GS & SD ASSOCIATES,CHENNAI vs. ITO, NCW-8(2), CHENNAI

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

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2767/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Gs & Sd Associates, Vs. The Income Tax Officer, No. 03, Vania Street, Kundrathur, Non Corporate Ward 8(2), Chennai 600 069. Chennai. [Pan:Aaqfg8838C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, Ca ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 08.01.2026 घोषणा की तारीख /Date Of Pronouncement 26.02.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 22.08.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2017-18. 2. The Assessee Raised 6 Grounds Amongst Which The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Addition Made By The Assessing Officer Under Section 68 Of The Income Tax Act , 1961 [“Act” In Short].

section 68 of the Act. He placed on record copy of the assessment order dated 28.02.2023 in the case of Govinda Rajulu Srinivasan in support his contention that the same amount was also assessed in the hands of the partner of the assessee. Further, he argued that the ld. CIT(A) failed to appreciate that when the partner

M/S. GLOBAL KNITTING NEEDS (FIRM),,CHENNAI vs. ITO, NCW-22(1),, CHENNAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.403 & 404/Chny/2020 िनधा"रण वष"/Assessment Year: 2012-13 M/S. Global Knitting Needs (Firm), Vs. The Income Tax Officer, Block No. C-1, 4Th Floor, D. No. 402, Non Corporate Ward 22(1), Akshya Belvedre Apartments, Gst Chennai. Road, Nandivaram Village, Guduvancherry, Chennai 603 202. [Pan:Aahfg6848D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.S. Lakshmi Venkataraman, Ca ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.04.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals)-10, Chennai Dated 26.11.2019 Towards Quantum & The Order Dated 14.01.2020 Against Levy Of Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2012-13. The Assessee Has Challenged Confirmation Of Addition Of ₹.69,72,900/-

68 of the Act as well as addition of ₹.32,03,000/- under section 69 of the Act. 2. Brief facts of the case are that the assessee filed the return of income for the assessment year 2012-13 on 29.09.2012 declaring total income of ₹.1,66,160

M/S. GLOBAL KNITTING NEEDS (FIRM),,CHENNAI vs. ITO, NCW-22(1),, CHENNAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.403 & 404/Chny/2020 िनधा"रण वष"/Assessment Year: 2012-13 M/S. Global Knitting Needs (Firm), Vs. The Income Tax Officer, Block No. C-1, 4Th Floor, D. No. 402, Non Corporate Ward 22(1), Akshya Belvedre Apartments, Gst Chennai. Road, Nandivaram Village, Guduvancherry, Chennai 603 202. [Pan:Aahfg6848D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.S. Lakshmi Venkataraman, Ca ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.04.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals)-10, Chennai Dated 26.11.2019 Towards Quantum & The Order Dated 14.01.2020 Against Levy Of Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2012-13. The Assessee Has Challenged Confirmation Of Addition Of ₹.69,72,900/-

68 of the Act as well as addition of ₹.32,03,000/- under section 69 of the Act. 2. Brief facts of the case are that the assessee filed the return of income for the assessment year 2012-13 on 29.09.2012 declaring total income of ₹.1,66,160

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

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 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

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

DCIT , CHENNAI vs. M/S ADITYA TRADING SOLUTIONS PRIVATE LIMITED , CHENNAI

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपीलसं./Ita No.: 843/Chny/2022 & Co No.: 17/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Deputy Commissioner Of M/S. Aditya Trading Solutions Income Tax, V. Private Limited, Central Circle-3(1), 25 G9, Gems Court, Chennai – 34. Khader Nawaz Khan Road, Nungambakkam, Chennai – 600 034. [Pan: Aafca-0343-N] (अपीलाथ"/Appellant) (Respondent/Cross Objector) अपीलाथ" क" ओर से/Appellant By : Shri. V. Nandakumar, Cit : Shri. I. Dinesh, Advocate ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 28.02.2024 घोषणा क" तारीख/Date Of Pronouncement : 27.03.2024

section 68 of the IT Act cannot be applied to the assessment year 2012-13, without appreciating the ratio laid down by the Hon'ble Apex Court in the case of CIT v. Shri. Biju Patnaik, reported in 160

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

160 is liable as representative assessee or any part thereof ITA Nos.1345 & 1401/Mds/2016 & ITA Nos.1902, 981 & 982/Mds/2016 :- 24 -: (i) is not specifically receivable on behalf or for the benefit of any one person; or (ii) where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

160 is liable as representative assessee or any part thereof ITA Nos.1345 & 1401/Mds/2016 & ITA Nos.1902, 981 & 982/Mds/2016 :- 24 -: (i) is not specifically receivable on behalf or for the benefit of any one person; or (ii) where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate

ITO, CHENNAI vs. TVS SHRIRAM GRWOTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

160 is liable as representative assessee or any part thereof ITA Nos.1345 & 1401/Mds/2016 & ITA Nos.1902, 981 & 982/Mds/2016 :- 24 -: (i) is not specifically receivable on behalf or for the benefit of any one person; or (ii) where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

160 is liable as representative assessee or any part thereof ITA Nos.1345 & 1401/Mds/2016 & ITA Nos.1902, 981 & 982/Mds/2016 :- 24 -: (i) is not specifically receivable on behalf or for the benefit of any one person; or (ii) where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate

ITO, CHENNAI vs. TVS SHRIRAM GROWTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

160 is liable as representative assessee or any part thereof ITA Nos.1345 & 1401/Mds/2016 & ITA Nos.1902, 981 & 982/Mds/2016 :- 24 -: (i) is not specifically receivable on behalf or for the benefit of any one person; or (ii) where the individual shares of the persons on whose behalf or for whose benefit such income or such part thereof is receivable are indeterminate

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

SHI vs. U CANADIAN CLEAR WATERS LTD.,CHENNAIVS.ITO CORPORATE CIRCLE 6(2), CHENNAI

In the result the assessee’s appeal is treated as partly

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

section applies only to a case where “an allowance or deduction is allowed in a particular year and subsequently __ ". b. If the addition is vs Sec 68, the addition cannot be sustained U/ s.68 with regard to opening balance as at beginning of the year i.e., 1.4.2013. This proposition is supported by the Rajasthan High Court decision

ASIRVAD MICRO FINANCE LIMITED,ANNA SALAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1141/Chny/2025 Assessment Years: 2017-18 Asirvad Micro Finance Limited, Deputy Commissioner Of Income No.9 Ninth Floor, Club House Road, Tax, Anna Salai, Corporate Circle-1(1), Chennai- 600 002. Chennai. [Pan: Aagca5275J] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri P.R.Prasanna Varma, F.C.A & Mr.Arjun Rajagopalan, C.A, प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख /Date Of Pronouncement : 25.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

160/- along with book profit under section 115B of Rs. 51,12,21,007/- was filed on 31.10.2017. The Ld.AO noted that the assessee had through its securitization activity earned interest on loan (Microfinance) of Rs.334,37,28,960/-. From the impugned amount the assessee was found to have reduced an amount of Rs.28

(LATE) VIJAYARAJ JAIN (REP BY WIFE AND ONE OF LH V.LEELAVATHI),SALEM vs. ITO, SALEM

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

Bench: Shri N.R.S. Ganesanआयकर अपील सं./Ita No.474/Mds/2015 "नधा"रण वष" / Assessment Year : 2007-08

Section 68 of the Act. The assessee had offered `4,49,160/- as income and credited to Profit & Loss

SARANGABANI KIRUBAKARAN,CHENNAI vs. DCIT, CIRCLE-1(2), CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1237/Chny/2023 (िनधा)रण वष) / Assessment Year: 2014-15) Shri Sarangabani Kirubakaran Dcit बनाम/ 17/6, First Pillayar Koil Street, Circle-1(2) Vs. Ekkatuthangal, Chennai-600 032. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Bumpk-0892-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. T.V. Muthu Abirami (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 25-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 04-09-2024 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2014-15 Arises Out Of The Common Order Of Learned Commissioner Of Income Tax (Appeals)-18, Chennai, [Cit(A)] Dated 13-09-2023 In The Matter Of An Assessment Framed By The Ld. Ao U/S.153C R.W.S. 144 Of The Act On 31- 03-2022. The Grievance Of The Assessee Is Confirmation Of Addition U/S 69 For Rs.8.04 Lacs & Rs.5 Lacs. The Assessee Is Also Aggrieved By Computation Of Long-Term Capital Gains (Ltcg) Of Rs.157.45 Lacs. 2. The Ld Ar Advanced Arguments On Merits As Well As On Legal Grounds & Also Raised Additional Grounds Of Appeal. The Ld. Cit-Dr

Section rather it is a case of receipt of credit in the bank accounts and Ld. AO has gone wrong in appreciating the correct facts. 8. The decision of Hon’ble High Court of Jharkhand in Rajmeet Singh (160 Taxmann.com 83) is a case where the assessee deposited cash in the bank account which was added u/s 68