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

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

68,163 2017-18 - Total 40,77,13,731 5. The summary of the additions/disallowances in Rupees made by the AO which are in dispute in the cross appeals for AYs 2014-15 to 2017-18 are as follows: Particulars 14-15 15-16 16-17 17-18 Notings found in account

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

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

68,163 2017-18 - Total 40,77,13,731 5. The summary of the additions/disallowances in Rupees made by the AO which are in dispute in the cross appeals for AYs 2014-15 to 2017-18 are as follows: Particulars 14-15 15-16 16-17 17-18 Notings found in account

PERIASAMY ANBUNATHAN,KARUR vs. DCIT, CC-1(4), CHENNAI

In the result, all the appeals of the Revenue and the assessee are partly allowed for statistical purposes and the cross objections of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

68,163 2017-18 - Total 40,77,13,731 5. The summary of the additions/disallowances in Rupees made by the AO which are in dispute in the cross appeals for AYs 2014-15 to 2017-18 are as follows: Particulars 14-15 15-16 16-17 17-18 Notings found in account

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

M/S. P.P. FINANCIERS,KARUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

L KARUPPUSAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P P ENTERPRISES, BENGALURU

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

M/S. P.P. FINANCIERS,KARUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

P. PALANISAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

P.P. ENTERPRISES,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

M/S. P.P. ENTERPRISES,BENGALURU vs. ACIT< CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

PALANISAMY RAGHUPATHY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

P. PALANISAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

SELLAMUTHU KABILAN,BENGALURU vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

M/S. P.P. FINANCIERS,CHENNAI vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

153D of the Act, we\nnote that the said affidavit seeks to explain the procedure followed\nin the search assessment proceedings and delineates the respective\nroles of the Assessing Officer and the Range Head. The ld.AR has,\non the other hand, invited our attention to certain alleged clerical\n.. 45 ::\nand arithmetical errors in the approvals granted u/s.153D

M/S. P.P. ENTERPRISES,DINDIGUL vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

68==\ndistinct Profit and Loss account and Balance sheets are maintained in\nthe form of the monthly books along with other daily, weekly books.\nThe Assessing officer has incorporated scanned copies of sample pages\nof the different pages of the seized books / seized Profit and Loss\naccount and Balance Sheets in the assessment orders.\nThe firm PP Financiers Karur

P PALANISMAY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

153D of the Act, we\nnote that the said affidavit seeks to explain the procedure followed\nin the search assessment proceedings and delineates the respective\nroles of the Assessing Officer and the Range Head. The ld.AR has,\non the other hand, invited our attention to certain alleged clerical\n==End of OCR for page 45==\nand arithmetical errors

M/S. P.P. FINANCIERS,KARUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

section 115BBE increasing the rate of tax to 60% is not retrospectively applicable. The Hon’ble Madras High Court in S.M.I.L.E Microfinance Limited v ACIT 2024 SCC OnLine Mad 8416 (Pages 248 – 259 of Case Law Book 1) has categorically held that the rate of 60 percent is to be imposed only for the transactions from 01.04.2017. The above