loss account, noticed that theassessee has debited expenses on interest payment of Rs.3.00 lakhs to one Shri P.T.Dinakaran for unsecured loans. Since no TDS was deducted, the Assessing Officer disallowed expenses by invoking provisions of section

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)

17. We have heard rival contentions and gone through facts and circumstances of the case. The Assessing Officer, on verification of profit & loss account, noticed that theassessee has debited expenses on interest payment of Rs.3.00 lakhs to one Shri P.T.Dinakaran for unsecured loans. Since no TDS was deducted, the Assessing Officer disallowed expenses by invoking provisions of section

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10,17,517/- has been made for purchase of Gold from M/s MJPL. As per provisions of section

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10,17,517/- has been made for purchase of Gold from M/s MJPL. As per provisions of section

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10,17,517/- has been made for purchase of Gold from M/s MJPL. As per provisions of section

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10,17,517/- has been made for purchase of Gold from M/s MJPL. As per provisions of section

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10,17,517/- has been made for purchase of Gold from M/s MJPL. As per provisions of section

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10,17,517/- has been made for purchase of Gold from M/s MJPL. As per provisions of section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

Section under\n| | | | order of | assessment | which\n| | | | CIT(A) | order | assessment order\n| | | | | | was passed\n| 1 | 1872/Chny/2025 | 2013-14 | 07.04.2025 | 05.05.2021 | 153A r.w.s 143(3)\n| 2 | 1873/Chny/2025 | 2014-15 | 07.04.2025 | 05.05.2021 | 153A r.w.s 143(3)\n| 3 | 1875/Chny/2025 | 2015-16 | 09.04.2025 | 06.05.2021 | 153A r.w.s 143(3)\n| 4 | 1877/Chny/2025 | 2016-17 | 09.04.2025 | 06.05.2021 | 153A r.w.s 143(3

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

17,110\n98,24,09,751\n5. Considering the facts and circumstances of the case, we deem it\nappropriate to adjudicate upon the grounds of appeal raised by the Revenue on\nan issue-wise basis. However, before adverting to the merits of the issues\ninvolved, it would be just and proper to first address the preliminary objection\nraised

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

17,110\n98,24,09,751\n5. Considering the facts and circumstances of the case, we deem it\nappropriate to adjudicate upon the grounds of appeal raised by the Revenue on\nan issue-wise basis. However, before adverting to the merits of the issues\ninvolved, it would be just and proper to first address the preliminary objection\nraised

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

17,110\n98,24,09,751\n5. Considering the facts and circumstances of the case, we deem it\nappropriate to adjudicate upon the grounds of appeal raised by the Revenue on\nan issue-wise basis. However, before adverting to the merits of the issues\ninvolved, it would be just and proper to first address the preliminary objection\nraised

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

17,110 98,24,09,751\n5. Considering the facts and circumstances of the case, we deem it\nappropriate to adjudicate upon the grounds of appeal raised by the Revenue on\nan issue-wise basis. However, before adverting to the merits of the issues\ninvolved, it would be just and proper to first address the preliminary objection\nraised

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

17 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 through the head labourer and therefore, there was no liability to TDS. Considering the above facts and circumstances, we are of the opinion that the ld. CIT(A) has rightly deleted the disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

17 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 through the head labourer and therefore, there was no liability to TDS. Considering the above facts and circumstances, we are of the opinion that the ld. CIT(A) has rightly deleted the disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

17 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 through the head labourer and therefore, there was no liability to TDS. Considering the above facts and circumstances, we are of the opinion that the ld. CIT(A) has rightly deleted the disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

17 I.T.A. Nos.2153-2156/Chny/18 & C.O. Nos. 132-133/Chny/18 through the head labourer and therefore, there was no liability to TDS. Considering the above facts and circumstances, we are of the opinion that the ld. CIT(A) has rightly deleted the disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2150, 2151 & 2152/Chny/2018 िनधा"रण वष"/Assessment Years: 2010-11, 2011-12 & 2012-13 The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 16.04.2018 Relevant To The Assessment Years 2010-11, 2011-12 & 2012-13. 2. The Appeals Filed By The Revenue Are Delayed By Three Days, For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which The Ld. Counsel For The Assessee Has Not Raised Any Serious Objection.

section 153A of the Act, the assessee has offered only a sum of ₹.1,71,32,430/-, for taxation under the head bought note. After considering the submissions of Shri D. Kabilan, the Assessing Officer 16 I.T.A. Nos.2150-2152/Chny/18 added further amount of ₹.3,00,000/-. On appeal, the ld. CIT(A) deleted the addition. While deleting the addition