VAIDYANATHAN KALAIVANI,CHENNAI vs. PCIT, CHENNAI

Appeal of the assessee stands dismissed

Section 56(2) (xi) of the Income Tax Act, 1961 (in short 'the Act") ?\n4. The Id. Ld. Assessing Officer framed reassessment

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 ()

56. The interest income of Rs.58.80 Lacs pertaining to M/s SG Wind farms Pvt. Ltd. was added on protective basis. 3.13 The Ld. AO also made addition of alleged undisclosed investment for Rs.600 Lacs. The same is also based on material seized during search on Shri O. Arumugasamy group. As per the seized material, the assessee advanced cash loan

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 ()

Section 80- 1A of the Act scrupulously, the denial of such claim in the computation sheet annexed to the search assessment order Is wholly unjustified and not sustainable in law. 24. The CIT(Appeals) - 20, Chennai failed to appreciate that the assessment order under consideration was passed out of lime, Invalid, passed without jurisdiction and not sustainable both on facts

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 ()

Section 80- 1A of the Act scrupulously, the denial of such claim in the computation sheet annexed to the search assessment order Is wholly unjustified and not sustainable in law. 24. The CIT(Appeals) - 20, Chennai failed to appreciate that the assessment order under consideration was passed out of lime, Invalid, passed without jurisdiction and not sustainable both on facts

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 ()

Section 80- 1A of the Act scrupulously, the denial of such claim in the computation sheet annexed to the search assessment order Is wholly unjustified and not sustainable in law. 24. The CIT(Appeals) - 20, Chennai failed to appreciate that the assessment order under consideration was passed out of lime, Invalid, passed without jurisdiction and not sustainable both on facts

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.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

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.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

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.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

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.

Section 56 of the Act in the computation of taxable total income without assigning proper reasons and justification. 9. The CIT(Appeals) - 20, Chennai failed to appreciate that the additions made merely based on the 'dairy statement seized during search in the premises of Mr. O. Arumugasamy and others was wholly unjustified and ought to have appreciated that the subsequent

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

The appeals stand allowed in terms of our above order

56. The interest income of Rs.58.80 Lacs pertaining to\nM/s SG Wind farms Pvt. Ltd. was added on protective basis.\n9\n3.13 The Ld. AO also made addition of alleged undisclosed investment\nfor Rs.600 Lacs. The same is also based on material seized during\nsearch on Shri O. Arumugasamy group. As per the seized material, the\nassessee advanced cash loan

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

The appeals stand allowed in terms of our above order

reassess or make additions. The Tribunal relied on various High Court decisions and the Supreme Court ruling in Pr. CIT vs. Abhisar Buildwell (P.) Ltd. to support this view.", "result": "Allowed", "sections": [ "153A", "153C", "143(3)", "69", "56

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

The appeals stand allowed in terms of our above order

56. The interest income of Rs.58.80 Lacs pertaining to\nM/s SG Wind farms Pvt. Ltd. was added on protective basis.\n9\n3.13 The Ld. AO also made addition of alleged undisclosed investment\nfor Rs.600 Lacs. The same is also based on material seized during\nsearch on Shri O. Arumugasamy group. As per the seized material, the\nassessee advanced cash loan

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

The appeals stand allowed in terms of our above order

Section 80-\n1A of the Act scrupulously, the denial of such claim in the computation sheet annexed to\nthe search assessment order Is wholly unjustified and not sustainable in law.\n24. The CIT(Appeals) - 20, Chennai failed to appreciate that the assessment order\nunder consideration was passed out of lime, Invalid, passed without jurisdiction and not\nsustainable both on facts

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

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

Section 153A of the Act\nbased on the incriminating materials seized during the search in\nthe premises of Mr. O. Arumugasamy and others in contra\ndistinction to the search in the premises of the appellant herein,\nwherein no incriminating materials were seized for the purpose of\nmaking the disputed addition(s) in the search assessment\norder(s), the consequential search

NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

reassessment of the return of income of the appellant, within the time frame stipulated under the Act. In this case, the limitation period of six years for reopening the assessment for the year 2011~12 under section 147 of the Act, came to an end on 31.03.2018. In such circumstances, there is no requirement for this court to go into

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

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

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

56(2)(vii) alleging receipt of cash without consideration. He thus urged us that such whimsical action taken by the AO u/s 153C of the Act ought to be struck down. 22. We have heard both the parties and perused the relevant provisions of the Act. Before we advert to the legal issue raised by the assessee, it would first

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

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

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

56(2)(vii) alleging receipt of cash without consideration. He thus urged us that such whimsical action taken by the AO u/s 153C of the Act ought to be struck down. 22. We have heard both the parties and perused the relevant provisions of the Act. Before we advert to the legal issue raised by the assessee, it would first

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

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

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

56(2)(vii) alleging receipt of cash without consideration. He thus urged us that such whimsical action taken by the AO u/s 153C of the Act ought to be struck down. 22. We have heard both the parties and perused the relevant provisions of the Act. Before we advert to the legal issue raised by the assessee, it would first