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

150/- Add: Disallowance of interest unrelated to Rs. 8,93,642/- profession Income assessed u/s 143(3) r.w.s 153A Rs. 5,35,492/- Tuition income as undisclosed income u/s 68 Rs. 10,65,970/- Gift received as undisclosed income u/s 68 Rs. 24,80,636/- Receipts from friends and relatives u/s 68 Rs. 50,50,000/- Long Term Capital gain

KEB HANA BANK,CHENNAI vs. JOINT DIRECTOR OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the Reporting Entity are allowed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. Nos.440, 441 & 442/Chny/2023 िनधा"रण वष"/Assessment Years: 2018-19, 2019-20 & 2020-21 Keb Hana Bank, Vs. The Joint Director Of 4Th Floor, Bannari Amman Towers, Income Tax, Dr.R.K. Salai, Mylapore, Intelligence & Criminal Investigation, Chennai, Tamil Nadu 600 004. Chennai. [Pan:Aadck4261D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Va Mehta, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 12.07.2023 घोषणा की तारीख /Date Of Pronouncement : 10.08.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Assessee Are Directed Against Separate But Identical Orders Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, All Dated 09.02.2023 Relevant To The Assessment Years 2018-19, 2019-20 & 2020-21 Passed Under Section 271Faa Of The Income Tax Act, 1961 [“Act” In Short] Levying Penalty Of ₹.50,000/- For Each Calendar Years 2017, 2018 & 2019. 2

u/s 271FAA was introduced to ensure due compliance to this 'Due diligence' requirement considering the seriousness of such reporting requirement as per the tax treaties with various countries on exchange of information. The captioned assessee in appeal, a foreign bank was found, under reporting of certain reportable transactions of three Calendar years 2018, 2019 and 2020. This was detected during

KEB HANA BANK,CHENNAI vs. JOINT DIRECTOR OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the Reporting Entity are allowed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. Nos.440, 441 & 442/Chny/2023 िनधा"रण वष"/Assessment Years: 2018-19, 2019-20 & 2020-21 Keb Hana Bank, Vs. The Joint Director Of 4Th Floor, Bannari Amman Towers, Income Tax, Dr.R.K. Salai, Mylapore, Intelligence & Criminal Investigation, Chennai, Tamil Nadu 600 004. Chennai. [Pan:Aadck4261D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Va Mehta, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 12.07.2023 घोषणा की तारीख /Date Of Pronouncement : 10.08.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Assessee Are Directed Against Separate But Identical Orders Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, All Dated 09.02.2023 Relevant To The Assessment Years 2018-19, 2019-20 & 2020-21 Passed Under Section 271Faa Of The Income Tax Act, 1961 [“Act” In Short] Levying Penalty Of ₹.50,000/- For Each Calendar Years 2017, 2018 & 2019. 2

u/s 271FAA was introduced to ensure due compliance to this 'Due diligence' requirement considering the seriousness of such reporting requirement as per the tax treaties with various countries on exchange of information. The captioned assessee in appeal, a foreign bank was found, under reporting of certain reportable transactions of three Calendar years 2018, 2019 and 2020. This was detected during

KEB HANA BANK,CHENNAI vs. JOINT DIRECTOR OF INCOME TAX, CHENNAI

In the result, all the appeals filed by the Reporting Entity are allowed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. Nos.440, 441 & 442/Chny/2023 िनधा"रण वष"/Assessment Years: 2018-19, 2019-20 & 2020-21 Keb Hana Bank, Vs. The Joint Director Of 4Th Floor, Bannari Amman Towers, Income Tax, Dr.R.K. Salai, Mylapore, Intelligence & Criminal Investigation, Chennai, Tamil Nadu 600 004. Chennai. [Pan:Aadck4261D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Va Mehta, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 12.07.2023 घोषणा की तारीख /Date Of Pronouncement : 10.08.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Assessee Are Directed Against Separate But Identical Orders Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, All Dated 09.02.2023 Relevant To The Assessment Years 2018-19, 2019-20 & 2020-21 Passed Under Section 271Faa Of The Income Tax Act, 1961 [“Act” In Short] Levying Penalty Of ₹.50,000/- For Each Calendar Years 2017, 2018 & 2019. 2

u/s 271FAA was introduced to ensure due compliance to this 'Due diligence' requirement considering the seriousness of such reporting requirement as per the tax treaties with various countries on exchange of information. The captioned assessee in appeal, a foreign bank was found, under reporting of certain reportable transactions of three Calendar years 2018, 2019 and 2020. This was detected during

PARRY INFRASTRUCTURE CO P LTD. ,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1) , CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

271(1)(c) of the Income Tax Act, 1961 in respect of the additions made to the tune of Rs.45,91,25,185/- by way of enhancement to the income returned. Penalty proceedings u/s.271(1)(c) are therefore, initiated on both counts viz., concealment of income and furnishing of inaccurate particulars of income.” Aggrieved, now assessee is in appeal before

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

u/s 131 of the Act, in our view, the same cannot be used against the , in our view, the same cannot be used against the , in our view, the same cannot be used against the assessee. As rightly pointed out by ointed out by Ld. AR, in our view, the assessee is R, in our view, the assessee is being

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

u/s 131 of the Act, in our view, the same cannot be used against the , in our view, the same cannot be used against the , in our view, the same cannot be used against the assessee. As rightly pointed out by ointed out by Ld. AR, in our view, the assessee is R, in our view, the assessee is being

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

u/s 131 of the Act, in our view, the same cannot be used against the , in our view, the same cannot be used against the , in our view, the same cannot be used against the assessee. As rightly pointed out by ointed out by Ld. AR, in our view, the assessee is R, in our view, the assessee is being

SENGODA GOUNDER HUF, SALEM,SALEM vs. DCIT, CIRCLE-1, SALEM, SALEM

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

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.1179/Chny/2023 िनधा(रण वष( /Assessment Year: 2010-11 Sengoda Gounder Huf, The Dy. Commissioner Of 6, Backside Of Collector’S Vs. Income Tax, Bungalow, Hasthampatti, Circle-1, Salem – 636 007. Salem. [Pan: Aayhs-3071-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri T. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 15.02.2024 घोषणा क" तारीख /Date Of Pronouncement : 15.03.2024

section 271(1)(c) of the Act (hereinafter “the Act”) levied by the ld. AO vide order dated 12-12-2019. :- 2 -: 2. The grounds of appeal of the assessee are as under: “1. The order of the Commissioner of Income Tax(Appeals) dismissing the appeal is contrary to law, erroneous and unsustainable on the facts of the case. 2

BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. ACIT CENTRAL CIRCLE 3(2), CHENNAI

150 2,95,28,722 38,94,321 \n2020-21 3,99,78,278 59,96,742 50,486 \nTotal 95,60,42,392 14,34,06,358 1,69,28,055 \n\n4.3 The AO further observed that Smt. V. Valliammai, in her answer to \nQuestion No. 2, had stated that, the 15% discount on the bill value

BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. ACIT CENTRAL CIRCLE 3(2), CHENNAI

150\n2,95,28,722\n38,94,321\n2020-21\n3,99,78,278\n59,96,742\n50,486\nTotal\n95,60,42,392\n14,34,06,358\n1,69,28,055\n4.3 The AO further observed that Smt. V. Valliammai, in her answer to\nQuestion No. 2, had stated that, the 15% discount on the bill value was\ngiven

DCIT , CENTRAL CIRCLE - 3, COIMBATORE vs. SHRI D VIJAY MOHAN, COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

150 taxmann.com 227 (Rajasthan); and several other decisions of this Tribunal, the Ld. CIT-DR thus contended that such retraction was not admissible. According to him, the AO had given elaborate reasoning as to why the additional income offered by way of loan & interest income from Shri Yousuf could not be adjusted/set-off against the admitted unaccounted investment of Rs.5.42 crores

DCIT , CENTRAL CIRCLE - 3, COIMBATORE vs. SMT.VANITHA MOHAN, COIMBATRE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

150 taxmann.com 227 (Rajasthan); and several other decisions of this Tribunal, the Ld. CIT-DR thus contended that such retraction was not admissible. According to him, the AO had given elaborate reasoning as to why the additional income offered by way of loan & interest income from Shri Yousuf could not be adjusted/set-off against the admitted unaccounted investment of Rs.5.42 crores

VANITHA MOHAN,COIMBATORE vs. DCIT CENTRAL CIRCLE-3, COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

150 taxmann.com 227 (Rajasthan); and several other decisions of this Tribunal, the Ld. CIT-DR thus contended that such retraction was not admissible. According to him, the AO had given elaborate reasoning as to why the additional income offered by way of loan & interest income from Shri Yousuf could not be adjusted/set-off against the admitted unaccounted investment of Rs.5.42 crores

VIJAY MOHAN,COIMBAORE vs. DCIT, CENTRAL CIRCLE-(3)(I/C), COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

150 taxmann.com 227 (Rajasthan); and several other decisions of this Tribunal, the Ld. CIT-DR thus contended that such retraction was not admissible. According to him, the AO had given elaborate reasoning as to why the additional income offered by way of loan & interest income from Shri Yousuf could not be adjusted/set-off against the admitted unaccounted investment of Rs.5.42 crores