SIVAKUMARAN PUGAZHENDHI,CHENNAI vs. PCIT,, CHENNAI-4

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.27/Chny/2022 िनधा"रण वष" /Assessment Year: 2014-15 Sivakumaran Pugazhendhi, The Principal Commissioner 70 Raja Agraharam Street, Vs. Of Income Tax, Poonamalle, Chennai-4. Chennai – 600 056. [Pan: Aiapp-7309-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. T.V. Muthu Abirami, Advocate ""यथ" क" ओर से /Respondent By : Shri M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 05.09.2022 : 21.09.2022 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R

money or not obtained from a company either from a director or by a person who has substantial interest in the company and any sum paid by any such company in respect of any obligation which, but for such payment would, have been payable by the director or other person aforesaid, is defined to be income to be taxed

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the assessment year assessment year relevant to the previous year in which search is relevant to the previous year in which search is conducted. Applying this yardstick, the conducted. Applying this

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

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the reassess the total income of six years immediately preceding the assessment year assessment year relevant to the previous year in which search is relevant to the previous year in which search is conducted. Applying this yardstick, the conducted. Applying this

M/S. ARYAN SHARE AND STOCK BROCKERS LIMITED,CHENNAI vs. ITO, CORP WARD-1,, CHENNAI

In the result, Appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No. 2115/Chny/2025 "नधा"रण वष"/Assessment Year: 2014-15 M/S Aryan Share & Stock Brokers V. Ito Corp Ward-1, Limited., Itd, M G Road, No. 07, 07Th Cross Street, Nungambakkam, 2Nd Floor, Shreeji Metropolis, Chennai-600034 Aminjikarai, Chennai-600030 Tamil Nadu Tamil Nadu [Pan:Aadca 1233 H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Assessee By : Mr. Y Sridhar, Ca ""यथ" क" ओर से /Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 10.11.2025 घोषणा क" तार"ख /Date Of Pronouncement : 13.01.2026

unexplained money by any stretch of imagination and hence submitted that no addition u/s 69A can be made in the instant case. (f) The transaction has been recorded in the books of account of the appellant. (g) Further, he stated that when books of account are duly audited and the said loss is part of the books of account, question

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

unexplained money u/s. 69A. 7. In response, the legal heir again sought dropping of the proceedings and asserted that the deposits pertained to the partnership firm Nather Hussain. Copies of the cash book and bank statements of Sathyamurthy Indane Gas Services were furnished. However, the Assessing Officer held that the documents produced did not satisfactorily establish a nexus between

ASSISTANT COMMISSIONER OF INCOME TAX, COIMBATORE vs. KAMATCHIPURAM VELLINGIRI JAYARAMAN, COIMBATORE

Appeal of the revenue is dismissed, where as the Cross objection of the assessee is allowed

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

money, by taking recourse to provisions of Section 147 read with Section 148 of the Act, unless it assesses to tax that income with reference to which the Assessing Officer had formed reason to believe (within the meaning of Section 147), that it had escaped assessment. C.O.No.27/Chny/2025 21. To my mind, a careful reading of Section 147

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

unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy CIT, (2012) 340 ITR 53 (Del), there being omission and failure on the part of the assessee to disclose fully and truly material facts Thus reassessment proceedings were held to be valid

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

unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy CIT, (2012) 340 ITR 53 (Del), there being omission and failure on the part of the assessee to disclose fully and truly material facts Thus reassessment proceedings were held to be valid

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

unexplained trade credits, they were invalid. On appeal, it has been held that the reassessments were to be valid. In Honda Siel Power Products Ltd. v. Deputy CIT, (2012) 340 ITR 53 (Del), there being omission and failure on the part of the assessee to disclose fully and truly material facts Thus reassessment proceedings were held to be valid

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita No. 1163, 1256, 1257 & 1259/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 | The Dcit, Central Circle-2(2), Chennai. V. M/S. Southern Agrifurane Industries Pvt. Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. (अपीलार्थी/Appellant) [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita No.1231, 1232, 1234 & 1236/Chny/2025 निर्धारणवर्ष/Assessment Years: 2013-14 To 2016-17 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] (अपीलार्थी/Appellant) V. The Dcit, Central Circle-2(2), Chennai. (प्रत्यर्थी/Respondent) Department By : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit Assessee By : Mr. N. Arjun Raj, Advocate सुनवाईकीतारीख/Date Of Hearing : 08.10.2025 घोषणाकीतारीख / Date Of Pronouncement : 21.11.2025

unexplained or undisclosed, which is valued Rs 50 Lakhs or more, that the AO can be said to be in possession of the jurisdictional fact to initiate proceedings u/s 153A for 7th-10th AY (AY 2011-12, in the instant case)." 6.3.24 The above finding of the Hon'ble Tribunal was ratified by the Hon'ble Gauhati High Court

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

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

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

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

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

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

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

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

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

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

SHRI GOPAL YADEV SELVA KUMAR,VELLORE vs. ITO, WARD-2, VELLORE

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

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri G. Manjunathaआयकर अपील सं./Ita No.111/Chny/2018 िनधा"रण वष" /Assessment Year: 2011-12 Mr.Gopal Yadav Selva Kumar, V. The Income Tax Officer, 65, Vellore Main Road, Ward-2, 1St Street, Arcot, Vellore-632 503. Vellore. [Pan: Btsps 5973 E] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.Salai Varun Isai Azhagan, Adv. ""यथ" क" ओर से /Respondent By : Mr.Ar.V.Sreenivasan, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 15.11.2021 घोषणा क" तारीख /Date Of Pronouncement : 12.01.2022

unexplained investment. 3. The assessee carried the matter in appeal before the Ld.CIT(A). Before the Ld.CIT(A), the assessee has challenged the reopening of assessment on multiple grounds including non-disposal of objections filed by the assessee in light of the decision of the Hon’ble Supreme Court in the case of M/s.GKN Driveshafts (India) Ltd. v. ITO reported

DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE - 1, MADURAI vs. SRI RETHINAM AGENCY, MADURAI

In the result the appeals raised by the Revenue are dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1213/Chny/2023, निर्धारण वर्ा /Assessment Years: 2016-17 आयकर अपील सं./Ita Nos.1214/Chny/2023, निर्धारण वर्ा /Assessment Years: 2017-18 The Deputy Commissioner Of Income Sri Rethinam Agency, Tax, No.36, Old Betal Shop Street, Non-Corporate Circle-1, Madurai-625001. Madurai [Pan: Abifs4717R]

147 and passed reassessment orders u/s 143(3). Thus the Ld.AO made additions to the returned income of Rs.3,21,58,183/- u/s. 69C for AY-2016-17 and of Rs.3,15,16,995/- u/s. 69C, Rs.20,66,59,763/- u/s 69A for AY-2017-18. Page - 2 - of 9 ITA No.1213 & 2014/Chny/2023 4.0 The first issue raised

DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 1, MADURAI vs. SRI RETHINAM AGENCY, MADURAI

In the result the appeals raised by the Revenue are dismissed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.1213/Chny/2023, निर्धारण वर्ा /Assessment Years: 2016-17 आयकर अपील सं./Ita Nos.1214/Chny/2023, निर्धारण वर्ा /Assessment Years: 2017-18 The Deputy Commissioner Of Income Sri Rethinam Agency, Tax, No.36, Old Betal Shop Street, Non-Corporate Circle-1, Madurai-625001. Madurai [Pan: Abifs4717R]

147 and passed reassessment orders u/s 143(3). Thus the Ld.AO made additions to the returned income of Rs.3,21,58,183/- u/s. 69C for AY-2016-17 and of Rs.3,15,16,995/- u/s. 69C, Rs.20,66,59,763/- u/s 69A for AY-2017-18. Page - 2 - of 9 ITA No.1213 & 2014/Chny/2023 4.0 The first issue raised