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

150/- Add: Disallowance of interest unrelated to Rs. 8,93,642/- profession Income assessed u/s 143(3) r.w.s 153A Rs. 5,35,492/- Tuition income as undisclosed income u/s 68 Rs. 10,65,970/- Gift received as undisclosed income u/s 68 Rs. 24,80,636/- Receipts from friends and relatives u/s 68 Rs. 50,50,000/- Long Term Capital gain

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

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

150 taxmann.com 108 (SC). Even earlier the hon'ble Delhi High Court had held in PCIT v Vikas Telecom Ltd [2022] 135 taxmann.com 362 (Delhi) had held that post-search enquiries cannot be the basis of assessments under Section 153A/153C. Therefore, the reliance placed by the AO on the TP orders passed after the search cannot be countenanced.\n9.7

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

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

Section 43B 153A bearing funds 6. Donations disallowance disallowed assessee 10,91,095 30,00,000 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 1989, 1449 to 1455, 1485 to 1491/17. ITA Nos. 1447, 1448, 1988, 19,00,874 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 4,30,000 7,240 ----- ----- ----- ----- ----- ----- ----- ---- ---- ---- 1,36,558 4,09,277 99,884 23,67,150

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

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

Section 43B 153A bearing funds 6. Donations disallowance disallowed assessee 10,91,095 30,00,000 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 1989, 1449 to 1455, 1485 to 1491/17. ITA Nos. 1447, 1448, 1988, 19,00,874 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 4,30,000 7,240 ----- ----- ----- ----- ----- ----- ----- ---- ---- ---- 1,36,558 4,09,277 99,884 23,67,150

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

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

Section 43B 153A bearing funds 6. Donations disallowance disallowed assessee 10,91,095 30,00,000 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 1989, 1449 to 1455, 1485 to 1491/17. ITA Nos. 1447, 1448, 1988, 19,00,874 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 4,30,000 7,240 ----- ----- ----- ----- ----- ----- ----- ---- ---- ---- 1,36,558 4,09,277 99,884 23,67,150

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

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

Section 43B 153A bearing funds 6. Donations disallowance disallowed assessee 10,91,095 30,00,000 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 1989, 1449 to 1455, 1485 to 1491/17. ITA Nos. 1447, 1448, 1988, 19,00,874 ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- 4,30,000 7,240 ----- ----- ----- ----- ----- ----- ----- ---- ---- ---- 1,36,558 4,09,277 99,884 23,67,150

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

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

150 taxmann.com 108 (SC). Even earlier\nthe hon'ble Delhi High Court had held in PCIT v Vikas Telecom Ltd\n[2022] 135 taxmann.com 362 (Delhi) had held that post-search\nenquiries cannot be the basis of\nassessments under Section 153A/153C. Therefore, the reliance\nplaced by the AO on the TP orders passed after the search\ncannot be countenanced

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

150-51 (Bom.). The Hon’ble jurisdictional High Court held as under:- “Held, that there was material on record on the basis of survey and statement of person to show that the assessee had wrongfully claim deduction u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

150-51 (Bom.). The Hon’ble jurisdictional High Court held as under:- “Held, that there was material on record on the basis of survey and statement of person to show that the assessee had wrongfully claim deduction u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

150-51 (Bom.). The Hon’ble jurisdictional High Court held as under:- “Held, that there was material on record on the basis of survey and statement of person to show that the assessee had wrongfully claim deduction u/s 80IA. Therefore, the Assessing Officer had reason to believe that income had escaped assessment for assessment year 1994-95.” Identically

SMT P.D.ANURADHA,COIMBATORE vs. ACIT, COIMBATORE

In the result, both the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

150 9. The learned Counsel for the Assessee stated that on these declared items, the Assessee paid taxes amounting to Rs.4,81,245/- which was accepted by the concerned Commissioner of Income Tax at that point of time. The learned Counsel drew our attention to the declaration filed in Form under Rule-3 and the relevant Annexure :: 10 :: I.T.A. Nos.102

SMT P.D.ANURADHA,COIMBATORE vs. ACIT, COIMBATORE

In the result, both the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

150 9. The learned Counsel for the Assessee stated that on these declared items, the Assessee paid taxes amounting to Rs.4,81,245/- which was accepted by the concerned Commissioner of Income Tax at that point of time. The learned Counsel drew our attention to the declaration filed in Form under Rule-3 and the relevant Annexure :: 10 :: I.T.A. Nos.102

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

68,89,00,000 under Section 56(2)(viia) of the Act; and o Disallowance of interest expenditure of INR 5,70,62,500 under Section 36(1)(iii) of the Act, being computed at 10% of the buyback value, i.e., 57,06,25,000 :-9-: ITA Nos.:1339, 1616/Chny/2025 & C.O.No.66/Chny/2025 • Pursuant to the appeal filed

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

68,89,00,000 under Section 56(2)(viia) of the Act; and o Disallowance of interest expenditure of INR 5,70,62,500 under Section 36(1)(iii) of the Act, being computed at 10% of the buyback value, i.e., 57,06,25,000 :-9-: ITA Nos.:1339, 1616/Chny/2025 & C.O.No.66/Chny/2025 • Pursuant to the appeal filed

TR PCHAMUTHU NOW KNOWN AS TR PAARIVENDHAR,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(3), CHENNAI

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

section 67(2) of the Scheme. The credit remains unexplained and therefore, warrants addition u/s 68 of the Income-tax Act, 1961 for the failure of the assessee to prove the source of this credit in his books for the assessment year 1998-99. 12. Accordingly, the addition of Rs. 1,50,10,000 u/s 68 of the Income

SRI NIDHI FINANCE,SALEM vs. THE INCOME TAX OFFICER, WARD 1(4), SALEM

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

68 of the Act to an extent of\n₹.4,46,524/- vide his order dated 11.12.2019 passed under section\n143(3) of the Act. The Id. CIT(A) confirmed the same.\n8.\nBefore us, the Id. AR placed on record paper book consisting 308\npages. He drew our attention to page

VIRUTCHAM MICRO FINANCE LTD.,MADURAI vs. ITO, CORP. CIRCLE.2,, MADURAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.1313/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Virutcham Micro Finance Limited, Vs. The Assistant Commissioner Of C-50, Gurudev Nagar, Avaniyapuram Income Tax, Bypass Road, Madurai 625 002. Corporate Circle 2, Madurai. [Pan:Aaccv9529Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. V. Supraja, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 16.07.2025 घोषणा की तारीख /Date Of Pronouncement : 18.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. When The Appeal Was Taken Up For Hearing On 16.07.2025, We Find No Representation On Behalf Of The Assessee. Further, On Perusal Of The Record, We Find That The Notice Issued On 18.06.2025 Returned

section 68 of the Income Tax Act, 1961 [“Act” in short] in the facts and circumstances of the case. 4. Brief facts emanating from record are that the assessee filed the return of income admitting total income of ₹.35,00,150