DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

20. In this factual background, if we examine reasons given by the AO to invoke provisions of section 68 of the Act, to treat entries in diary and notebook and deleted entries from computer CPU as unexplained cash credit, one has to first understand provisions of section 68 of the Act. The provisions of section 68 deals

DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

20. In this factual background, if we examine reasons given by the AO to invoke provisions of section 68 of the Act, to treat entries in diary and notebook and deleted entries from computer CPU as unexplained cash credit, one has to first understand provisions of section 68 of the Act. The provisions of section 68 deals

DICT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. GSNR RICE INDUSTRIES PVT. LTD.,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

20. In this factual background, if we examine reasons given by the AO to invoke provisions of section 68 of the Act, to treat entries in diary and notebook and deleted entries from computer CPU as unexplained cash credit, one has to first understand provisions of section 68 of the Act. The provisions of section 68 deals

DCIT, CORPORATE CIRCLE - 2 (1),, CHENNAI vs. SHRI KANAKKILIANALLUR NARAYANA REDDIYAR MANIVANNAN,, TIRUPUR

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

20. In this factual background, if we examine reasons given by the AO to invoke provisions of section 68 of the Act, to treat entries in diary and notebook and deleted entries from computer CPU as unexplained cash credit, one has to first understand provisions of section 68 of the Act. The provisions of section 68 deals

ITO, NCW - I (4),, CHENNAI vs. SHRI KANAKILLIYANALLUR NARAYANAN NEHRU,, CHENNAI

In the result, appeal filed by the Revenue for Asst

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2407, 2408, 2409, 2410 & 2411/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12, 2012-13, 2013-14, 2014-15 & 2015-16 The Dcit, M/S. Gsnr Rice Industries Corporate Circle – 2(1), V. Pvt. Ltd., Chennai. (Formerly Known As M/S. Snr Rice Industries Pvt. Ltd.,) No.21, C V Raman Raod, Alwarpet, Chennai – 600 018. Pan: Aamcs 5834P

20. In this factual background, if we examine reasons given by the AO to invoke provisions of section 68 of the Act, to treat entries in diary and notebook and deleted entries from computer CPU as unexplained cash credit, one has to first understand provisions of section 68 of the Act. The provisions of section 68 deals

M/S AADHI ENTERPRISES PRIVATE LIMITED,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(1), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.: 308/Chny/2023 िनधा"रण वष"/Assessment Year: 2016-17 Aadhi Enterprises Pvt. Ltd., The Acit, No.1-130, Perambur Barracks V. Central Circle-3(1), Road, Pattalam, Chennai. Chennai – 600 112. Pan: Aanca 0382P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri B. Ramakrishnan, Fca Shri S. Neelakantan, Fca Shri Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई क" तारीख/Date Of Hearing : 11.07.2023 घोषणा क" तारीख/Date Of Pronouncement : 23.08.2023

10. 12. Ld Counsel argued that 2nd proviso to amended section 68 of the Act (1st proviso to pre-amended section 68, which was inserted by the Finance Act, 2012) is noted to be applicable to persons who are residents, who are further required to substantiate the 'source of source' of funds. This additional burden cast upon

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. MS DAR PARADISE PVT. LTD., COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1106/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Dar Paradise Pvt. Ltd., Income Tax, V. 599, Raja Street, Corporate Circle -1, Coimbatore – 641 001. Coimbatore. [Pan: Aafcd-3066-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri. N. Arjun Raj, Ca सुनवाई क" तारीख/Date Of Hearing : 05.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 21.03.2024

section 68 of the Act. 18. Be that as it may. The fact remains that, the assessee has furnished name and address of the customers from whom it has received advances for sale of jewellery. The assessee need not obtain confirmation and submit to the Assessing Officer, because, the law does not mandate colleting PAN details of the persons

M/S. HYUNDAI MOTOR INDIA LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

In the result, the appeal of the assessee is allowed

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

10 to Section 43(1) of the Act. 21. In this connection, the ld.AR relied upon the ruling of the Hon’ble Supreme Court in the case of V-Con Integrated Solutions Pvt. Ltd. (SLP(Diary) No. 13205 of 2025), wherein it was held as under: “The assessee does not have control over the pen of the Assessing Officer

BAREFOOT RESORTS & LEISURES INDIA P LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.2002 To 2006/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2012-13) M/S. Barefoot Resorts & Leisures India Vs The Deputy Commissioner Of Pvt.Ltd. Income Tax, 77/43, 2Nd Floor, Chamiers Road, Corporate Circle-1(2), Chennai-600 028. Chennai-34. Pan: Aaffb 5380B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/ Appellant By : Mr. S.Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Mr. P.Sajit Kumar, Jcit सुनवाईक"तार"ख/Date Of Hearing : 04.08.2022 घोषणाक"तार"ख /Date Of Pronouncement : 12.10.2022 आदेश / O R D E R Per G. Manjunatha, Am: This Bunch Of Five Appeals Filed By The Assessee Are Directed Against Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Chennai Dated 01.06.2018 & Pertain To Assessment Years 2008-09 To 2012- 13. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Consolidated Order.

10. The CIT (Appeals) failed to appreciate that the misconstruction of the provisions of section 68 of the Act would vitiate the decision to tax share capital contribution in the hands of the appellant especially in para 55 of the impugned order on various grounds. 11. The CIT (Appeals) failed to appreciate that having taken on record the objections

BAREFOOT RESORTS & LEISURES INDIA P LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.2002 To 2006/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2012-13) M/S. Barefoot Resorts & Leisures India Vs The Deputy Commissioner Of Pvt.Ltd. Income Tax, 77/43, 2Nd Floor, Chamiers Road, Corporate Circle-1(2), Chennai-600 028. Chennai-34. Pan: Aaffb 5380B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/ Appellant By : Mr. S.Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Mr. P.Sajit Kumar, Jcit सुनवाईक"तार"ख/Date Of Hearing : 04.08.2022 घोषणाक"तार"ख /Date Of Pronouncement : 12.10.2022 आदेश / O R D E R Per G. Manjunatha, Am: This Bunch Of Five Appeals Filed By The Assessee Are Directed Against Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Chennai Dated 01.06.2018 & Pertain To Assessment Years 2008-09 To 2012- 13. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Consolidated Order.

10. The CIT (Appeals) failed to appreciate that the misconstruction of the provisions of section 68 of the Act would vitiate the decision to tax share capital contribution in the hands of the appellant especially in para 55 of the impugned order on various grounds. 11. The CIT (Appeals) failed to appreciate that having taken on record the objections

BAREFOOT RESORTS & LEISURES INDIA P LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.2002 To 2006/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2012-13) M/S. Barefoot Resorts & Leisures India Vs The Deputy Commissioner Of Pvt.Ltd. Income Tax, 77/43, 2Nd Floor, Chamiers Road, Corporate Circle-1(2), Chennai-600 028. Chennai-34. Pan: Aaffb 5380B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/ Appellant By : Mr. S.Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Mr. P.Sajit Kumar, Jcit सुनवाईक"तार"ख/Date Of Hearing : 04.08.2022 घोषणाक"तार"ख /Date Of Pronouncement : 12.10.2022 आदेश / O R D E R Per G. Manjunatha, Am: This Bunch Of Five Appeals Filed By The Assessee Are Directed Against Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Chennai Dated 01.06.2018 & Pertain To Assessment Years 2008-09 To 2012- 13. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Consolidated Order.

10. The CIT (Appeals) failed to appreciate that the misconstruction of the provisions of section 68 of the Act would vitiate the decision to tax share capital contribution in the hands of the appellant especially in para 55 of the impugned order on various grounds. 11. The CIT (Appeals) failed to appreciate that having taken on record the objections

BAREFOOT RESORTS & LEISURES INDIA P LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.2002 To 2006/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2012-13) M/S. Barefoot Resorts & Leisures India Vs The Deputy Commissioner Of Pvt.Ltd. Income Tax, 77/43, 2Nd Floor, Chamiers Road, Corporate Circle-1(2), Chennai-600 028. Chennai-34. Pan: Aaffb 5380B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/ Appellant By : Mr. S.Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Mr. P.Sajit Kumar, Jcit सुनवाईक"तार"ख/Date Of Hearing : 04.08.2022 घोषणाक"तार"ख /Date Of Pronouncement : 12.10.2022 आदेश / O R D E R Per G. Manjunatha, Am: This Bunch Of Five Appeals Filed By The Assessee Are Directed Against Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Chennai Dated 01.06.2018 & Pertain To Assessment Years 2008-09 To 2012- 13. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Consolidated Order.

10. The CIT (Appeals) failed to appreciate that the misconstruction of the provisions of section 68 of the Act would vitiate the decision to tax share capital contribution in the hands of the appellant especially in para 55 of the impugned order on various grounds. 11. The CIT (Appeals) failed to appreciate that having taken on record the objections

BAREFOOT RESORTS & LEISURES INDIA P LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.Nos.2002 To 2006/Chny/2018 ("नधा"रणवष" / Assessment Years: 2008-09 To 2012-13) M/S. Barefoot Resorts & Leisures India Vs The Deputy Commissioner Of Pvt.Ltd. Income Tax, 77/43, 2Nd Floor, Chamiers Road, Corporate Circle-1(2), Chennai-600 028. Chennai-34. Pan: Aaffb 5380B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/ Appellant By : Mr. S.Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Mr. P.Sajit Kumar, Jcit सुनवाईक"तार"ख/Date Of Hearing : 04.08.2022 घोषणाक"तार"ख /Date Of Pronouncement : 12.10.2022 आदेश / O R D E R Per G. Manjunatha, Am: This Bunch Of Five Appeals Filed By The Assessee Are Directed Against Common Order Passed By The Learned Commissioner Of Income Tax (Appeals)-1, Chennai Dated 01.06.2018 & Pertain To Assessment Years 2008-09 To 2012- 13. Since, Facts Are Identical & Issues Are Common, For The Sake Of Convenience, These Appeals Were Heard Together & Are Being Disposed Off, By This Consolidated Order.

10. The CIT (Appeals) failed to appreciate that the misconstruction of the provisions of section 68 of the Act would vitiate the decision to tax share capital contribution in the hands of the appellant especially in para 55 of the impugned order on various grounds. 11. The CIT (Appeals) failed to appreciate that having taken on record the objections

SHRI. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,370 Payable-Sundries Sub-total 19,46,04,820 TOTAL 80,06,28,317 2021- Coolies and Various 52,55,10,803 Cash 22 wages dates Various 14,78,900 Coolie and wages dates advance account TOTAL 52,69,89,703 11. Before us, the Ld. CIT, DR reiterated the above observations made by the AO regarding the above

SHRI. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CRICLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,370 Payable-Sundries Sub-total 19,46,04,820 TOTAL 80,06,28,317 2021- Coolies and Various 52,55,10,803 Cash 22 wages dates Various 14,78,900 Coolie and wages dates advance account TOTAL 52,69,89,703 11. Before us, the Ld. CIT, DR reiterated the above observations made by the AO regarding the above

SHRI. IRULANDI THEVAR VETRIVEL ,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,370 Payable-Sundries Sub-total 19,46,04,820 TOTAL 80,06,28,317 2021- Coolies and Various 52,55,10,803 Cash 22 wages dates Various 14,78,900 Coolie and wages dates advance account TOTAL 52,69,89,703 11. Before us, the Ld. CIT, DR reiterated the above observations made by the AO regarding the above

SHIR. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,370 Payable-Sundries Sub-total 19,46,04,820 TOTAL 80,06,28,317 2021- Coolies and Various 52,55,10,803 Cash 22 wages dates Various 14,78,900 Coolie and wages dates advance account TOTAL 52,69,89,703 11. Before us, the Ld. CIT, DR reiterated the above observations made by the AO regarding the above

ACIT, CENTRAL CIRCLE-2, TRICHY vs. M/S MANGAL & MANGAL, TRICHY

In the result, appeal filed by the revenue is dismissed

Bench: Shri Manjunatha. G, Hon’Ble & Shri Manomohan Das, Hon’Bleआयकर अपील सं./Ita No.: 772/Chny/2022 िनधा"रण वष" / Assessment Years: 2017-18 The Assistant Commissioner Of M/S. Mangal & Mangal, Income Tax, V. 25, N.S.B. Road, Teppakulam, Central Circle -2, Trichy – 620 002. No. 44, Williams Road, [Pan: Aaifm-3378-B] Cantonment, Trichy – 620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Dr. R. Mohan Reddy, Cit ""यथ" क" ओर से/Respondent By : Shri. S. Sridhar, Advocate सुनवाई की तारीख/Date Of Hearing : 08.06.2023 घोषणा की तारीख/Date Of Pronouncement : 06.09.2023

20 crores for financial year 2014-15 and the same has been used for :-5-: ITA. No: 772/Chny/2022 purchase of stock in trade. It was further observed that, the assessee had also admitted Rs. 40 crores income from discounts and incentives for the assessment year 2016-17 and the same has been resulted in increase in stock in trade