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

section 139 has been filed after the date of search. Therefore, in the facts and circumstances of the case, these grounds of appeal have no merits." 7.2.6 Thus Hon'ble Delhi High Court has taken view that there is no bar in making regular additions while making assessment u/s 153A for those years where return has not been filed

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

193 of 2008 dated 25.7.2008 ITA Nos.2578 to 2580/chny/2017 :- 6 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells b) ACIT Vs A.F.Ferguuson & Co. in ITA No. 87 of 2011 dated 21.7.2011 6. We have heard the rival submissions and perused the materials available on record. The facts stated hereinabove remain undisputed and hence the same are not reiterated for the sake

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

193 of 2008 dated 25.7.2008 ITA Nos.2578 to 2580/chny/2017 :- 6 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells b) ACIT Vs A.F.Ferguuson & Co. in ITA No. 87 of 2011 dated 21.7.2011 6. We have heard the rival submissions and perused the materials available on record. The facts stated hereinabove remain undisputed and hence the same are not reiterated for the sake

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

193 of 2008 dated 25.7.2008 ITA Nos.2578 to 2580/chny/2017 :- 6 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells b) ACIT Vs A.F.Ferguuson & Co. in ITA No. 87 of 2011 dated 21.7.2011 6. We have heard the rival submissions and perused the materials available on record. The facts stated hereinabove remain undisputed and hence the same are not reiterated for the sake

K.THANIKACHALAM,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals of the assessee in ITA No

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकरअपीलसं./Ita Nos.2628 & 2629/Mds/2014 िनधा"रणवष" / Assessment Years : 2008-09&2010-11 Shri K. Thanikachalam, The Asstt. Commissioner Of C/O. S. Sridhar, V. Income Tax, Advocate, Business Circle - Ii, New No.14, Old No.82, Flat No.5, Chennai. 1St Avenue, Indira Nagar, Adyar, Chennai – 600 020. [Pan: Aaept 1404 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri S. Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Shri Shiva Srinivas, Jcit सुनवाईक"तारीख/Date Of Hearing : 12.01.2017 घोषणाक"तारीख/Date Of Pronouncement : 22.02.2017 आदेश आदेश /O R D E R आदेश आदेश Per D.S. Sunder Singh:

193 ITR 321 (SC) expressed view that Rule of consistency required to be followed in assessment proceedings. In the instant case, there was no dispute that the assessee has admitted the income as business income in the earlier years and the same was accepted by the department and there is no change in the facts in the year under consideration

K.THANIKACHALAM,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals of the assessee in ITA No

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकरअपीलसं./Ita Nos.2628 & 2629/Mds/2014 िनधा"रणवष" / Assessment Years : 2008-09&2010-11 Shri K. Thanikachalam, The Asstt. Commissioner Of C/O. S. Sridhar, V. Income Tax, Advocate, Business Circle - Ii, New No.14, Old No.82, Flat No.5, Chennai. 1St Avenue, Indira Nagar, Adyar, Chennai – 600 020. [Pan: Aaept 1404 B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri S. Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Shri Shiva Srinivas, Jcit सुनवाईक"तारीख/Date Of Hearing : 12.01.2017 घोषणाक"तारीख/Date Of Pronouncement : 22.02.2017 आदेश आदेश /O R D E R आदेश आदेश Per D.S. Sunder Singh:

193 ITR 321 (SC) expressed view that Rule of consistency required to be followed in assessment proceedings. In the instant case, there was no dispute that the assessee has admitted the income as business income in the earlier years and the same was accepted by the department and there is no change in the facts in the year under consideration

MANOJ KUMAR DUGAR,ERODE vs. ITO, WARD-1(1), ERODE

In the result, the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Jagadish

section 68 of the Income Tax Act 1961. The ld. CIT(A) dismissed the appeal of the assessee on legal issue as well as on merits of addition. 3. The assessee has raised, inter alia, the following grounds:  That the learned CIT(A) has erred in upholding the validity of reopening u/s 147 of the Act.  That

ACIT , CENTRAL CIRCLE-1, TRICHY vs. M/S SARATHA'S , TRICHY

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Manjunatha. G & Shri Manomohan Das

section 115BBE of the Act. The AO observed that the said amount actually represents the ‘excess stock’ found during the survey (Rs.53,09,68,719/- less ‘obsolete stock’ of Rs.3,48,71,193

DCIT, CIRCLE-2, TRICHY vs. M/S. MC HOSPITAL, NAGAPATTINAM

In the result, the appeal of the Revenue is dismissed as the Cross

Bench: Shri Mahavir Singh & Shri Girish Agrawalassessment Year: 2017-18 Deputy Commissioner Of M/S. M. C. Hospital Income-Tax, Plot No. 38, Sivan Sannathi Circle-2, Trichy. Street, Velipalayam, O/O The Joint Nagapattinam, Vs. Commissioner Of Income Tamil Nadu-611001. Tax, Range-2, No. 100, (Pan: Aapfm2058R) Nanjikottai Road, Thanjavur, Tamil Nadu- 620001. (Appellant) (Respondent) & C.O. No. 6/Chny/2022 In Ita No.11/Chny/2021 Assessment Year: 2017-18 M/S. M. C. Hospital Deputy Commissioner Of Plot No. 38, Sivan Sannathi Income-Tax, Street, Velipalayam, Circle-2, Trichy. Nagapattinam, Vs. O/O The Joint Commissioner Tamil Nadu-611001. Of Income Tax, Range-2, No. (Pan: Aapfm2058R) 100, Nanjikottai Road, Thanjavur, Tamil Nadu- 620001. (Cross Objector) (Respondent) Present For: Revenue/Appellant By : Shri Chinthapalli Mehar Chand, Jcit Assessee/Cross Objector By : Shri K. P. Dewani, Advocate Date Of Hearing : 24.05.2022 Date Of Pronouncement : 19.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Revenue & The Cross Objection By The Assessee Are Directed Against The Order Of Ld. Cit(A)-1, Trichy Vide Ita No.535/2019-20/Cit(A0-1/Try Dated 23.09.2020 Against The Assessment Order Passed By Acit, Circle-2(1), Trichy U/S. 143(3) Of The 2

193 to 195. For the assessment order of AY 2016- 17, reason for its selection for scrutiny assessment u/s. 143(3) of the Act was “large difference in cash in hand shown in Balance sheet as per return of income and revised return of income (part A-BS of the return) & revised return filed after 07.11.2016 and cash deposit reported

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MRF LIMITED, CHENNAI

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

68,88,613/-]. The assessee urged before the Ld.CIT(A) that the AO couldn’t have tinkered with the approval given by the prescribed authority as per the Act, which is the prescribed expert body i.e. DSIR; and couldn’t have disallowed weighted deduction as approved by it (DSIR) in Form No.3CL. The assessee also brought to the notice

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MRF LIMITED, CHENNAI

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

68,88,613/-]. The assessee urged before the Ld.CIT(A) that the AO couldn’t have tinkered with the approval given by the prescribed authority as per the Act, which is the prescribed expert body i.e. DSIR; and couldn’t have disallowed weighted deduction as approved by it (DSIR) in Form No.3CL. The assessee also brought to the notice

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

193,27,18,841/- under the provisions of Section 115JB of the Act. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax, Central Circle Salem (hereinafter called as ‘’Assessing Officer’’) vide order dated 29.12.2016 passed u/s. 143(3) of the Income Tax Act, 1961 (for short ITA Nos.2280-83 /2018

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

193,27,18,841/- under the provisions of Section 115JB of the Act. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax, Central Circle Salem (hereinafter called as ‘’Assessing Officer’’) vide order dated 29.12.2016 passed u/s. 143(3) of the Income Tax Act, 1961 (for short ITA Nos.2280-83 /2018

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

193,27,18,841/- under the provisions of Section 115JB of the Act. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax, Central Circle Salem (hereinafter called as ‘’Assessing Officer’’) vide order dated 29.12.2016 passed u/s. 143(3) of the Income Tax Act, 1961 (for short ITA Nos.2280-83 /2018

ACIT CENTRAL CIRCLE, SALEM vs. THRIVENI EARTHMOVERS PVT. LTD., SALEM

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy] आयकर अपील सं./I.T.A. Nos. 2280, 2281, 2282 & 2283/Chny/2018 "नधा"रण वष" /Assessment Years :2011-12, 2012-13, 2013-14 & 2014-15 The Assistant Commissioner Vs. M/S. Thriveni Earthmovers Pvt Ltd, Of Income Tax, 22/110, Greenways Road, Central Circle, Fairlands, Salem Salem 636 016. [Pan Aabct 6759R] (अपीलाथ"/Appellant) (""यथ"/Respondent)

193,27,18,841/- under the provisions of Section 115JB of the Act. Against the said return of income, the assessment was completed by the Assistant Commissioner of Income Tax, Central Circle Salem (hereinafter called as ‘’Assessing Officer’’) vide order dated 29.12.2016 passed u/s. 143(3) of the Income Tax Act, 1961 (for short ITA Nos.2280-83 /2018

ACIT NON CORPORATE CIRCLE 10(1), CHENNAI vs. S.VINODH KUMAR, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.2527/Chny/2017 & C.O.No.9/Chny/2018 (Ita No.2527/Chny/2017) "नधा"रण वष" /Assessment Year : 2011-2012. The Assistant Commissioner Of Vs. Shri. S. Vinodh Kumar, Income Tax, No.25, Ranganathan Avenue, Non Corporate Circle 10 (1) Kilpauk, Chennai. Chennai 600 010. [Pan Aaipv 5798G] (अपीलाथ"/Appellant) (Respondent/Cross Objector)

193 PPF Interest 1,99,853 Salary received 3,96,00,000 Profit on sale of shares – LTCG 69,900 Profit on sale of shares foreign company 1,18,259 Miscellaneous Income 1,670 Dividend received. 7,07,421 In our opinion non charging of interest from few persons to whom assessee had advanced loans would not be a sufficient

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 2(42C) of the Act. We further observe that, the transaction involving the sale of windmill undertaking was carried out with a related concern for which an independent valuation report was obtained and the price agreed between the parties at Rs.93 crores was higher than the value determined by the independent valuer. It is noticed that

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section 199 of the IT Act which provides that credit for tax deduction at source shall be allowed only in the year in which the corresponding income is declared. Thus, it is clarified that the tax is required to be deducted at source u/s 193 or 195, as the case may be only at the time of redemption

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section 199 of the IT Act which provides that credit for tax deduction at source shall be allowed only in the year in which the corresponding income is declared. Thus, it is clarified that the tax is required to be deducted at source u/s 193 or 195, as the case may be only at the time of redemption