PRINCE GOLD & DIAMONDS INDIA P LTD,CHENNAI vs. DCIT, CC-1(4), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.427 & 428/Chny/2021 िनधा"रण वष"/Assessment Years: 2011-12 & 2012-13 M/S. Prince Gold & Diamonds India Vs. The Deputy Commissioner Of P. Ltd., 3, Nana Street, T. Nagar, Income Tax, Chennai 600 017. Central Circle 1(4), Chennai. [Pan: Aaecp1891R] (अपीलाथ" /Appellant) (""थ"/Respondent) Assessee By : Shri D. Palanivel, Advocate Department By : Ms. L. Jancy Elizabeth Rani, Jcit सुनवाई की तारीख/ Date Of Hearing 28.06.2022 : घोषणा की तारीख /Date Of Pronouncement : 03.08.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 31.08.2021 Relevant To The Assessment Years 2011-12 & 2012-13. Besides Challenging Reopening Of Assessment Under Section 147 Of The Income Tax Act, 1961 [“Act”], The Assessee Has Also Disputed The Confirmation Of Disallowance Of Purchase On Merits In Both The Assessment Years Under Consideration.

reassessment order passed under section 143(3) r.w.s. 153B(1)(b) r.w.s. 147 of the Act for the assessment year 2011-12 as well as section 143(3) r.w.s. 147 of the Act for the assessment year 2012-13 both dated 28.12.2018. 4. On the other hand, the ld. DR strongly supported the orders of authorities below. 5. We have

PRINCE GOLD & DIAMONDS INDIA P LTD,CHENNAI vs. DCIT,CC-1(4), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.427 & 428/Chny/2021 िनधा"रण वष"/Assessment Years: 2011-12 & 2012-13 M/S. Prince Gold & Diamonds India Vs. The Deputy Commissioner Of P. Ltd., 3, Nana Street, T. Nagar, Income Tax, Chennai 600 017. Central Circle 1(4), Chennai. [Pan: Aaecp1891R] (अपीलाथ" /Appellant) (""थ"/Respondent) Assessee By : Shri D. Palanivel, Advocate Department By : Ms. L. Jancy Elizabeth Rani, Jcit सुनवाई की तारीख/ Date Of Hearing 28.06.2022 : घोषणा की तारीख /Date Of Pronouncement : 03.08.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Both Dated 31.08.2021 Relevant To The Assessment Years 2011-12 & 2012-13. Besides Challenging Reopening Of Assessment Under Section 147 Of The Income Tax Act, 1961 [“Act”], The Assessee Has Also Disputed The Confirmation Of Disallowance Of Purchase On Merits In Both The Assessment Years Under Consideration.

reassessment order passed under section 143(3) r.w.s. 153B(1)(b) r.w.s. 147 of the Act for the assessment year 2011-12 as well as section 143(3) r.w.s. 147 of the Act for the assessment year 2012-13 both dated 28.12.2018. 4. On the other hand, the ld. DR strongly supported the orders of authorities below. 5. We have

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), CHENNAI, CHENNAI vs. BONDALAPATI SHIVAJI RAO, CHENNAI

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,-- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

BONDALAPATI SHIVAJI RAO,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), CHENNAI, CHENNAI

In the result, appeal filed by the assessee stands allowed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 निर्धारण वर्ष/Assessment Year: 2019-20 Shri Bondalapati Shivaji Rao, 121, Shankar Nagar, M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलार्थी/Appellant) The Dcit, Central Circle-1(2), Chennai. (अपीलार्थी/Appellant) V. The Dcit, Central Circle-1(2), Chennai. (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 निर्धारण वर्ष/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, 121, Shankar Nagar, M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (प्रत्यर्थी/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Shri S. Dwarakesh, Ca Shri Shrenik Chordia, Ca Department By : Shri V. Nandakumar, Cit सुनवाईकीतारीख/Date Of Hearing : 08.08.2024 घोषणाकीतारीख /Date Of Pronouncement : 18.09.2024 आदेश / Order Per Aby T. Varkey, Jm: These Appeals Preferred By The Assessee & The Revenue Are Against The Order Of The Learned Commissioner Of Income Tax (Appeals)- 18, Chennai (Hereinafter In Short `The Ld.Cit(A)') Dated 26.07.2023 Passed For Assessment Year (Hereinafter In Short `Ay') 2019-20.

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that,-- (a) any money, bullion, jewellery or other valuable article or thing, seized or requisitioned, belongs to; or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. SUBRAMANIAM KATHIRESAN, CHENNAI

In the result, appeal filed by the Revenue for AY 2014-15 is dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within

ARUNACHALAM SRINIVASAN,PERAMBALUR vs. ACIT, CENTRAL CIRCLE-1 , TRICHY

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY vs. A. SRINIVASAN, PERAMBALUR

In the result, appeal filed by the Revenue for AY 2014-15 in ITA

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita No.1527/Chny/2023 िनधा"रण वष"/Assessment Year: 2014-15 & Cross Objection No.13/Chny/2024 (In Ita No.1527/Chny/2023) िनधा"रण वष"/Assessment Year: 2014-15

147, section 148, section 149, section 151 and section 153, in the case of a person where a search is initiated under section 132 or books of account, other documents or any assets are requisitioned under section 132A after the 31st day of May, 2003, the Assessing Officer shall- (a) issue notice to such person requiring him to furnish within

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

ACIT CENTRAL CIRCLE 2 (1) INVESTIGATION WING, CHENNAI vs. M/S G TECH STONE LTD, CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

G-TECH STONE LTD.,CHENNAI vs. ACIT CORPORATE CIRCLE 2(1), CHENNAI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

147 therefore, was made in the context of the Assessing Officer being authorized and permitted to assess or re-assess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. Before us, such is not the position, and even if this judgment of the High Court had been brought

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- V. The Dcit, Industries Pvt Ltd Central Circle-2(2), Chennai. Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that - (a) any money, bullion, Jewellery or other valuable article or thing seized or requisitioned, "belongs to, or (b) any books of account or documents, seized or requisitioned, pertains or pertain to, or any information contained therein, relates to, a person other than

ACIT, COIMBATORE vs. SHRI A.SENTHILKUMAR, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153B. The question now is - what is the scope of assessment or reassessment of total income u/s 153A (1) (b) and the first proviso? We are of the view that for answering this question, guidance will have to be sought from section 132(1). If any books of account or other documents relevant to the assessment had not been produced

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

153B. The question now is - what is the scope of assessment or reassessment of total income u/s 153A (1) (b) and the first proviso? We are of the view that for answering this question, guidance will have to be sought from section 132(1). If any books of account or other documents relevant to the assessment had not been produced