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-:

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

SMT A LATHA ,COIMBATORE vs. ACIT CENTRAL CIRCLE 2, COIMBATORE

In the result, appeal filed by the assessee for assessment

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos. 1223/Chny/2018, 3 & 39/Chny/2018 ("नधा"रणवष" / Assessment Years: 2014-15, 2014-15 & 2015-16) Smt. A. Latha, Vs Assistant Commissioner Of No.112, Gopal Layout Income Tax, Ponniayarajapuram Central Circle-2 Coimbatore-641 002. Coimbatore. Pan: Abvpl 0483E (अपीलाथ"/Appellant) (""यथ"/Respondent)

money has been used to make payment to Shri Ashok Kumar. Therefore, we are of the considered view that additions made by the Assessing Officer towards advance payment made to Mr. K.Thangavelu on the basis of sale agreement dated 07.02.2014 is not correct. 11. Coming back to additions made by the learned CIT(A). The learned CIT(A) made addition

A LATHA,COIMBATORE vs. ACIT CETRAL CIRCLE - 2,, COIMBATORE

In the result, appeal filed by the assessee for assessment

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos. 1223/Chny/2018, 3 & 39/Chny/2018 ("नधा"रणवष" / Assessment Years: 2014-15, 2014-15 & 2015-16) Smt. A. Latha, Vs Assistant Commissioner Of No.112, Gopal Layout Income Tax, Ponniayarajapuram Central Circle-2 Coimbatore-641 002. Coimbatore. Pan: Abvpl 0483E (अपीलाथ"/Appellant) (""यथ"/Respondent)

money has been used to make payment to Shri Ashok Kumar. Therefore, we are of the considered view that additions made by the Assessing Officer towards advance payment made to Mr. K.Thangavelu on the basis of sale agreement dated 07.02.2014 is not correct. 11. Coming back to additions made by the learned CIT(A). The learned CIT(A) made addition

A LATHA,COIMBATORE vs. -, COIMBATORE

In the result, appeal filed by the assessee for assessment

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos. 1223/Chny/2018, 3 & 39/Chny/2018 ("नधा"रणवष" / Assessment Years: 2014-15, 2014-15 & 2015-16) Smt. A. Latha, Vs Assistant Commissioner Of No.112, Gopal Layout Income Tax, Ponniayarajapuram Central Circle-2 Coimbatore-641 002. Coimbatore. Pan: Abvpl 0483E (अपीलाथ"/Appellant) (""यथ"/Respondent)

money has been used to make payment to Shri Ashok Kumar. Therefore, we are of the considered view that additions made by the Assessing Officer towards advance payment made to Mr. K.Thangavelu on the basis of sale agreement dated 07.02.2014 is not correct. 11. Coming back to additions made by the learned CIT(A). The learned CIT(A) made addition

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

property at Coimbatore. The Ld. representative further submitted that by telescoping the income earned by the assessee for all the years under consideration, the investment made by the assessee cannot at all be treated as undisclosed income. According to the Ld. representative, at page 178 of the seized material KS/B&D/S-6 Shri V.T. Elangovan mentioned some figures. This writing made

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

property at Coimbatore. The Ld. representative further submitted that by telescoping the income earned by the assessee for all the years under consideration, the investment made by the assessee cannot at all be treated as undisclosed income. According to the Ld. representative, at page 178 of the seized material KS/B&D/S-6 Shri V.T. Elangovan mentioned some figures. This writing made

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

property at Coimbatore. The Ld. representative further submitted that by telescoping the income earned by the assessee for all the years under consideration, the investment made by the assessee cannot at all be treated as undisclosed income. According to the Ld. representative, at page 178 of the seized material KS/B&D/S-6 Shri V.T. Elangovan mentioned some figures. This writing made

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

property at Coimbatore. The Ld. representative further submitted that by telescoping the income earned by the assessee for all the years under consideration, the investment made by the assessee cannot at all be treated as undisclosed income. According to the Ld. representative, at page 178 of the seized material KS/B&D/S-6 Shri V.T. Elangovan mentioned some figures. This writing made

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

property at Coimbatore. The Ld. representative further submitted that by telescoping the income earned by the assessee for all the years under consideration, the investment made by the assessee cannot at all be treated as undisclosed income. According to the Ld. representative, at page 178 of the seized material KS/B&D/S-6 Shri V.T. Elangovan mentioned some figures. This writing made

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. SUBBIAH NADAR JEGATHEESAN, TIRUNELVELI

In the result, appeal filed by the Revenue stands dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:603/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income Subbiah Nadar Jegatheesan, Tax, Vs. 3, Ml Theri Road, Keeraikaranthattu, Central Circle -2, Mahadevankulam, Madurai. Tirunelveli – 627 657. [Pan:Abxpj-7672-F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. ""थ" की ओर से/Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख/Date Of Pronouncement : 09.07.2025

unexplained is untenable and not legally sustainable. Accordingly, we are of the considered opinion that the explanation offered by the assessee merits acceptance, and no adverse inference can be drawn solely on the basis of suspicion or absence of further corroborative evidence. Our above view has been asserted by the following judicial precedents. 33. The Hon’ble Karnataka High Court

P RAMASAMY,KUMBAKONAM vs. ITO, WARD-1(1), KUMBAKONAM

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

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri G. Manjunathaआयकर अपील सं./Ita No.3156/Chny/2018 िनधा"रण वष" /Assessment Year: 2001-02 Mr.P.Ramasamy, V. The Income Tax Officer, No.27/29, 2Nd Street, Ward-I(1), Thiruvalluvar Nagar, Kumbakonam. Kumbakonam. [Pan: Aaipr 7169 P] (अपीलाथ"/Appellant) (""यथ"/Respondent)

house property. The AO after considering relevant submissions of the assessee, has completed the assessment u/s.143(3) :: 3 :: r.w.s.254 of the Act on 28.03.2013 and made various additions, including addition towards unexplained investment for purchase of property at Rs.7.00 lakhs, unexplained investment in cost of construction and addition towards agricultural income, etc. The assessee carried the matter in appeal before

V.BALACHANDRAN ,CUDDALORE vs. ITO , INTERNATIONAL TAXATION WARD 1 (1) , CHENNAI

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

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita No.: 717/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18 Balachandran Venugopal, Income Tax Officer, C/O. Mr.S. Ramanathan, V. International Taxation-Ward 31/15, Mosque Street, 1(1), Puthupalayam, Chennai. Cuddalore – 607 001. [Pan: Ccypb-7250-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Y. Sridhar, Ca ""यथ" क" ओर से/Respondent By : Shri. P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 16.01.2023 घोषणा क" तारीख/Date Of Pronouncement : 16.01.2023

house property and earlier withdrawals from same bank accounts. The AO has accepted explanation of the assessee and out of Rs. 16,83,000/-, a sum of Rs. 9,90,000/- has been accepted. The balance amount of Rs. 6,93,000/- has been treated as unexplained money

DEPUTY COMMISSIONER OF INCOME-TAX, NON-CORPORATE CIRCLE 7(1), CHENNAI vs. KUMARASAMY PILLAI APARNA, CHENNAI

In the result the appeal of the revenue is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 999/Chny/2023 िनधा"रणवष" / Assessment Year: 2016-17 Kumarasamy Pillai Aparna, Deputy Commissioner Of V. No. 43, Kannadasan Salai, Income Tax, T.Nagar, Srds, Non-Corporate Circle -7(1), Chennai – 600 017. Chennai. [Pan:Afzpa-9359-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. R. Vikneswaran, Jcit ""यथ"क"ओरसे/Respondent By : Shri. T. Vasudevan, Advocate सुनवाई क" तारीख/Date Of Hearing : 03.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.07.2024 आदेश /O R D E R

money. No doubt, such contractual right can be surrendered or neutralized by the :-6-: ITA. No:999/Chny/2023 parties through subsequent contract or conduct leading to no transfer of the property to the proposed vendee but that is not the case a hand. 22. In addition to the fact that the term "transfer" has been defined under, Section

BSR BUILDERS ENGINEERS CONTRACTORS,,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

money flowed to M/s BSR Builders apart from the amounts mentioned in the agreement. 7. The reply to Question No.6 as given by the assessee was as follows: - Q. No.6 During the course of search proceedings conducted at the First Floor, No.49/20, Perianna Maistry Street, Periamedu, Chennai - 600 003 some loose sheets were found and seized vide ANN/KVK/SPS/LS/S-1 (pages

BSR BUILDERS ENGINEERS CONTRACTORS, ,CHENNAI vs. DCIT, CENT. CIRCLE-2(3), CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

money flowed to M/s BSR Builders apart from the amounts mentioned in the agreement. 7. The reply to Question No.6 as given by the assessee was as follows: - Q. No.6 During the course of search proceedings conducted at the First Floor, No.49/20, Perianna Maistry Street, Periamedu, Chennai - 600 003 some loose sheets were found and seized vide ANN/KVK/SPS/LS/S-1 (pages

DCIT, CHENNAI vs. BSR BUILDERS ENGINEERS CONTRACTORS, CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

money flowed to M/s BSR Builders apart from the amounts mentioned in the agreement. 7. The reply to Question No.6 as given by the assessee was as follows: - Q. No.6 During the course of search proceedings conducted at the First Floor, No.49/20, Perianna Maistry Street, Periamedu, Chennai - 600 003 some loose sheets were found and seized vide ANN/KVK/SPS/LS/S-1 (pages

ACIT, CHENNAI vs. M/S. BSR BUILDERS ENGINEERS CONTRACTORS , CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

money flowed to M/s BSR Builders apart from the amounts mentioned in the agreement. 7. The reply to Question No.6 as given by the assessee was as follows: - Q. No.6 During the course of search proceedings conducted at the First Floor, No.49/20, Perianna Maistry Street, Periamedu, Chennai - 600 003 some loose sheets were found and seized vide ANN/KVK/SPS/LS/S-1 (pages

MRS.JOTHI NARAYANAN ,CHENNAI vs. ACIT , CHENNAI

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

house at Rs.1.20 lakhs and divided among himself and his wife and declared Rs.60,000/- from this property and none of the authorities below have carried out this exercise of computing the correct market value, we feel that on estimate deemed rental income cannot be added u/s.24 of the Act. Hence, we delete the addition and allow this issue