MOHAMED THAJUDEEN ABUTHAHIR,SIRKALI CHENNAI vs. ITO WARD 2, , NAGAPATTINAM CHENNAI

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

Bench: Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 650/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Mohamed Thajudeen Abuthahir, The Income Tax Officer, 17, Railway Road, V. Ward-2, Sirkali – 609 110. Nagapattinam. Tamilnadu. [Pan: Afdpa-4979-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. N. Arjun Raj, Ca ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 03.08.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.08.2023

reassessment in case where assessee had made a deposit of cash in bank during demonetization period, which was reflected in his return

VG RAJAMANI AGENCIES PVT. LTD.,COIMBATORE vs. PCIT-1, COIMBATORE

In the result, the appeal filed by the assessee is allowed and the order passed by the Commissioner dated 14

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.812/Chny/2023 (िनधा"रण वष" / Assessment Year: 2017-18) M/S. V.G. Rajamani Agencies Pvt. Ltd. Pcit-1 बनाम/ Vs. 66, Subbiah Mudaliar Street, Coimbatore. Thomas Street, Coimbatore-641 001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabcv-1589-R (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri S. Sridhar (Advocate) Erode - Ld.Ar !"थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 09-01-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

demonetization period, by not making any addition on this issue but meandering into other issues and making addition on that issue alone is not valid in the eyes of law. By not assesseing the income for which reassessment

HAMASAMANI SILKS,KANCHEEPURAM vs. ITO, WARD-1,, KANCHEEPURAM

In the result, the appeal stands partly allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:2664/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 & S.A. No.100/Chny/2025 [In I.T.A. No.2664/Chny/2025] िनधा$रण वष$ / Assessment Year: 2017-18

demonetization period has to be taxed as unexplained money and therefore, the Ld.Sr.DR requested to confirm the order of the lower authorities. 5. Having heard the rival submissions and upon perusal of case records, our adjudication would be as under. From reassessment

NEXGEN ANIMATORS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-4(1), CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri George George Kआयकर अपील सं./Ita No.: 782/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18

reassessment proceedings, the AO issued letter u/s.133(6) of the Act to the bank, where the assessee company had maintained its bank account calling for the copies of bank statements for the relevant assessment year. From the bank statement received it was noticed that assessee had made cash :- 3 -: deposit of Rs.15,50,000/- during the demonetization

SG WIND FARM PVT. LTD.,TIRUPUR vs. DCIT,CC-3,, COIMBATORE

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं. / Ita No.1227/Chny/2024 (िनधा;रणवष; / Assessment Year: 2014-15) & 2. आयकरअपील सं. / Ita No.1228/Chny/2024 (िनधा;रणवष; / Assessment Year: 2015-16) & 3. आयकरअपील सं. / Ita No.1229/Chny/2024 (िनधा;रणवष; / Assessment Year: 2016-17) & 4. आयकरअपील सं. / Ita No.1230/Chny/2024 (िनधा;रणवष; / Assessment Year: 2017-18) M/S Sg Wind Farm Private Limited Dcit बनाम/ Vs. 21, Pollachi Road, Central Circle-3 Palladam, Tirupur-641 664. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aarcs-5303-E (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S. Sridhar (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 25-10-2024 घोषणा की तारीख /Date Of Pronouncement : 19-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

demonetization as part of Rs.36 Crores that was totally repaid to Shri PK Ganeshwar. As per document seized during search on that group, outstanding quantum of loan lent by Shri PK Ganeshwar and the assessee was Rs.71.88 Crores. Out of the same, the undisclosed portion was Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which was the disclosed portion

SG WIND FAARM PVT. LTD.,,TIRUPUR vs. DCIT, CC-3,, COIMBATORE

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं. / Ita No.1227/Chny/2024 (िनधा;रणवष; / Assessment Year: 2014-15) & 2. आयकरअपील सं. / Ita No.1228/Chny/2024 (िनधा;रणवष; / Assessment Year: 2015-16) & 3. आयकरअपील सं. / Ita No.1229/Chny/2024 (िनधा;रणवष; / Assessment Year: 2016-17) & 4. आयकरअपील सं. / Ita No.1230/Chny/2024 (िनधा;रणवष; / Assessment Year: 2017-18) M/S Sg Wind Farm Private Limited Dcit बनाम/ Vs. 21, Pollachi Road, Central Circle-3 Palladam, Tirupur-641 664. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aarcs-5303-E (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S. Sridhar (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 25-10-2024 घोषणा की तारीख /Date Of Pronouncement : 19-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

demonetization as part of Rs.36 Crores that was totally repaid to Shri PK Ganeshwar. As per document seized during search on that group, outstanding quantum of loan lent by Shri PK Ganeshwar and the assessee was Rs.71.88 Crores. Out of the same, the undisclosed portion was Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which was the disclosed portion

SG WIND FARM PVT. LTD.,,TIRUPUR vs. DCIT, CC-3, COIMBATORE

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं. / Ita No.1227/Chny/2024 (िनधा;रणवष; / Assessment Year: 2014-15) & 2. आयकरअपील सं. / Ita No.1228/Chny/2024 (िनधा;रणवष; / Assessment Year: 2015-16) & 3. आयकरअपील सं. / Ita No.1229/Chny/2024 (िनधा;रणवष; / Assessment Year: 2016-17) & 4. आयकरअपील सं. / Ita No.1230/Chny/2024 (िनधा;रणवष; / Assessment Year: 2017-18) M/S Sg Wind Farm Private Limited Dcit बनाम/ Vs. 21, Pollachi Road, Central Circle-3 Palladam, Tirupur-641 664. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aarcs-5303-E (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri S. Sridhar (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 25-10-2024 घोषणा की तारीख /Date Of Pronouncement : 19-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

demonetization as part of Rs.36 Crores that was totally repaid to Shri PK Ganeshwar. As per document seized during search on that group, outstanding quantum of loan lent by Shri PK Ganeshwar and the assessee was Rs.71.88 Crores. Out of the same, the undisclosed portion was Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which was the disclosed portion

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, CHENNAI

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 548 To 552/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15 To 2018-19 Shri Mohanraj Deputy Commissioner Of 76, State Bank Road, Vs. Income Tax, Coimbatore-641 018. Central Circle-3 Pan: Ahopm-2335-H Coimbatore. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S.Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Ms.T.M.Suganthamala, Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.03.2025 आदेश /O R D E R Per Bench: These Five Appeals At The Instance Of The Assessee Are Directed Against Five Separate Orders Of Cit(A), Chennai-20, All Dated 16.02.2024, Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2014-15 To 2018-19. 2. The Common Issue Is Raised In These Appeals, Hence, They Were Heard Together & Are Being Disposed Off By This Consolidated Order. Identical Grounds Are Raised Except For Variation In Figures.

reassessment and its conditions are completely different and distinct for the conditions prescribed by the law laid ITA Nos.548 to 552//CHNY/2024 down by the Hon'ble Supreme Court in the case of in the case of PCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra). Therefore, in light of the undisputed facts that for the assessment years

PALLADAM KRISHNASAMY GANESHWAR,TIRUPUR vs. DCIT, CC-3, COIMBATORE

The appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.1222/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2014-15) & 2. आयकरअपील सं./ Ita No.1223/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2015-16) & 3. आयकरअपील सं./ Ita No.1224/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) & 4. आयकरअपील सं./ Ita No.1225/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2017-18) Shri Palladam Krishnasamy Ganeshwar Dcit बनाम/ 21,Shri Ganesa Textiles, Pollachi Road, Central Circle-3 Vs. Palladam, Tirupur-641 664. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Adfpg-6476-N (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओर से/ Appellant By : Shri S. Sridhar (Advocate)-Ld.Ar " थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 10-09-2024 घोषणा की तारीख /Date Of Pronouncement : 19-11-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

demonetization as part of Rs.36 Crores that was totally repaid to Shri PK Ganeshwar. As per document seized during search on that group, outstanding quantum of loan lent by the assessee and his concerns was Rs.71.88 Crores. Out of the same, the undisclosed portion was Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which was the disclosed portion

PALLADAM KRISHNASAMY GANESHWAR,TIRUPUR vs. DCIT, CC-3, COIMBATORE

The appeals stand allowed in terms of our above order

demonetization as part of Rs.36 Crores that was totally repaid to\nShri PK Ganeshwar. As per document seized during search on that\ngroup, outstanding quantum of loan lent by the assessee and his\nconcerns was Rs.71.88 Crores. Out of the same, the undisclosed portion\nwas Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which\nwas the disclosed portion

PALLADAM KRISHNASAMY GANESHWAR,TIRUPUR vs. DCIT, CC-3, COIMBATORE

The appeals stand allowed in terms of our above order

demonetization as part of Rs.36 Crores that was totally repaid to\nShri PK Ganeshwar. As per document seized during search on that\ngroup, outstanding quantum of loan lent by the assessee and his\nconcerns was Rs.71.88 Crores. Out of the same, the undisclosed portion\nwas Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which\nwas the disclosed portion

MOHANRAJ,COIMBATORE vs. DCIT, CENTRAL CIRCLE 3, COIMBATORE

In the result, all the five appeals filed by the assessee are\nallowed

reassessment and its conditions are completely\ndifferent and distinct for the conditions prescribed by the law laid\ndown by the Hon'ble Supreme Court in the case of in the case of\nPCIT, Central-3 Vs. Abhisar Buildwell Private Limited (supra).\nTherefore, in light of the undisputed facts that for the assessment\nyears 2014-15 to 2017-18 assessments remain

PALLADAM KRISHNASAMY GANESHWAR,TIRUPUR vs. DCIT, CC-3, COIMBATORE

The appeals stand allowed in terms of our above order

demonetization as part of Rs.36 Crores that was totally repaid to\nShri PK Ganeshwar. As per document seized during search on that\ngroup, outstanding quantum of loan lent by the assessee and his\nconcerns was Rs.71.88 Crores. Out of the same, the undisclosed portion\nwas Rs.42.34 Crores whereas the balance was Rs.29.54 Crores which\nwas the disclosed portion

SG WIND FARM PVT. LTD.,,TIRUPUR vs. DCIT, CC-3,, COIMBATORE

The appeals stand allowed in terms of our above order

reassessment shall be made in case of persons\ncovered u/s 132. There was no discretion given to AO not to issue notice\nu/s 153A once the provisions of Sec.153A were attracted.\n4.5 On the argument of invocation of Sec. 153C, the Ld. CIT(A) held\nthat the impugned additions were based on incriminating material found\nduring search in other case

KJS JEWELLERS PRIVATE LIMITED,SALEM vs. ACIT, CENTRAL CRICLE, SALEM, SALEM

In the result, all the appeals of the assessee for AY 2017-18 to AY

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3334, 3335, 3336, 3337 & 3338/Chny/2025 िनधा$रण वष$ /Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21 & 2021-22

demonetization period. A search u/s. 132 of the Act was initiated on 10.11.2020 in the case of M/s.Mohanlal Jewells Pvt. Ltd. Certain incriminating materials were found and seized during the course of search and a statement of Shri Rajendra Kotari, Accountant was recorded u/s. 132(4) of the Act. On further investigation, it is noticed that in the accounting software

KJS JEWELLERS PRIVATE LIMITED,SALEM vs. ACIT CENTRAL CRICLE SALEM, SALEM

In the result, all the appeals of the assessee for AY 2017-18 to AY

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.3334, 3335, 3336, 3337 & 3338/Chny/2025 िनधा$रण वष$ /Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21 & 2021-22

demonetization period. A search u/s. 132 of the Act was initiated on 10.11.2020 in the case of M/s.Mohanlal Jewells Pvt. Ltd. Certain incriminating materials were found and seized during the course of search and a statement of Shri Rajendra Kotari, Accountant was recorded u/s. 132(4) of the Act. On further investigation, it is noticed that in the accounting software