SUNDARAM SUBRAMANIAN REP. BY LEGAL HEIR S SUNDARAM,PUDUKKOTTAI vs. ITO, CIRCLE-2(1), TRICHY

In the result, both the appeals of the Assessee are partly allowed

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

section 68 operates independently, and rejection of books is required only where income is sought to be estimated, or the correctness of accounts as a whole is in dispute. The addition made by the AO, irrespective of its correctness, is not pivoted to the entries in the books of accounts and its accuracy. Moreover, the addition is not made

SUNDARAM SUBRAMANIAN,PUDUKKOTTAI vs. ITO, CIRCLE-2(1), TRICHY

In the result, both the appeals of the Assessee are partly allowed

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

section 68 operates independently, and rejection of books is required only where income is sought to be estimated, or the correctness of accounts as a whole is in dispute. The addition made by the AO, irrespective of its correctness, is not pivoted to the entries in the books of accounts and its accuracy. Moreover, the addition is not made

M/S. SRI BALAJI EDUCATIONAL AND CHARITABLE PUBLIC TRUST,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(4), CHENNAI

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

127/- and hospital collection of Rs. 1,49,86,176/-are already considered as sale receipts in the books of accounts and out of the said receipts, an amount of Rs. 1,43,13,000/- was received in SBNs and the same was deposited in the bank accounts. It is also noted that the remaining amount of Rs.1.13

ACIT, CHENNAI vs. SRI BALAJI EDUCATIONAL AMD TRUST CHARITABLE PUBLIC TRUST , CHENNA

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

127/- and hospital collection of Rs. 1,49,86,176/-are already considered as sale receipts in the books of accounts and out of the said receipts, an amount of Rs. 1,43,13,000/- was received in SBNs and the same was deposited in the bank accounts. It is also noted that the remaining amount of Rs.1.13

ACIT CENTRAL CIRCLE 3(1), CHENNAI vs. SHIV SAHAI & SONS (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

SAHAI & SONS (I) LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

sections": [ "143(3)", "133A", "139(1)", "143(2)", "142(1)", "68", "115BBE", "127", "120", "2(7A)" ], "issues": "1. Validity

DEPUTY COMMISSIONER OF INCOME TAX, MADURAI vs. SUBBIAH NADAR JEGATHEESAN, TIRUNELVELI

In the result, appeal filed by the Revenue stands dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:603/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income Subbiah Nadar Jegatheesan, Tax, Vs. 3, Ml Theri Road, Keeraikaranthattu, Central Circle -2, Mahadevankulam, Madurai. Tirunelveli – 627 657. [Pan:Abxpj-7672-F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. E. Pavuna Sundari, C.I.T. ""थ" की ओर से/Respondent By : Shri. R. Venkata Raman, C.A. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख/Date Of Pronouncement : 09.07.2025

Section 68 of the Act, the initial onus lies upon the assessee to offer an explanation regarding the nature and source of any credit found in the books of accounts. In the present case, the assessee has discharged this burden by stating that the sum in question represents agricultural income derived from self-owned agricultural land and by furnishing

DCIT CORPORATE CIRCLE 1, COIMBATORE vs. KOVAI MEDIA P. LTD., COIMBATORE

In the result, the appeal filed by the Revenue and cross

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunatha

127 (E) dated 19.02.2019 as the assessment order making an addition of Rs.2,72,80,664/- under section 56(2)(viib) was passed on 15.12.2018, whereas the date of issue of Notification is 19.02.2019. Hence, para no.4 of the Notification based on which the Ld. CIT(A) has given relief to the assessee is not applicable to this assessee

R MURUGAPPA @ MURUVAPPAN,PONDICHERRY vs. ITO, WARD-4, PONDICHERRY

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

68 of the Act consequently in the hands of the Appellant was wrong, erroneous, unjustified, incorrect and not sustainable in law. 4. The CIT (Appeals) failed to appreciate that the sustenance of the addition made in the hands of the Appellant was wrong, erroneous, unjustified, incorrect and not sustainable in law. 5. The CIT (Appeals) went wrong in recording

ITO, NCW - 3 (4),, CHENNAI vs. MS. KAVITHA SIDDAREDDY,, CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh, Hon’Ble & Shrimanjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.160/Chny/2020 िनधा"रणवष"/Assessment Year: 2013-14 V. The Income Tax Officer, Ms.Kavithasiddareddy, Non-Corporate Ward-3(4), No.7/1, Surabhi, Chennai. Sriram Nagar, North Street, Opp. To Frontline Eye Hospital, Alwarpet, Chennai-600 018. [Pan:Aeppk 0880 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) Department By : Mr.Ar.V.Sreenivasan, Addl.Cit. : Assessee By Mr.D.Anand, Adv : सुनवाईक"तारीख/Date Of Hearing 11.05.2023 : घोषणाक"तारीख /Date Of Pronouncement 14.06.2023 आदेश / O R D E R Per Manjunatha.G:

127 TTJ (Ctk.) (UO) 15]. 10.1. The Hon'ble Supreme Court in CIT vs. Smt. P.K. Noorjahan (1999) 237 ITR 570 (has held that the language used in the deeming provisions of Sections 68

SMART MARKETING,TIRUCHIRAPPALLI vs. ITO, WARD-2(1), TIRUCHIRAPPALLI

In the result the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1695/Chny/2024 िनधा"रण वष" / Assessment Year: 2021-22 Smart Marketing, The Income Tax Officer, No.19, Ground Floor, V. Ward -2(1), Arun Papers, 44, Williams Road, Opp To Gvn Hospital, Cantonment, Babu Road, Tiruchirapalli – 620 001. Tiruchirapalli – 620 008. [Pan: Adqfs-8517-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Mr. S. Girish Kumar, Advocate ""यथ" क" ओर से/Respondent By : Mr. C. Murugesan, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 05.02.2025 घोषणा की तारीख/Date Of Pronouncement : 20.02.2025 आदेश /O R D E R

section 68 of the Act and made an addition in spite of providing the identity of the lender. Apart from that :-5-: ITA. No: 1695/Chny/2024 the ld.AR stated that the assessee had filed the confirmation letter from the lender (page no.60 of PB), with her PAN, financial statements of the lender, computation of total income of the lender (page

C-2573 DHAMALERIMUTHUR PACCS LTD.,TIRUPATTUR vs. ITO, WARD-1, VELLORE

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1035/Chny/2025 िनधा"रण वष"/Assessment Year: 2020-21 C-2573 Dhamalerimuthur Paccs Ltd., Vs. The Income Tax Officer, 188/2, Dhamalerimuthur, Ward 1, Tirupattur, 635 853. Vellore. [Pan:Aabad1030D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Jainendar, C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 01.07.2025 घोषणा की तारीख /Date Of Pronouncement : 17.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 18.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2020-21. 2. The Assessee Raised 9 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under 2

68 of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances of the case. 3. Brief facts relating to the case are that the assessee filed return of income declaring total income of ₹.0. The case of the assessee was selected for complete scrutiny through CASS and notice under section

MAILANCHIKKAL ABDUL MUNEEM,CHENNAI vs. ITO INTERNATIONAL TAXATION 1(2), CHENNAI

In the result, the appeals filed by the assessee in ITA

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकर अपील सं./Ita No.: 2627/Chny/2017 िनधा"रण वष" /Assessment Year: 2013-14 & धनकर अपील सं/ Wta Nos.: 61/Chny/2017 & 75/Chny/2018 िनधा"रण वष" /Assessment Years: 2009-10 & 2010-11 Shri Mailanchikkal Abdul The Income Tax Officer / Muneem, V. The Wealth Tax Officer, Ff-1, 48, Chander Plaza Arcot International Taxation Ward Road, Saligramam, 1(2), Chennai – 600 093. Chennai. Pan: Aalpm 4410F (अपीलाथ"/Appellant) (""यथ"/Respondent)

68 cents situated at 127, A Block, Panruti Village, Sriperumbudur Taluk, Kanchipuram District on 06.06.2012 for sale consideration of Rs.2,76,00,000/-. The assessee after arriving at long term capital gain at Rs.21,95,913/- after claiming of indexation claimed deduction u/s.54F of the Act but the AO computed long term capital gains tax at Rs.3

TAMIL NADU BRICK INDUSTRIES,CHENNAI vs. ITO, CHENNAI

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.744/Chny/2017 "नधा"रण वष"/Assessment Year:2013-14 M/S. Tamilnadu Brick Industries, The Income Tax Officer, No. 47, Mangali Nagar 1St Street, Vs. Non Corporate Circle 8(1), Arumbakkam, Chennai 600 106. Chennai. [Pan: Aafft3643P] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri Vijay Kumar Punna, Jr. Standing Counsel सुनवाई क" तार"ख/ Date Of Hearing : 13.02.2018 घोषणा क" तार"ख /Date Of Pronouncement : 11.05.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai, Dated 27.02.2017 Relevant To The Assessment Year 2013-14. The Assessee Has Raised The Following Grounds: “1. The Order Of The Commissioner Of Income Tax (Appeals) 9, Chennai Dated 27.02.2017 In I.T.A.No.07/Cit(A)-9/2016-17 For The Above Mentioned Assessment Year Is Contrary To Law, Facts & In The Circumstances Of The Case.

127 which has taken such view. Section 45(2) therefore is relevant. 4.3.4 The capital gains as on conversion can be offered in the year of actual sale and the difference in sale price and market value on conversion will be offered as business profits. Looking at the situation independently, one can say that the provision of section

ITO NON CORPORATE WARD 2(1), CHENNAI vs. A.M.K.SHAHUL HAMEED, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1253/Chny/2019 िनधा"रण वष"/Assessment Years: 2012-13 The Income Tax Officer, Shri A.M.K. Shahul Hameed, Non Corporate Ward 2(1), Vs. Old No. 5, New No. 9, Rangan Street, Chennai 600 034. T. Nagar, Chennai 600 017. [Pan:Aabph6895F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ar V. Sreenivasan, Addl. Cit ""थ" की ओर से/Respondent By : Shri B. Ramakrishnan, C.A. सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 24.01.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-2, Chennai Dated 11.01.2019 Relevant To The Assessment Year 2012-13. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2012-13 On 01.06.2013 Admitting Total Income Of ₹.10,82,700/-. The Case Was Selected For Scrutiny & After Following Due Process, The Assessment Was Completed Under Section 2

68,26,030/- consequent to the denial of benefit claimed under section 54F of the Act on two counts viz., (i) delay in completion of construction of residential units and (ii) deduction was claimed on multiple properties. On appeal, by following the decisions Hon’ble Jurisdictional High Court, the ld. CIT(A) has held that the assessee is eligible

ACIT, CHENNAI vs. M/S. SGP EXIM PVT. LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 2005/Chny/2019 िनधा"रण वष" / Assessment Year: 2012-13 Deputy Commissioner Of M/S. S.G.P. Exim Pvt Ltd., Income Tax, V. No. 68, Cathedral Road, Corporate Circle 6(1), Goapalapuram, Chennai. Chennai – 600 086. [Pan: Aabcs-0551-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By : Shri. G. Baskar, Advocate सुनवाई क" तारीख/Date Of Hearing : 24.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 02.12.2022

68, Cathedral Road, Corporate Circle 6(1), Goapalapuram, Chennai. Chennai – 600 086. [PAN: AABCS-0551-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri. P. Sajit Kumar, JCIT ""यथ" क" ओर से/Respondent by : Shri. G. Baskar, Advocate सुनवाई क" तारीख/Date of Hearing : 24.11.2022 घोषणा क" तारीख/Date of Pronouncement : 02.12.2022 आदेश