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)

80,000.00 which was in violation of Section 269SS of the Act, attracting penalty under Section 271D of the Act. 17. Before we advert to the reply submitted by the petitioner, we may mention that under Section 269SS of the Act, no person shall take or accept from any other person (referred to as a depositor) any loan or deposit

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)

80,000.00 which was in violation of Section 269SS of the Act, attracting penalty under Section 271D of the Act. 17. Before we advert to the reply submitted by the petitioner, we may mention that under Section 269SS of the Act, no person shall take or accept from any other person (referred to as a depositor) any loan or deposit

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)

80,000.00 which was in violation of Section 269SS of the Act, attracting penalty under Section 271D of the Act. 17. Before we advert to the reply submitted by the petitioner, we may mention that under Section 269SS of the Act, no person shall take or accept from any other person (referred to as a depositor) any loan or deposit

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

80 (Delhi)\nShanbhag Restaurant v. DCIT [2004] 134 TAXMAN 495 (Karnataka)\n15. The Ld. AR further submitted that, the Revenue's contention that,\nthe date of initiation of penalty cannot be reckoned from the date on\nwhich the AO records his satisfaction, because the AO is not the\ncompetent authority to levy penalty, has been examined and answered in\nthe

PENTA MEDIA GRAPHICS LTD.,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1402/Chny/2015 िनधा"रण वष"/Assessment Year: 2000-01 M/S. Penta Media Graphics Ltd., The Deputy Commissioner Of ‘Taurus’, No. 25, First Main Road, Vs. Income Tax, Media Circle I, Room No. 311, 3Rd Floor, New Block, United India Colony, Kodambakkam, Chennai 600 024. 121, Mahatma Gandhi Road, Nungambakkam, Chennai 600 034. [Pan: Aaacp1647B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Baskar, Advocate & : Smt. Sree Valli Lakshmi, Advocate ""थ" की ओर से/Respondent By None [Dept. Letter Submission] : सुनवाई की तारीख/ Date Of Hearing 12.04.2023 : घोषणा की तारीख /Date Of Pronouncement : 10.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai Dated 30.03.2015 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

u/s 271(1)(c) since the same proceeds only on a different interpretation of the statutory position . 6. The Commissioner of Income-tax (Appeals) ought to have noted that the quantum of Royalty as well as the manner of computation thereof had been estimated by various officer of the department and this estimation cannot be the basis of the levy

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

80,886/- requires no\ninterference. According, to the Revenue the presumption is that, the jewellery belongs\nto the person, in whose premises it was found at the time of search. It is pertinent to\nstate that the jewellery was never found in the premises of the assessee. Rather, it was\nfound at the premises of assessee's father

SILUVAIKANI CHELLIAH,CHENGALPATTU vs. ITO, NCW-22(6),, TAMBARAM

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

u/s 271D for violating section 269SS held as under: “22. From an analysis of Sections 271D and 271E of the Act, it is seen that both the provisions are pari materia to each other. While Section 271D of the Act would be attracted on a person accepting loan or deposit or specified sum in contravention of Section 269SS

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

80,886/- requires no\ninterference. According, to the Revenue the presumption is that, the jewellery belongs\nto the person, in whose premises it was found at the time of search. It is pertinent to\nstate that the jewellery was never found in the premises of the assessee. Rather, it was\nfound at the premises of assessee's father

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

80,886/- requires no\ninterference. According, to the Revenue the presumption is that, the jewellery belongs\nto the person, in whose premises it was found at the time of search. It is pertinent to\nstate that the jewellery was never found in the premises of the assessee. Rather, it was\nfound at the premises of assessee's father

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

P. KALAISELVI ,POLUR vs. ACIT , VELLORE

In the result, appeal filed by the assessee is dismissed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Arun Khodpia, Hon’Bleआयकर अपील सं./Ita No.984/Chny/2022 िनधा"रण वष" /Assessment Year: 2017-18 V. Ms.Palani Kalai Selvi, The Asst. Commissioner – No.2A, Old No.7, Of Income Tax, Abdul Sukkur St., Circle-1, Polur-606 608. Vellore. [Pan: Bcapk 5385 B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : None ""थ" की ओर से /Respondent By : Mr.P. Sajit Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 14.03.2023 घोषणा की तारीख /Date Of Pronouncement : 14.03.2023

271 B, respectively. 2.6 The AO ought to have appreciated that the delay in completion of audit for the earlier year ending 31.3.2016 only on 30.9.2017 was a reasonable cause for the delay in the audit for the year ending 31.3.2017 - Roopali Dyeing and Printing Works vs AO - February 96 BCAJ 784; CIT vs Tea King 123 Taxman

REDINGTON DISTRIBUTIONS PTE LTD.,SINGAPORE vs. ACIT, INTL TAXN CIRCLE-2(1), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

80% of the attributed profits was withdrawn and the remaining was confirmed, as agreed between the Competent authorities of both the countries. The AO is noted to have initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution for AYs 2011-12 to 2016-17 and penalty under the new penal

M/S. REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. ACIT, INTL TAXN CIRCLE-2(1), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

80% of the attributed profits was withdrawn and the remaining was confirmed, as agreed between the Competent authorities of both the countries. The AO is noted to have initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution for AYs 2011-12 to 2016-17 and penalty under the new penal

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. ACIT, INTL TAXN CIRCLE-2(1), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

80% of the attributed profits was withdrawn and the remaining was confirmed, as agreed between the Competent authorities of both the countries. The AO is noted to have initiated and levied penalty u/s 271(1)(c) in relation to the addition finally confirmed under the MAP resolution for AYs 2011-12 to 2016-17 and penalty under the new penal

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

80,636/- as unexplained cash gift by correctly following provisions of section and legal precedents on this issue. Once the amount is held taxable u/s 68, no fault can be found with AO in applying tax rate as per provisions of section 115BBE of IT Act as it is inserted vide Finance Act, 2012 and applicable in case of income

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

80,636/- as unexplained cash gift by correctly following provisions of section and legal precedents on this issue. Once the amount is held taxable u/s 68, no fault can be found with AO in applying tax rate as per provisions of section 115BBE of IT Act as it is inserted vide Finance Act, 2012 and applicable in case of income

M JAYAPRAKASH,CHENNAI vs. DCIT, NCC-8(1), CHENNAI

In the result, all the five appeals filed by the assessee are stands dismissed

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred before the CIT(A), who vide impugned order confirmed the action of the assessing Page - 3 - of 6 ITA No.3525,3526,3527,3528 & 3529/Chny/2025 officer. Being aggrieved, the appellant is in appeal before us in the present appeal

M. JAYAPRAKASH,CHENNAI vs. DCIT, NCC-8(1), CHENNAI

In the result, all the five appeals filed by the assessee are stands dismissed

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred before the CIT(A), who vide impugned order confirmed the action of the assessing Page - 3 - of 6 ITA No.3525,3526,3527,3528 & 3529/Chny/2025 officer. Being aggrieved, the appellant is in appeal before us in the present appeal

M. JAYAPRAKASH,CHENNAI vs. DCIT, NCC-8(1), CHENNAI

In the result, all the five appeals filed by the assessee are stands dismissed

Bench: Hon’Ble Shri Inturi Rama Rao & Shri Ss Viswanethra Ravi

80,740/- u/s 271(1)(C) vide order dated 14.09.2022. 7.0 Being aggrieved by the levy of penalty, an appeal was preferred before the CIT(A), who vide impugned order confirmed the action of the assessing Page - 3 - of 6 ITA No.3525,3526,3527,3528 & 3529/Chny/2025 officer. Being aggrieved, the appellant is in appeal before us in the present appeal