SRINIVASAN MOHAMMAD IBRAHIM,MADURAI vs. ITO,NON-CORPORATE WRD-2(3), MADURAI

In the result, the appeal filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.233 & 234/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 Srinivasan Mohammad Ibrahim, Vs. The Income Tax Officer, 69, South Marret Street, Non Corporate Ward 2(3), Madurai South, South Gate S.O., Chennai. Madurai 625 001. [Pan: Ailpm0929R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri R. V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 23.07.2024 घोषणा की तारीख /Date Of Pronouncement : 26.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi:

156/- made under section 68 of the Act. 4. At the outset, we note that the assessment was completed

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

68 of the Act is patently unwarranted. It\nwas therefore submitted that the addition sustained by the Ld.CIT(A) is liable to\nbe deleted in full.\n54. The Ld. AR submitted that Section 47 of the Act, enumerates transactions\nwhich are not regarded as \"transfer\" for the purpose of chargeability of capital\ngains. Adverting specifically to clause

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

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

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

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

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

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

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

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

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

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

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

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

156 taxman 206 (Kerala) even went to the extent so long as the AO has independently applied his mind to all the relevant aspect and has arrived to a belief the reopening cannot be said to be invalid. ITA Nos.2578 to 2580/chny/2017 :- 25 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells 5.3. We are aware that “mere change of opinion” cannot form

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

156 taxman 206 (Kerala) even went to the extent so long as the AO has independently applied his mind to all the relevant aspect and has arrived to a belief the reopening cannot be said to be invalid. ITA Nos.2578 to 2580/chny/2017 :- 25 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells 5.3. We are aware that “mere change of opinion” cannot form

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

156 taxman 206 (Kerala) even went to the extent so long as the AO has independently applied his mind to all the relevant aspect and has arrived to a belief the reopening cannot be said to be invalid. ITA Nos.2578 to 2580/chny/2017 :- 25 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells 5.3. We are aware that “mere change of opinion” cannot form

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

SANGUINE MEDIA LIMITED,CHENNAI vs. ITO,NCW-20(5), CHENNAI

In the result, the appeal stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

section 68 of the income tax act to the returned income of the appellant company despite the undisputed finding that the assessee company was merely a conduit company operated and maintained for providing accommodation entries. 7. That the Ld. AO as well as Ld. CIT(A) grossly erred in law and to the facts of the case by passing

M.MALARVIZHI,CHENNAI vs. ITO NON CORPORATE WARD 8(5), CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.779/Chny/2019 िनधा"रण वष"/Assessment Year:2013-14 Smt. M. Malarvizhi, The Income Tax Officer, 18, Mettu Theru, Vs. Non Corporate Ward 8(5), Kumananchavadi, Chennai 600 034. Chennai 600 056. [Pan:Apjpm2455H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Pranay J. Shah, C.A ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 04.07.2019 घोषणा की तारीख /Date Of Pronouncement : 19.07.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai Dated 30.01.2019 Relevant To The Assessment Year 2013-14. The Grounds Raised By The Assessee In The Grounds Of Appeal Are Reproduced As Under: “1. For That The Order Of The Learned Commissioner Of Income Tax (Appeals) - 9, Chennai U/S.271(1)(C) Of The Income Tax Act, 1961Is Opposed To Law, Facts & Circumstances Of The Case. 2. For That The Learned Commissioner Of Income Tax (Appeals) Erred In Passing The Order Dismissing The Appeal Filed By The Appellant Herein Without Noting That The Notice Issued By The 2

68,03,570/- was raised. Accordingly demand notice under section 156 penalty show cause notice under section 274 r.w.s.271

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

68,750 Investments in M/s. Natchiyar Industrial Makes. 27,362 Salary and interest from M/s. Natchiyar Industrial Makes. 5. Aggrieved, assessees moved in appeals before the ld. Commissioner of Income Tax (Appeals). Apart from challenging the merits of the additions, assessees also challenged the validity of the reopening. As per assessees, there was no material gathered at the ITA Nos.1218

PRAKASH,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

68,750 Investments in M/s. Natchiyar Industrial Makes. 27,362 Salary and interest from M/s. Natchiyar Industrial Makes. 5. Aggrieved, assessees moved in appeals before the ld. Commissioner of Income Tax (Appeals). Apart from challenging the merits of the additions, assessees also challenged the validity of the reopening. As per assessees, there was no material gathered at the ITA Nos.1218

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

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

Bench: Shri Abraham P. George]

68,750 Investments in M/s. Natchiyar Industrial Makes. 27,362 Salary and interest from M/s. Natchiyar Industrial Makes. 5. Aggrieved, assessees moved in appeals before the ld. Commissioner of Income Tax (Appeals). Apart from challenging the merits of the additions, assessees also challenged the validity of the reopening. As per assessees, there was no material gathered at the ITA Nos.1218

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

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

Bench: Shri Abraham P. George]

68,750 Investments in M/s. Natchiyar Industrial Makes. 27,362 Salary and interest from M/s. Natchiyar Industrial Makes. 5. Aggrieved, assessees moved in appeals before the ld. Commissioner of Income Tax (Appeals). Apart from challenging the merits of the additions, assessees also challenged the validity of the reopening. As per assessees, there was no material gathered at the ITA Nos.1218

S.DEVENDRAN,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

68,750 Investments in M/s. Natchiyar Industrial Makes. 27,362 Salary and interest from M/s. Natchiyar Industrial Makes. 5. Aggrieved, assessees moved in appeals before the ld. Commissioner of Income Tax (Appeals). Apart from challenging the merits of the additions, assessees also challenged the validity of the reopening. As per assessees, there was no material gathered at the ITA Nos.1218

PRAKASH,TRICHY vs. ITO, TRICHY

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

Bench: Shri Abraham P. George]

68,750 Investments in M/s. Natchiyar Industrial Makes. 27,362 Salary and interest from M/s. Natchiyar Industrial Makes. 5. Aggrieved, assessees moved in appeals before the ld. Commissioner of Income Tax (Appeals). Apart from challenging the merits of the additions, assessees also challenged the validity of the reopening. As per assessees, there was no material gathered at the ITA Nos.1218