ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

172 (All), wherein, the Income-tax Department had sent a requisition on 27-3-2002, under section 132A requisitioning the books of account and other documents seized by the Central Excise Department. The record of the proceeding dated 18-4-2002, showed that the requisition was not fully executed as all the books of account and other documents

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 143(3) of Income lax Act, 1961 on 28.02.2014 by assessing income at Rs.242,82,49,494/- & STCG at Rs. 2,25,843/-. Deputy Commissioner of Income Tax, Central Circle XXI, Kolkata has informed vide his letter dated 18.03.2014 that during the assessment proceedings in the case of M/s.Sakshi Trade Link

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 143(3) of Income lax Act, 1961 on 28.02.2014 by assessing income at Rs.242,82,49,494/- & STCG at Rs. 2,25,843/-. Deputy Commissioner of Income Tax, Central Circle XXI, Kolkata has informed vide his letter dated 18.03.2014 that during the assessment proceedings in the case of M/s.Sakshi Trade Link

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 143(3) of Income lax Act, 1961 on 28.02.2014 by assessing income at Rs.242,82,49,494/- & STCG at Rs. 2,25,843/-. Deputy Commissioner of Income Tax, Central Circle XXI, Kolkata has informed vide his letter dated 18.03.2014 that during the assessment proceedings in the case of M/s.Sakshi Trade Link

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

u/s 143(3) of Income lax Act, 1961 on 28.02.2014 by assessing income at Rs.242,82,49,494/- & STCG at Rs. 2,25,843/-. Deputy Commissioner of Income Tax, Central Circle XXI, Kolkata has informed vide his letter dated 18.03.2014 that during the assessment proceedings in the case of M/s.Sakshi Trade Link

PLANTIUM HOLDING P LTD,CHENNAI vs. DCIT, CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal stands partly allowed

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.3436/Chny/2018 (िनधा"रण वष" / Assessment Year: 2008-09) M/S Platinum Holdings Private Ltd. Dcit बनाम/ No.2/1, Abu Garden, Omr Road, Central Circle-3(4) Vs. Navalur, Chennai-600 103. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aadcp-8781-D (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/Appellant By : Shri P. Murali Mohan Rao (Ca)-Ld. Ar !"थ"कीओरसे/ Respondent By : Smt. Komali Krishna (Cit)- Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 27-02-2024 घोषणाकीतारीख /Date Of Pronouncement : 17-05-2024

section 153A in respect of unabated assessments. 4. The material relied upon by the Commissioner (Appeals) to confirm the additions was not found during the course of the search of the Appellant. The said material was already available with the Assessing Officer which had been collected in the course of the search of another entity. The Commissioner (Appeals), therefore, erred

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

u/s. 147 of the I.T. Act, 1961.” 2.4 However, reassessment under section 143(3) r.w.s. 147 of the Act has been completed by making various other disallowances. By relying on the 4 I.T.A. No.1139/Chny/08, 1135/Chny/10 & C.O. No. 69/Chny/17, 1136/Chny/10 & 632-634/Chny/17 decision in the case of CIT v. Shri Ram Singh 306 ITR 343 (Raj), the assessee contended before

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

u/s. 147 of the I.T. Act, 1961.” 2.4 However, reassessment under section 143(3) r.w.s. 147 of the Act has been completed by making various other disallowances. By relying on the 4 I.T.A. No.1139/Chny/08, 1135/Chny/10 & C.O. No. 69/Chny/17, 1136/Chny/10 & 632-634/Chny/17 decision in the case of CIT v. Shri Ram Singh 306 ITR 343 (Raj), the assessee contended before

ACIT, CHENNAI vs. M/S. MASCON GLOBAL LTD., CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

u/s. 147 of the I.T. Act, 1961.” 2.4 However, reassessment under section 143(3) r.w.s. 147 of the Act has been completed by making various other disallowances. By relying on the 4 I.T.A. No.1139/Chny/08, 1135/Chny/10 & C.O. No. 69/Chny/17, 1136/Chny/10 & 632-634/Chny/17 decision in the case of CIT v. Shri Ram Singh 306 ITR 343 (Raj), the assessee contended before

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

u/s. 147 of the I.T. Act, 1961.” 2.4 However, reassessment under section 143(3) r.w.s. 147 of the Act has been completed by making various other disallowances. By relying on the 4 I.T.A. No.1139/Chny/08, 1135/Chny/10 & C.O. No. 69/Chny/17, 1136/Chny/10 & 632-634/Chny/17 decision in the case of CIT v. Shri Ram Singh 306 ITR 343 (Raj), the assessee contended before

ARUNRAJ,ERODE vs. ACIT, CENTRAL CIRC 3, CBE, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

172/-. Aggrieved, the assessee filed further appeal before the CIT(A). :- 4 -: 3. The CIT(A) confirmed the addition made by the A.O on the ground that the director of M/s. Anitha Texcot India Pvt. Ltd. has accepted having entered into bogus purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

172/-. Aggrieved, the assessee filed further appeal before the CIT(A). :- 4 -: 3. The CIT(A) confirmed the addition made by the A.O on the ground that the director of M/s. Anitha Texcot India Pvt. Ltd. has accepted having entered into bogus purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before

EVERYEADY SPINNING MILLS PRIVATE LIMITED,TRIUPUR vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

172/-. Aggrieved, the assessee filed further appeal before the CIT(A). :- 4 -: 3. The CIT(A) confirmed the addition made by the A.O on the ground that the director of M/s. Anitha Texcot India Pvt. Ltd. has accepted having entered into bogus purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before

SEETHADEVI,ERODE vs. ACIT, CENTRAL CIRCLE-3, , COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

172/-. Aggrieved, the assessee filed further appeal before the CIT(A). :- 4 -: 3. The CIT(A) confirmed the addition made by the A.O on the ground that the director of M/s. Anitha Texcot India Pvt. Ltd. has accepted having entered into bogus purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before

SUNDARASAMY REP. BY KOKILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

172/-. Aggrieved, the assessee filed further appeal before the CIT(A). :- 4 -: 3. The CIT(A) confirmed the addition made by the A.O on the ground that the director of M/s. Anitha Texcot India Pvt. Ltd. has accepted having entered into bogus purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before

SUNDARASAMY KOHILA,TIRUPPUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita Nos.2206, 2204 & 2207/Chny/2025 िनधा#रण वष# /Assessment Years: 2018-19, 2019-20 & 2021-22

172/-. Aggrieved, the assessee filed further appeal before the CIT(A). :- 4 -: 3. The CIT(A) confirmed the addition made by the A.O on the ground that the director of M/s. Anitha Texcot India Pvt. Ltd. has accepted having entered into bogus purchase transactions which substantiates that the assessee has raised bogus sales invoices. The assessee is in appeal before

S.A.BHIMARAJA,CHENNAI vs. ITO, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 3414/Chny/2016 िनधा"रण वष" / Assessment Year: 2008-09

172 6) Oriental Bank of Commerce v AdCIT [2014] 90 CCH 27 Del High Court 7) PVP Ventures Limited v ACIT [2015] 94 CCH 0147 (Chennai HC) 10. The ld.DR on the other hand strongly opposing additional grounds filed by the assessee challenging validity of reopening of assessment submitted that there is no merit in arguments advanced by the ld.AR

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

172 taxmann.com 94 (ITAT, Jaipur)\nBhowmick Raj Singh v. JCIT [2025] 171 taxmann.com 575 (ITAT, Raipur)\n11. Another important aspect pointed out in the context of the present\ncase by the Ld. AR was that, the assessment order dated 30-12-2022\nwhich contained express satisfaction for initiation of penalty u/s 271D of\nthe Act was passed