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

131(1A) could not disprove this claim by bringing out any discrepancies :-20-: ITA. No: 1106/Chny/2023 in the purchases, sales and closing Stock as on the dates of enquiries 6.17 Further, the cash deposited in the demonetized currency added as income of the assessee by applying the provisions of section 68

SMT. SHOBHA AGARWAL,,CHENNAI vs. DCIT, CENTRAL CIRCLE - 3 (2),, CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 3263/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Rita Agarwal, The Deputy Commissioner Of 4D, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aagpr4368A] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3264/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Shri Pankaj Agarwal, Vs. The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aflpa1767N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3265/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Shobha Agarwal, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aaxpc8430H] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3266/Chny/2019 िनधा"रण वष"/Assessment Year:2012-13 Smt. Bimla Devi, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aadpd8240L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent)

section 68 of the Act. The ld. Counsel for the assessee, further referring to the assessment order submitted that 17 I.T.A. Nos.3263-3266/Chny/19 the Assessing Officer has made addition on the basis of bank statement, which was filed by the assessee during the course of assessment proceedings, but such bank statement was already with the Assessing Officer and thus

SMT. BIMLA DEVI,,CHENNAI vs. DCIT, CENTRAL CIRCLE - 3(2),, CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 3263/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Rita Agarwal, The Deputy Commissioner Of 4D, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aagpr4368A] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3264/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Shri Pankaj Agarwal, Vs. The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aflpa1767N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3265/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Shobha Agarwal, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aaxpc8430H] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3266/Chny/2019 िनधा"रण वष"/Assessment Year:2012-13 Smt. Bimla Devi, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aadpd8240L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent)

section 68 of the Act. The ld. Counsel for the assessee, further referring to the assessment order submitted that 17 I.T.A. Nos.3263-3266/Chny/19 the Assessing Officer has made addition on the basis of bank statement, which was filed by the assessee during the course of assessment proceedings, but such bank statement was already with the Assessing Officer and thus

SMT. RITA AGARWAL,,CHENNAI vs. DCIT, CENTRAL CIRCLE - 3 (2),, CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 3263/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Rita Agarwal, The Deputy Commissioner Of 4D, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aagpr4368A] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3264/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Shri Pankaj Agarwal, Vs. The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aflpa1767N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3265/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Shobha Agarwal, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aaxpc8430H] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3266/Chny/2019 िनधा"रण वष"/Assessment Year:2012-13 Smt. Bimla Devi, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aadpd8240L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent)

section 68 of the Act. The ld. Counsel for the assessee, further referring to the assessment order submitted that 17 I.T.A. Nos.3263-3266/Chny/19 the Assessing Officer has made addition on the basis of bank statement, which was filed by the assessee during the course of assessment proceedings, but such bank statement was already with the Assessing Officer and thus

SHRI PANKAJ AGARWAL,,CHENNAI vs. DCIT, CENTRAL CIRCLE,, CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 3263/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Rita Agarwal, The Deputy Commissioner Of 4D, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aagpr4368A] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3264/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Shri Pankaj Agarwal, Vs. The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aflpa1767N] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3265/Chny/2019 िनधा"रण वष"/Assessment Year:2011-12 Smt. Shobha Agarwal, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aaxpc8430H] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 3266/Chny/2019 िनधा"रण वष"/Assessment Year:2012-13 Smt. Bimla Devi, The Deputy Commissioner Of 4E, Heritage Apartments, Orms Road, Vs. Income Tax, Kilapauk, Chennai 600 010. Central Circle 3(2), [Pan:Aadpd8240L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent)

section 68 of the Act. The ld. Counsel for the assessee, further referring to the assessment order submitted that 17 I.T.A. Nos.3263-3266/Chny/19 the Assessing Officer has made addition on the basis of bank statement, which was filed by the assessee during the course of assessment proceedings, but such bank statement was already with the Assessing Officer and thus

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

68, section 69, section 69A, section 69B, section 69C or section 69D\nto the extent such income has been included by the assessee in the return of\nincome furnished under section 139 and the tax in accordance with the\nprovisions of clause (i) of sub-section (1) of section 115BBE has been

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

sections": [ "143(3)", "132", "131", "154", "115BBE", "270A", "271(1)(c)", "271AAC", "68", "69", "69A", "69B", "69C", "69D", "246A

MRS. USHA KRISHNAN,CHENNAI vs. ITO, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.2780/Mds/2016 "नधा"रण वष" / Assessment Year : 2012-13 Mrs. Usha Krishnan, The Income Tax Officer, No.9/1, Eighth Street, V. Non Corporate Ward - 18(3), Nanganallur, Chennai - 600 061. Chennai - 600 034. Pan : Aahpu 1864 D (अपीलाथ"/Appellant) (""यथ"/Respondent)

68 of the Income-tax Act, 1961 2 I.T.A. No.2780/Mds/16 (in short 'the Act'). According to the Ld. counsel, the assessee has received gifts from her husband and other close relatives. All the relatives who gifted money to the assessee were summoned by the Assessing Officer under Section 131

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

sections": [ "143(3)", "132", "131", "270A", "154", "115BBE", "271AAC", "271(1)(c)", "246A", "250", "274", "275", "68", "69", "69A", "69B", "69C", "69D", "139" ], "issues

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. J VIVEK, THIRUVARUR

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1778/Chny/2024 िनधा"रण वष"/Assessment Year: 2016-17 The Deputy Commissioner Of Vs. J. Vivek, Income Tax, No. 32/1, Mannai Nagar, Mannargudi, Central Circle 2(4), Thiruvarur 614 001. Chennai. [Pan:Aqqpv7997M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundar Rajan, Cit ""थ" की ओर से/Respondent By : Ms. S. Jecintha, Advocate सुनवाई की तारीख/ Date Of Hearing : 12.02.2025 घोषणा की तारीख /Date Of Pronouncement : 26.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi:

68 of the Act. Thereafter, by considering the rectification application of the assessee under section 154 of the Act, the Assessing Officer assessed the total income of the assessee at ₹.4,40,51,970/- vide his order dated 24.06.2020. 4. Having aggrieved by the order made under section 69A of the Act, the assessee preferred an appeal before

DCIT, CENTRAL CIRCLE2(4), CHENNAI vs. S. ELAMBHARATHI, CHENNAI

In the result, both the appeals filed by the Revenue and the Cos\nfiled by the assessee are dismissed

section 68 of the Act. The\nRevenue is in appeal before the Tribunal by raising grounds forming part\nof Form 36.\n7. Heard both the parties and perused the material on record. We find\nsimilar issue on same identical facts arising out of same search in the\ncase of Shri Karuppagounder Palaniswami came up before this Tribunal,\nwhich

ACIT, NCC-11,, CHENNAI vs. SMT. DEVAKUMARI,, CHENNAI

In the result, the appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.3066/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Smt. Devakumari, Vs. The Assistant Commissioner Of No. 48, Venkata Maistry Street, Income Tax, Mannady, Chennai 600 001. Non Corporate Circle 11, Chennai. [Pan:Aagpd0150L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.3181/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Assistant Commissioner Of Vs. Smt. Devakumari, Income Tax, No. 48, Venkata Maistry Street, Non Corporate Circle 11(1), Mannady, Chennai 600 001. Chennai.

68 of the Act. 6.2 Before the Tribunal, the Revenue has filed an appeal against deletion of addition towards unsecured loans taken to the extent of ₹.2.40 crores as well as allowing the interest of ₹.7,62,738/- on the above unsecured loans. Against the total deletion of addition towards unsecured loans of ₹.2,85,00,000/-, by accepting

SMT. DEVAKUMARI,CHENNAI vs. ACIT, NCC-11, , CHENNAI

In the result, the appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.Corrigendum To I.T.A. No.3066/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Smt. Devakumari, Vs. The Assistant Commissioner Of No. 48, Venkata Maistry Street, Income Tax, Mannady, Chennai 600 001. Non Corporate Circle 11, [Pan:Aagpd0150L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) शु""प" आदेश /Corrignendum Order Per V. Durga Rao: The Appeal Of The Assessee In Ita No. 3066/Chny/2019 As Well As The Appeal Filed By The Revenue In Ita No. 3181/Chny/2019 For The Assessment Year 2014-15 Were Disposed Off By The Division Bench ‘B’, Chennai Benches, Chennai Vide Common Order Dated 13.09.2023. The Ld. Counsel For The Assessee Has Brought To The Notice That There Is A Typographical Error In Last Sentence In Para 9 Of The Order, Wherein, The Bench Has Observed That The Element Of Personal Usage Cannot Be Ruled Out In The Absence Of Production Of Electricity Bills & Thereby, The Addition To The Extent Of ₹.2,00,000/- Has Been Sustained Out Of Addition Confirmed By The Ld. Cit(A). However, It Was Also Mentioned That The “Balance Addition Of ₹.3,00,000/- Stands Sustained” Is A Typographical Error.

68 of the Act. 6.2 Before the Tribunal, the Revenue has filed an appeal against deletion of addition towards unsecured loans taken to the extent of ₹.2.40 crores as well as allowing the interest of ₹.7,62,738/- on the above unsecured loans. Against the total deletion of addition towards unsecured loans of ₹.2,85,00,000/-, by accepting

S.BAGAVATHI RAJAM,CHENNAI vs. ITO NON CORPORATE WARD 23(10, TAMBARAM

Appeal is allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudharyआयकरअपीलसं./I.T.A No.:2876/Chny/2018 िनधा"रणवष"/Assessment Year: 2011 - 2012 Smt. S. Bagavathi Rajam, Phase 2, Villa 17, Chettinad Enclave, Pallikaranai, Chennai - 600100 अपीलाथ"/Appellant Pan: Awhps2925B …………… Vs. The Income Tax Officer, Non Corporate Circle 23(1), ""थ"/Respondent Tambaram …………… Appearances: For The Appellant/Assessee : Shri M. Karunakaran, Advocate For The Respondent/Department : Shri G Johnson, Addl. Cit Date Of Conclusion Of Hearing : 02.06.2022 Date Of Pronouncement Of Order : 26 .08.2022 आदेश /O R D E R Per Rahul Chaudhary:

68 of the Act by identifying the source of cash deposits. However, the Assessing Officer rejected explanation offered by the Appellant regarding source of cash on the ground that the Appellant had, on one hand, taken a stand that the Appellant was not maintaining any books of accounts, while on the other hand, the Appellant was relying upon statement

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

131 of the Act wherein he had stated that, the accounts section is separate and he is Act wherein he had stated that, the accounts section is separate and he is Act wherein he had stated that, the accounts section is separate and he is not aware as to the manner in which account entries are made

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

131 of the Act wherein he had stated that, the accounts section is separate and he is Act wherein he had stated that, the accounts section is separate and he is Act wherein he had stated that, the accounts section is separate and he is not aware as to the manner in which account entries are made

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

131 of the Act wherein he had stated that, the accounts section is separate and he is Act wherein he had stated that, the accounts section is separate and he is Act wherein he had stated that, the accounts section is separate and he is not aware as to the manner in which account entries are made

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. PERIYASAMY ANBUNATHAN, KARUR

68,163\n2017-18\nTotal\n40,77,13,731\n5.\nThe summary of the additions/disallowances in Rupees made by the\nAO which are in dispute in the cross appeals for AYs 2014-15 to 2017-18\nare as follows:\nParticulars\n14-15\n15-16\n16-17\n17-18\nNotings found in account\nbook(s)\nID\nmarked\nANN/FAY/CPA/B&D/S-1 on\nprotective

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

Section 92CA(3) was passed on 20.12.2018 proposing downward adjustment of Rs.832.05 crores to the cost of equipment imported from MIPP. The TPO did not propose any adjustment on the receipt of share capital reported in the Form ЗСЕВ.\n4.6\nSubsequently, a show cause notice ('SCN') was issued on 11.02.2019 to show cause why share capital and share premium