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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

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

section 68 of the Act, nowhere it is mentioned ‘regular’ books of accounts. The intention of the legislature to mention as ‘books’ is to include all the books whether it is regular or irregular: disclosed or undisclosed. 1.3 CIT(A) relying the diary to hold that the ‘cash receipts’ as reflected in the diary are on account of business

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPUR vs. SRI SHANMUGAVEL MILLS PRIVATE LIMITED, TIRUPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

68,67,372/- for the whole of the year. 6. It may be noted that the assessee claimed a deduction u/s.80-IA of the Act to the tune of Rs.18,41,58,470/- and the AO vide assessment order passed u/s.143(3)r.w.s.144C(3)r.w.s.144B dated 11.06.2021 in accordance with the value determined by TPO determined the ALP of the inter

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPPUR vs. PRABHU SPINNING MILLS PRIVATE LIMITED, TIRUPPUR

In the result all the grounds raised by the revenue for the A

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 Prabhu Spining Mills Private 121, Adarns Plaza, Vs. Limited, 60, Feet Road, No. 207 – 86, Mangalam Road, Tiruppur – 641 602. Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. (अपीलाथी/Appellant) [Pan:Aabcp-0750-E] (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यथी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

8) held that the average selling price by an assessee to TANGEDCO should be based on the tariff rates fixed by Tamil Nadu Electricity Regulatory Commission (TNERC) for purchase of electricity generated by a windmill undertaking which during the year would have been as follows: Sl.N Name of wind Date of No. of units Tariff rate ALP of sale

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,TIRUPPUR, TIRUPPUR vs. PRABHU SPINNING MILLS PRIVATE LIMITED, TIRUPPUR

In the result all the grounds raised by the revenue for the A

8) held that the average selling price\nby an assessee to TANGEDCO should be based on the tariff rates fixed by Tamil\nNadu Electricity Regulatory Commission (TNERC) for purchase of electricity\ngenerated by a windmill undertaking which during the year would have been as\nfollows:\nSI.N\n0.\nName of wind\nenergy\ngenerator\nDate of\ncommissio\nning the\nNo. of units

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

13 9 0 0 0 22 13 9 05-06 37 28 0 0 0 65 37 28 65 06-07 ITA Nos2125 to 2128 :- 68 -: & 2219 to 2222 /2017

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

13 9 0 0 0 22 13 9 05-06 37 28 0 0 0 65 37 28 65 06-07 ITA Nos2125 to 2128 :- 68 -: & 2219 to 2222 /2017

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

13 9 0 0 0 22 13 9 05-06 37 28 0 0 0 65 37 28 65 06-07 ITA Nos2125 to 2128 :- 68 -: & 2219 to 2222 /2017

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

13 9 0 0 0 22 13 9 05-06 37 28 0 0 0 65 37 28 65 06-07 ITA Nos2125 to 2128 :- 68 -: & 2219 to 2222 /2017

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

13. From the above amendment to section 68 of the Act, it is abundantly clear that the said amendment is not a retrospective amendment and thus, the source of source in relation to credit by way of loans or borrowing or any such amount can be insisted by the AO only from Assessment Year 2023-2024 onwards. Therefore

INCOME TAX OFFICER, BIBIKULAM MADURAI vs. D N PUBLIC CHARITABLE TRUST, ARASARADI MADURAI TAMIL NADU

13(1)(c) of the Act in the preceding\nparagraph Consequently, the appellant trust is eligible for the exemption\nclaimed in the return of income under sections 11 and 12 of the Act for surplus\nincome. Accordingly, the addition of Rs. 19,59,537/- is hereby deleted.\n12. Aggrieved by the aforesaid action of the Ld.CIT(A)/NFAC

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 115BBE of the Act will have no application so as to treat the income of the assessee as income from other sources. Hon'ble Kolkata Tribunal in the case of CIT Vs. Associated Transport Pvt. Ltd. reported in 84 Taxman 146 on identical facts took the view that when cash sales are admitted and income from sales

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.

13. Since, facts are identical and issues are common, for the sake of convenience, these appeals were heard together and are being disposed off, by this consolidated order. 2. The assessee has more or less filed common grounds of appeal for all assessment years, therefore, for the sake of brevity, grounds of appeal filed for the assessment year