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)

143(3) r.w.s. 153A of the Act dated 31.03.2015 by making addition of ₹.1,25,00,000/- under section 68

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)

143(3) r.w.s. 153A of the Act dated 31.03.2015 by making addition of ₹.1,25,00,000/- under 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)

143(3) r.w.s. 153A of the Act dated 31.03.2015 by making addition of ₹.1,25,00,000/- under section 68

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)

143(3) r.w.s. 153A of the Act dated 31.03.2015 by making addition of ₹.1,25,00,000/- under section 68

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

143(3), the AO made the additions viz; Disallowance of interest expenditure of Rs.14,94,644/-, Treating Rs.38,79,163/- offered under "Other sources" as unexplained cash credit u/s 68 and taxing under section

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

143(3), the AO made the additions viz; Disallowance of interest expenditure of Rs.14,94,644/-, Treating Rs.38,79,163/- offered under "Other sources" as unexplained cash credit u/s 68 and taxing under section

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

68", "Section 143(1)", "Section 153A", "Section 143(3)", "Section 153C", "Section 292C"], "issues": "Whether

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 132(4) did not constitute incriminating material. [Para 10.4] • The Tribunal, has correctly analyzed the statement of the managing director. The statement does not allude to the fact that the assessee had introduced 'unaccounted money' in the form of share capital/share premium through investor entities. The retraction letter, as noted by the Tribunal, also did not advert

PRAKASH,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

section 148 of the Act, and pointing out that ld. Assessing Officer was not sure whether income escaped assessment was more than "1,00,000/-. As per the assessees, the reopening was purely based on presumptions and reasons recorded were vague. Assessees also alleged that there was no live link between reasons recorded and formation of believe for escapement

M.R.PRASAD,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

section 148 of the Act, and pointing out that ld. Assessing Officer was not sure whether income escaped assessment was more than "1,00,000/-. As per the assessees, the reopening was purely based on presumptions and reasons recorded were vague. Assessees also alleged that there was no live link between reasons recorded and formation of believe for escapement

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

section 148 of the Act, and pointing out that ld. Assessing Officer was not sure whether income escaped assessment was more than "1,00,000/-. As per the assessees, the reopening was purely based on presumptions and reasons recorded were vague. Assessees also alleged that there was no live link between reasons recorded and formation of believe for escapement

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

section 148 of the Act, and pointing out that ld. Assessing Officer was not sure whether income escaped assessment was more than "1,00,000/-. As per the assessees, the reopening was purely based on presumptions and reasons recorded were vague. Assessees also alleged that there was no live link between reasons recorded and formation of believe for escapement

M.R.PRASAD,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

section 148 of the Act, and pointing out that ld. Assessing Officer was not sure whether income escaped assessment was more than "1,00,000/-. As per the assessees, the reopening was purely based on presumptions and reasons recorded were vague. Assessees also alleged that there was no live link between reasons recorded and formation of believe for escapement

PRAKASH,TRICHY vs. ITO, TRICHY

In the result, the appeals of the assessees for all the

Bench: Shri Abraham P. George]

section 148 of the Act, and pointing out that ld. Assessing Officer was not sure whether income escaped assessment was more than "1,00,000/-. As per the assessees, the reopening was purely based on presumptions and reasons recorded were vague. Assessees also alleged that there was no live link between reasons recorded and formation of believe for escapement

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

ITO, NCW - I (4),, CHENNAI vs. M/S. NITHYASUDHA COMBINES,, CHENNAI

In the result, both the appeals filed by the Revenue as well as Cross Objections filed by the assessee are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.576 & 577/Chny/2020 िनधा"रण वष"/Assessment Year: 2015-16 & C.O. Nos. 06 & 07/Chny/2021 [In I.T.A. No. 576 & 577/Chny/2020] The Income Tax Officer, Vs. M/S. Nithyasudha Combines, Non Corporate Ward 1(4), No. 8/20, Second Cross Street, Chennai – 600 034. Nandanam Extension, Nandanam, Chennai 600 085. [Pan: Aakfn6811A] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By : Shri R. Venkata Raman, C.A. सुनवाई की तारीख/ Date Of Hearing : 25.04.2022 घोषणा की तारीख /Date Of Pronouncement : 06.05.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai, Both Dated 16.12.2019 Relevant To The Assessment Year 2015-16 Passed Against Deletion Of Quantum Addition Made Under Section 68 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Deletion Of Penalty Levied Under Section 271(1)(C) Of The Act. The First

68 of the Act. Thus, the appeal filed by the Revenue is dismissed. 8. The Revenue has also preferred an appeal against deletion of penalty levied under section 271(1)(c) of the Act. 8.1 After passing the assessment order under section 143

ITO, NCW - I (4),, CHENNAI vs. M/S. NITHYASUDHA COMBINES,, CHENNAI

In the result, both the appeals filed by the Revenue as well as Cross Objections filed by the assessee are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.576 & 577/Chny/2020 िनधा"रण वष"/Assessment Year: 2015-16 & C.O. Nos. 06 & 07/Chny/2021 [In I.T.A. No. 576 & 577/Chny/2020] The Income Tax Officer, Vs. M/S. Nithyasudha Combines, Non Corporate Ward 1(4), No. 8/20, Second Cross Street, Chennai – 600 034. Nandanam Extension, Nandanam, Chennai 600 085. [Pan: Aakfn6811A] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By : Shri R. Venkata Raman, C.A. सुनवाई की तारीख/ Date Of Hearing : 25.04.2022 घोषणा की तारीख /Date Of Pronouncement : 06.05.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai, Both Dated 16.12.2019 Relevant To The Assessment Year 2015-16 Passed Against Deletion Of Quantum Addition Made Under Section 68 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Deletion Of Penalty Levied Under Section 271(1)(C) Of The Act. The First

68 of the Act. Thus, the appeal filed by the Revenue is dismissed. 8. The Revenue has also preferred an appeal against deletion of penalty levied under section 271(1)(c) of the Act. 8.1 After passing the assessment order under section 143

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

143 or under Sec.144 is appealable. Similarly, the various other clauses of Sec. 246 specifically refer to the particular section, orders passed whereunder were appealable. In this setting, the use of the phrase “under this Act” should not mean under any individual section or provision of this Act. 5. In the case of Sushi 1 Kumar v. Commissioner

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

143 or under Sec.144 is appealable. Similarly, the various other clauses of Sec. 246 specifically refer to the particular section, orders passed whereunder were appealable. In this setting, the use of the phrase “under this Act” should not mean under any individual section or provision of this Act. 5. In the case of Sushi 1 Kumar v. Commissioner