DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

cash amounting to Rs. 17,00,00,000/- by the appellant from Shri. Anbuchezian. The levy of penalty has been challenged by the appellant on legal grounds as well as on merits. 17. One of the legal grounds advanced by the appellant by way of Additional Ground of appeal No.2 is that the penalty proceedings

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

cash amounting to Rs. 17,00,00,000/- by the appellant from Shri. Anbuchezian. The levy of penalty has been challenged by the appellant on legal grounds as well as on merits. 17. One of the legal grounds advanced by the appellant by way of Additional Ground of appeal No.2 is that the penalty proceedings

DCIT, CENTRALCIRCLE-2(2), CHENNAI vs. SUBRAMANIAM THANU, CHENNAI

In the result, all the appeals filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.785, 786, 787 & 788/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16 & 2016-17 & C.O. Nos. 40, 41, 42 & 43/Chny/2023 (In I.T.A. Nos.785 To 788/Chny/2023)

cash amounting to Rs. 17,00,00,000/- by the appellant from Shri. Anbuchezian. The levy of penalty has been challenged by the appellant on legal grounds as well as on merits. 17. One of the legal grounds advanced by the appellant by way of Additional Ground of appeal No.2 is that the penalty proceedings

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, appeal filed by the Revenue is dismissed and the\nCross-Objection filed by the assessee is allowed

cash\nFDs from these 111 persons and therefore deleted the penalty of Rs.\n28,94,71,555/- vide his appellate order dated 07.04.2025.\n6. Being aggrieved by the order of the Ld. CIT(A), the Revenue has\nfiled the present appeal wherein it has raised the following grounds:-\n\"1. The Order of the learned Commissioner of Income Tax (Appeals

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

depositions were\nrecorded from Shri P. Suresh Kumar, Purchase Manager, and Smt.\nVasanthi, Cashier, wherein they deposed that the management\nhad provided cash to employees and other associated persons of\nthe group, who, in turn, remitted the amounts to the Trust\nthrough cheques and/or other banking channels. Further, a sworn\nstatement was recorded from the assessee on 20.07.2021,\nwherein

MUTHURATHINAM,TIRUPPUR vs. ITO, WARD-1(2), TIRUPPUR

In the result, appeal filed by the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2656/Chny/2024 (िनधा"रणवष" / Assessment Year: 2013-2014) Muthurathinam, Vs. The Income Tax Officer, 27/29, Kumarappapuram, Ward 1(2) 1St Street, Rayapuram Extension, Tirupur. Tirupur 641 601. [Pan: Avypm 0862D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S. Sridhar, (Erode) Advocate By Virtual. ""यथ" क" ओर से /Respondent By : Ms. Anitha, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 31.12.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.01.2025 आदेश / O R D E R Per Manu Kumar Giri () This Penalty Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi [Cit(A)] Dated 21.08.2024 For Assessment Year 2013-14. 2. The Issue Sought To Be Urged By The Assessee In This Appeal Is Whether The Cit(A) Was Justified In Upholding The Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 ["Act"] By Ignoring The Fact That The Assessing Officer (‘Ao’ In Short) In Assessment Order Dated 28.09.2021 Has Satisfied That Penalty Proceeding Is Being Initiated Separately For “Furnishing Of Inaccurate Particulars Of Such Income” Where As Penalty Order U/S 271(1)(C) Dated 04.01.2022 Levied Penalty For “Concealment Of Income”, Although In The Notice Under Section 274 Read With Section 271(1) (C), The Ao Has Marked The Specified Limb As “That You Have Furnished Inaccurate Particulars Of Such Income”.

u/s 271(1)(c) dated 04.01.2022 levied penalty for “concealment of income”, although in the notice under Section 274 read with Section 271(1) (c), the AO has marked the specified limb as “that you have furnished inaccurate particulars of such income”. 3. For the sake of convenience, it will be apposite to refer to the facts of the case

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

depositions were\nrecorded from Shri P. Suresh Kumar, Purchase Manager, and Smt.\nVasanthi, Cashier, wherein they deposed that the management\nhad provided cash to employees and other associated persons of\nthe group, who, in turn, remitted the amounts to the Trust\nthrough cheques and/or other banking channels. Further, a sworn\nstatement was recorded from the assessee on 20.07.2021,\nwherein

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

depositions were\nrecorded from Shri P. Suresh Kumar, Purchase Manager, and Smt.\nVasanthi, Cashier, wherein they deposed that the management\nhad provided cash to employees and other associated persons of\nthe group, who, in turn, remitted the amounts to the Trust\nthrough cheques and/or other banking channels. Further, a sworn\nstatement was recorded from the assessee on 20.07.2021,\nwherein

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

depositions were\nrecorded from Shri P. Suresh Kumar, Purchase Manager, and Smt.\nVasanthi, Cashier, wherein they deposed that the management\nhad provided cash to employees and other associated persons of\nthe group, who, in turn, remitted the amounts to the Trust\nthrough cheques and/or other banking channels. Further, a sworn\nstatement was recorded from the assessee on 20.07.2021,\nwherein

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

depositions were\nrecorded from Shri P. Suresh Kumar, Purchase Manager, and Smt.\nVasanthi, Cashier, wherein they deposed that the management\nhad provided cash to employees and other associated persons of\nthe group, who, in turn, remitted the amounts to the Trust\nthrough cheques and/or other banking channels. Further, a sworn\nstatement was recorded from the assessee on 20.07.2021,\nwherein

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

depositions were\nrecorded from Shri P. Suresh Kumar, Purchase Manager, and Smt.\nVasanthi, Cashier, wherein they deposed that the management\nhad provided cash to employees and other associated persons of\nthe group, who, in turn, remitted the amounts to the Trust\nthrough cheques and/or other banking channels. Further, a sworn\nstatement was recorded from the assessee on 20.07.2021,\nwherein

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

Penalty proceedings u/s 271(1)(c) are independent proceedings, can't be adjudicated here. Consequently, Ground of appeal is Dismissed. 8. As a result, appeal of appellant is Dismissed. 12. The assessee contended that all the additions are not based on any seized/incriminating material relating to the assessee. The search was primarily conducted in the premises of the Pavai Varam

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

Penalty proceedings u/s 271(1)(c) are independent proceedings, can't be adjudicated here. Consequently, Ground of appeal is Dismissed. 8. As a result, appeal of appellant is Dismissed. 12. The assessee contended that all the additions are not based on any seized/incriminating material relating to the assessee. The search was primarily conducted in the premises of the Pavai Varam

THIMMAIYA GOPALUDU,KRISHNAGIRI vs. ITO, WARD 1, HOSUR, HOSUR

In the result, both the appeals filed by the assessee are partly allowed

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita Nos.2773 & 2774/Chny/2024 िनधा"रण वष" /Assessment Years: 2012-13

cash deposits without considering the withdrawals made from the same bank account, which were available for redeposit. We find merit in the submission of the Ld. AR that only the peak credit should have been considered, which comes to Rs.16,00,000/-. The Ld AR has explained the source of the deposit as arising from his past savings

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

u/s 274 r.w.s 271 was a vague notice in a printed form without specifying the exact charge for which the assessee was being penalized and therefore, it was a clear case of non-application of mind while initiating penalty against the assessee. The Ld. AO, while initiating the penalty was not clear as to specific limb which was applicable

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

u/s 274 r.w.s 271 was a vague notice in a printed form without specifying the exact charge for which the assessee was being penalized and therefore, it was a clear case of non-application of mind while initiating penalty against the assessee. The Ld. AO, while initiating the penalty was not clear as to specific limb which was applicable

THAMIRA GREEN FARMS P. LTD.,CHENNAI vs. ADDL.CIT CORPORATE RANGE 3 , CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1845/Chny/2018 िनधा"रण वष" / Assessment Year: 2008-09 M/S. Thamira Green Farm P The Additional Commissioner Of Ltd., V. Income Tax, No. 1824/4, Gautham Corporate Range -3, Apartments, 1St Floor, Chennai. 18Th Main Road, Anna Nagar West, Chennai – 600 040. [Pan: Aacct-7926-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. S. Sridhar, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. Ar V Sreenivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 12.07.2023 घोषणा क" तारीख/Date Of Pronouncement : 22.09.2023 आदेश /O R D E R

271 D of the Act. 6. The CIT (Appeals) failed to appreciate that the provisions of section 273B of the Act were completely missed while considering the necessity and compulsion for entering into the transaction with the Director/share holder and ought to have appreciated that the penalty under consideration for any violation of the provisions of section 269SS

THIMMAIYA GOPALUDU,KRISHNAGIRI vs. ITO, WARD-1,, HOSUR

In the result, both the appeals filed by the assessee are partly\nallowed

u/s.\n271(1)(c) of the Act were initiated for concealment of income. The Ld.\nDR further pointed out that notice issued u/s.274 r.w.s 271(1)(c) of the\nAct, the additional remarks specifically mentioned that the penalty was\nbeing initiated for concealment of income.\n12. We have heard the rival submissions, and perused the materials\navailable on record

R V R NAGESH LEGAL HEIR OF LATE VENGATTARAYALU RAJAN,KANCHIPURAM vs. INCOME TAX OFFICER, NON CORP WARD - 22(4), TAMBARAM, TAMBARAM

In the result, the appeal of the assessee is allowed

u/s 274 r.w.s 271 was\na vague notice in a printed form without specifying the exact charge for which the\nassessee was being penalized and therefore, it was a clear case of non-application of\nmind while initiating penalty against the assessee. The Ld. AO, while initiating the\npenalty was not clear as to specific limb which was applicable