ITO, NON CORPORATE WARD 1(4), , COIMBATORE vs. M/S SURABII GOLD , 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.: 372/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Income-Tax Officer, M/S. Surabii Gold, Non-Corporate Ward 1(4), V. 138, Karuppa Gounder Street, Aayakar Bhavan, K G Street, 63, Race Course Road, Coimbatore – 641 012. Coimbatore – 641 018. [Pan: Abufs-6503-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. D. Hema Bhupal, Jcit : Shri. S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 26.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.04.2024

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

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

68 to section 69A without issuing a specific show-cause notice violates section 251(2) and principles of natural justice. On this ground alone, the impugned action of the Ld.CIT(A) cannot be sustained. 24. With regard to the finding of fact about nature of business by the AO and ld.CIT(A) that the claim of moneylending business

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

68 to section 69A without issuing a specific show-cause notice violates section 251(2) and principles of natural justice. On this ground alone, the impugned action of the Ld.CIT(A) cannot be sustained. 24. With regard to the finding of fact about nature of business by the AO and ld.CIT(A) that the claim of moneylending business

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE2(2), CHENNAI, CHENNAI vs. S K T STUDIOS, CHENNAI

Appeal of the revenue is dismissed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

145(3) of the Act, making addition based on the statement recorded during the course of search is not sustainable. 8.3.12 As evident in the assessment order, it can be seen that the AO has contemplated the addition of Rs. 18.78 Crores (Rs. 13.08 Crores + Rs. 5.68 Crores ) on the basis of the statement recorded during the course of search

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. ASAIKANI NADAR KAMARAJ, RAJAPALAYAM

In the result, the appeal filed by the Revenue as well as Cross

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1197/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 & C.O. No. 54/Chny/2023 [In I.T.A. No. 1197/Chny/2023] The Assistant Commissioner Of Vs. Asaikani Nadar Kamaraj, Income Tax, 7/84, Pound Street, Chokkanathaputhur, Central Circle 2, Rajapalayam, Virudhunagar District, Madurai. Tamil Nadu 626 121. [Pan:Aaxpk1318E] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri R. Clement Ramesh Kumar, Cit Assessee By : Shri R. Venkataraman, C.A. सुनवाई की तारीख/ Date Of Hearing : 07.03.2024 घोषणा की तारीख /Date Of Pronouncement : 21.03.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue & The Cross Objection By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 31.08.2023 Relevant To The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2017-18 On 01.11.2017 Admitting A Total

145 of the Act, the Assessing Officer has concluded the assessment under section 144 of the Act dated 31.12.2019. During assessment proceedings, by considering the details in Form 26AS of the assessee for arriving at the total receipts from the civil contract business, the Assessing Officer has estimated net profits at 8% of the total receipt. Further, during

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

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

145 gms)\nAY 2012-13\n1,97,54,261\nAY 2013-14\n16,06,290\n41,84,410 (1,605 gms)\nAY 2014-15\n43,86,555\n37, 69,343 (1,446 gms)\nAY 2015-16\n68,16,158\n79,73,302 (3,060 gms)\nAY 2016-17\n45,50,376\n39,13,497 (1,350 gms)\nTotal

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

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

145 gms)\nAY 2012-13\n1,97,54,261\nAY 2013-14\n16,06,290\n41,84,410 (1,605 gms)\nAY 2014-15\n43,86,555\n37, 69,343 (1,446 gms)\nAY 2015-16\n68,16,158\n79,73,302 (3,060 gms)\nAY 2016-17\n45,50,376\n39,13,497 (1,350 gms)\nTotal

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

145 gms)\nAY 2012-13\n1,97,54,261\nAY 2013-14\n16,06,290\n41,84,410 (1,605 gms)\nAY 2014-15\n43,86,555\n37, 69,343 (1,446 gms)\nAY 2015-16\n68,16,158\n79,73,302 (3,060 gms)\nAY 2016-17\n45,50,376\n39,13,497 (1,350 gms)\nTotal

DCIT NON CORPORATE CIRCLE-4, COIMBATORE vs. NAVARATNA MAALIGAI, COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपीलसं./Ita No.: 801/Chny/2023 & Co No.: 48/Chny/2023 िनधा"रणवष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Navaratna Maaligai, Income Tax, V. No. 362, Raja Street, Non-Corporate Circle -4, Coimbatore – 641 001. Aayakar Bhavan, [Pan: Aaifn-6257-E] 63, Race Course Road, Coimbatore – 641 018. (अपीलाथ"/Appellant) (Respondent/Cross Objector) : Shri. P. Sajit Kumar, Jcit अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. T. Banusekar, Advocate सुनवाई क" तारीख/Date Of Hearing : 19.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.04.2024

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

THE INCOME TAX OFFICER, CORPORATE WARD-2,, COIMBATORE vs. M/S SAHANA JEWELLERY EXPORTS PRIVAE LTD., COIMBATORE

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.999/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. The Income Tax Officer, M/S.Sahana Jewellery- Corporate Ward-2, Exports Pvt. Ltd., Coimbatore. 600, Raja Street, Coimbatore-641 001. [Pan:Aaecs 7045 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

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

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

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

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

JCIT NON CORPORATE CIRCLE 2, COIMBATORE vs. TARA JEWELLERY, 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.: 276/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Joint Commissioner Of M/S. Tara Jewellery, Income-Tax, V. 61, West Bashyakaralu Road, Non-Corporate Circle -2, R S Puram, Aayakar Bhavan, Coimbatore – 641 002. 63, Race Course Road, [Pan: Aagft-2345-B] Coimbatore – 641 018. (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. D. Hema Bhupal, Jcit अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 25.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.04.2024

68 needed to be sustained as untenable, in view of the finding recorded by the Tribunal. [Para 14.4] • The entire purchase and sales had been duly recorded in the regular books of account of all parties; the transactions were routed through regular banking channels; the purchase and sales were duly supported by quantitative details; copies of bank statements showing sales

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2), CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

sections": [ "139", "143(2)", "143(3)", "153C", "132", "145(3)", "144", "271AAD", "145(3)", "68", "69", "69C", "145(3)", "145

ACIT, CIRCLE-1, TIRUNELVELI vs. ESAKKIMUTHU MUTHUVEL IYAPPAN, TIRUNELVELI

In the result, appeal filed by the revenue stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.794/Chny/2022 (िनधा"रणवष" / Assessment Year: 2017-2018) The Assistant Commissioner Of Vs. Shri Esakkimuthu Muthuvel Iyappan, Income Tax, No.4, Highways Road, Circle 1, Tisayanvilai, Tirunelveli 627 011. Tirunelveli 627 657. [Pan : Arupm 4796J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. T. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Arv Srinivasan, Irs, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 19.06.2024 घोषणा क" तार"ख /Date Of Pronouncement : 24.07.2024 आदेश / O R D E R Per Manu Kumar Giri ()

Section 145(3) of the I.T. Act. The cause of suspicion should trigger the Assessing Officer to use the appropriate legal provisions to bring conclusively concealed particulars. Since the appellant had already the admitted the sales as revenue receipt supported by VAT returns there is no case to decide for making the addition of cash deposits u/s 68

BSR BUILDERS ENGINEERS CONTRACTORS,,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

145 TTJ 340 to arrive at his conclusion. The relevant findings of the Ld. CIT(A) taken note of by us, are as follows:- “6.3.8 The undersigned has carefully considered the issue under consideration. On examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion

DCIT, CHENNAI vs. BSR BUILDERS ENGINEERS CONTRACTORS, CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

145 TTJ 340 to arrive at his conclusion. The relevant findings of the Ld. CIT(A) taken note of by us, are as follows:- “6.3.8 The undersigned has carefully considered the issue under consideration. On examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion

ACIT, CHENNAI vs. M/S. BSR BUILDERS ENGINEERS CONTRACTORS , CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

145 TTJ 340 to arrive at his conclusion. The relevant findings of the Ld. CIT(A) taken note of by us, are as follows:- “6.3.8 The undersigned has carefully considered the issue under consideration. On examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion

BSR BUILDERS ENGINEERS CONTRACTORS, ,CHENNAI vs. DCIT, CENT. CIRCLE-2(3), CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

145 TTJ 340 to arrive at his conclusion. The relevant findings of the Ld. CIT(A) taken note of by us, are as follows:- “6.3.8 The undersigned has carefully considered the issue under consideration. On examination of the submission of the appellant it can be seen that the appellant firm submits that it has been consistently following the “Project Completion