ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

Section 147 will come into play and only tangible material is required to reopen the concluded assessment and there is no requirement of having fresh material to reopen concluded assessment. It was submitted that if audit objections is based on factual errors, then it can be a valid ground for reopening of the concluded assessment

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

Section 147 will come into play and only tangible material is required to reopen the concluded assessment and there is no requirement of having fresh material to reopen concluded assessment. It was submitted that if audit objections is based on factual errors, then it can be a valid ground for reopening of the concluded assessment

SRINIVASAN MOHAMMAD IIBRAHIM,MADURAI vs. THE INCOME TAX OFFICER, NON CORPORATE WARD-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 under section 147 read with section 144B of the Act by disallowing 5% of total cash deposits of ₹.3

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 under section 147 read with section 144B of the Act by disallowing 5% of total cash deposits of ₹.3

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

3.—For the purpose of assessment or reassessment under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included

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

3.—For the purpose of assessment or reassessment under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included

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

3.—For the purpose of assessment or reassessment under this section, the Assessing Officer may assess or reassess the income in respect of any issue, which has escaped assessment, and such issue comes to his notice subsequently in the course of the proceedings under this section, notwithstanding that the reasons for such issue have not been included

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

156 TTJ 777 (Panaji - Trib) submitted that\nwhere, assee, a proprietary concern, had transferred all his assets and\nliabilities to a company and against consideration, he was allotted shares of the\ncompany, even though value of those shares was much more than value of\nassets disclosed in books of proprietary concern, provisions of section 47(xiv)\nwould apply

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)

3 Pg. no. 156 & 157 Ltd. taxmann.com 136 • Although the above rulings were rendered in the context of Section 14A, the principles establish shall squarely apply to the instant, case and accordingly, there shall be a presumption that the non-interest bearing equity funds were utilized for the payment of buyback consideration and hence, Section

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)

3 Pg. no. 156 & 157 Ltd. taxmann.com 136 • Although the above rulings were rendered in the context of Section 14A, the principles establish shall squarely apply to the instant, case and accordingly, there shall be a presumption that the non-interest bearing equity funds were utilized for the payment of buyback consideration and hence, Section

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

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

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

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

JAGATHESH,CHENNAI vs. AACIT, NCC-11(1), CHENNAI

In the result the appeal of the assessee in ITA No

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1565/Chny/2025 ननिाजरण वर्ज / Assessment Year: 2017-18 Jagathesh, Acit, Flat 2A, Block V, Vs. Non- Corporate Circle - 11(1), Rani Meyammai Towers, Chennai. Mrc Nagar, Raja Annamalai Puram, Chennai – 600 028. [Pan:Aclpj-4702-H] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.:1566/Chny/2025 ननिाजरण वर्ज / Assessment Year: 2017-18 Jagathesh, Acit, Flat 2A, Block V, Vs. Non- Corporate Circle - 11(1), Rani Meyammai Towers, Chennai. Mrc Nagar, Raja Annamalai Puram, Chennai – 600 028. [Pan:Aclpj-4702-H] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

68,69,000 8. 2015-16 70,00,000 9. 2016-17 75,00,000 Total 14,55,65,400 3. The assessee for all the years in aggregate made a declaration for a total undisclosed income of Rs.14,55,65,400/-. The said declaration in Form 1 came to be filed on 30.09.2016. The said declaration also showed that

JAGATHESH,CHENNAI vs. ACIT, NCC-1(1), CHENNAI

In the result the appeal of the assessee in ITA No

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.:1565/Chny/2025 ननिाजरण वर्ज / Assessment Year: 2017-18 Jagathesh, Acit, Flat 2A, Block V, Vs. Non- Corporate Circle - 11(1), Rani Meyammai Towers, Chennai. Mrc Nagar, Raja Annamalai Puram, Chennai – 600 028. [Pan:Aclpj-4702-H] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita No.:1566/Chny/2025 ननिाजरण वर्ज / Assessment Year: 2017-18 Jagathesh, Acit, Flat 2A, Block V, Vs. Non- Corporate Circle - 11(1), Rani Meyammai Towers, Chennai. Mrc Nagar, Raja Annamalai Puram, Chennai – 600 028. [Pan:Aclpj-4702-H] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

68,69,000 8. 2015-16 70,00,000 9. 2016-17 75,00,000 Total 14,55,65,400 3. The assessee for all the years in aggregate made a declaration for a total undisclosed income of Rs.14,55,65,400/-. The said declaration in Form 1 came to be filed on 30.09.2016. The said declaration also showed that

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

Section 143(3) of the Act\non 30.03.2024 for Assessment Year (AY) 2011-12, giving effect to the\nPage 5 of 10\nITA Nos.1519, 1520, 1521, 1522, 1523, 1524, 1525, 1526 & 1527/CHNY/2025\nAYs: 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2017-18, 2018-19 & 2021-22)\nM/s. Redington Distribution Pte Limited.\nMAP resolution

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

Section 143(3) of the Act\non 30.03.2024 for Assessment Year (AY) 2011-12, giving effect to the\nPage 5 of 10\nITA Nos.1519, 1520, 1521, 1522, 1523, 1524, 1525, 1526 & 1527/CHNY/2025\nAYs: 2011-12, 2012-13, 2013-14, 2014-15, 2015-16, 2016-17, 2017-18, 2018-19 & 2021-22)\nM/s. Redington Distribution Pte Limited.\nMAP resolution