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

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

cash deposits in the hands of the assessee. The additions were confirmed in first appellate order. 4.2 Consequently, penalty proceedings were initiated against the assessee and notice u/s 274 r.w.s. 271

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

K.GURUMURTHY,CHENNAI vs. ITO NON CORPORATE WARD 11(4), CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

271 (1) (C) R.W.S 129 OF THE INCOME TAX ACT, 1961 PAN: AATPG7393J/ NCW-11(4)/ REMAND REPORT/2018-19 Dated: 30/07/2018 To The Commissioner Of Income-Tax (Appeals)-13, 121, Mahatma Gandhi Road, Chennai-600 034. Respected Sir, : ITA Nos.2921 & 2922/Chny/2018 :- 9 -: Sub: Remand Report in the case of Shri. K. Gurumuthy-PAN: AAIPG7393J – AY: 2011-12 - reg. Ref: Remand report

K.GURUMURTHY,CHENNAI vs. ITO NON CORPORATE WARD 11(4), CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

271 (1) (C) R.W.S 129 OF THE INCOME TAX ACT, 1961 PAN: AATPG7393J/ NCW-11(4)/ REMAND REPORT/2018-19 Dated: 30/07/2018 To The Commissioner Of Income-Tax (Appeals)-13, 121, Mahatma Gandhi Road, Chennai-600 034. Respected Sir, : ITA Nos.2921 & 2922/Chny/2018 :- 9 -: Sub: Remand Report in the case of Shri. K. Gurumuthy-PAN: AAIPG7393J – AY: 2011-12 - reg. Ref: Remand report

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, 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, 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