INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

4). It was further contended that the seized electronic records lacked evidentiary value, as they did not comply with the mandatory requirements of section 65B of the Evidence Act, 1872. 57. The ld. CIT(A), after considering all the grounds raised, adjudicated the appeal by specifically addressing each of the additions made in the assessment order, in the manner

S.MAHIMA,CHENNAI vs. ACIT BUSINESS CIRCLE IV, CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No.1347/Chny/2019 िनधा"रण वष"/Assessment Year:2010-11 Smt. S. Mahima, The Assistant Commissioner Of Vs. No. 18/32, Dr. Ambedkar Road, Income Tax, Business Circle Iv, Kodambakkam, Chennai 600 024. Chennai. [Pan: Akkpm9079R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 03.12.2020 घोषणा की तारीख /Date Of Pronouncement : 16.02.2021 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) 7, Chennai Dated 31.03.2019 Relevant To The Assessment Year 2010-11. In The Grounds Of Appeal, The Assessee Has Challenged The Confirmation Of Addition Made Under Section 68 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Confirmation Of Disallowance Of Sales Promotion Expenses.

section 68 of the Act. In view of the above, the Assessing Officer is directed to verify as to whether the above credit entry appearing in the books of account of the assessee for the relevant previous year or preceding previous years and decide the issue in accordance with law after affording an opportunity of being heard

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, 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

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

68.\n7.5.12 The appellant further stated that the AO made the addition of the share premium u/s 56(1) on the reason that that the share premium of Rs.240 was huge and inflated. In other words, the AO has concluded that the fair value of the share was only Rs.10 without any valuation by him and that he has come

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

4.—For the removal of doubts, it is hereby clarified that the provisions of this section, as amended by the Finance Act, 2012, shall also be applicable for any assessment year beginning on or before the 1st day of April, 2012.” 5.2. If the aforesaid provision of the Act is analyzed, we find that after insertion of Explanation

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

4.—For the removal of doubts, it is hereby clarified that the provisions of this section, as amended by the Finance Act, 2012, shall also be applicable for any assessment year beginning on or before the 1st day of April, 2012.” 5.2. If the aforesaid provision of the Act is analyzed, we find that after insertion of Explanation

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

4.—For the removal of doubts, it is hereby clarified that the provisions of this section, as amended by the Finance Act, 2012, shall also be applicable for any assessment year beginning on or before the 1st day of April, 2012.” 5.2. If the aforesaid provision of the Act is analyzed, we find that after insertion of Explanation

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

68.\n7.5.12 The appellant further stated that the AO made the\naddition of the share premium u/s 56(1) on the reason\nthat that the share premium of Rs.240 was huge and\ninflated. In other words, the AO has concluded that the fair\nvalue of the share was only Rs.10 without any valuation by\nhim and that he has come

KAMLESH SHANTILAL JAIN,CHENNAI vs. ACIT, CHENNAI

In the result, appeal filed by assessee is allowed

Bench: Shri V.Durga Rao & Shri G.Manjunatha

4. The teamed CIT (Appeals) failed to note that the satisfaction of escapement of income was by the DIT (Investigation) only and not by the Assessing Officer himself and therefore it amounted to borrowed satisfaction. 5. The learned CIT (Appeals) failed to note that the sanction granted by the Joint Commissioner of Income tax was a mechanical one without reference

DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. PINNATHEVAR PALANICHAMY, MADURAI

In the result, appeal filed by the Revenue and Cross-Objection filed\nby the assessee are dismissed

249 cents on 22.01.2021 to Shri R. Sabapathy for\na sale consideration of Rs.49,70,04,000/- (approximately Rs.50 crores),\nwhich in its entirety was paid by him by way of Demand Drafts (details\ngiven in sale-deed) and that no portion was paid in cash, and that the\nentire sale consideration formed part of their books of accounts.\nThe

KRISHNAMURTHY PANDY,THANJAVUR vs. ITO, WARD-1,, THANJAVUR

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

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

4. Aggrieved by the above order of the ld.CIT(A), the assessee has preferred the present appeal. 5. The assessee is an FMCG distributor supplying to petty kirana stores in tier II towns having turnover of Rs.3.13 crore. During the period between 09.11.2016 to 30.12.2016, total deposits stood at Rs.38,19,900/- was made. From the said total deposit

HYUNDAI TRANSYS INC,REPUBLIC OF KOREA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.338/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Hyundai Transys Inc, Vs. The Deputy Commissioner Of 105, Sindang Income Tax, 1 Ro Seongyeon, International Tax, Myeon, Corporate Circle 1(1) Seosan, Ccn 356851 Chennai. Korea.

249 is less than the threshold limit of INR 5,000,000 prescribed under section 149(1)(b) of the Income-tax Act, 1961 ('the Act') as amended vide Finance Act, 2021, read with CBDT Instruction No. 01/2022 and as a result the case cannot be subjected to reassessment proceedings and such proceedings conducted

SRI SOWBAGYA FINANCIERS,KARUR vs. ITO, WARD-1, , KARUR

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.1723/Chny/2024 निर्धारण वर्ा /Assessment Years: 2018-19 Sri Sowbagya Financiers, Income Tax Officer, No.28/9-1, Ramakrishnapuram, Ward-1 Kaspa, Karur Town, Karur Karur-639001. [Pan: Abgfs4214D]

section 68 can only be invoked with reference to fresh / new loans acquired during the year and not the loans taken on earlier years. 10. Be that as it may be, we are of the view that the matter concerning unsecured loans claimed to have been received by the assessee have not been objectively and comprehensively analyzed

ARUSUVAI FOOD PROCESSORS PVT. LTD.,SALEM vs. DCIT, CIRCLE-1(1), SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

249 (SC), though passed in the context of levy of penalty u/s.271(1)(c) of the Act. But the requirement of law as given in section 271(1) & 270A(1) of the Act is noted to be pari-materia. As far as Section 271(1) is concerned, the AO to record ‘satisfaction’ to levy penalty whereas in section

TIRUPUR ARUNACHALA GOUNDER RADHAMBIKAI KUPPUSAMY,TIRUPUR vs. CIT(A), NFAC, DELHI

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

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.363/Chny/2024 (िनधा"रणवष" / Assessment Year: 2018-19) T A G Radhambikai Kuppusamy, Vs. The Income Tax Officer, No.5, Mp Nagar Extension, Che –C (68) (1) Suriya Prabha Garden, Chennai. Tirupur 641 607

68) (1) Suriya Prabha Garden, Chennai. Tirupur 641 607 [PAN: ADOPR 3346P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Shri. S. Ramachandran, C.A., ""यथ" क" ओर से /Respondent by : Shri. ARV Srinivasan, Addl. CIT. सुनवाई क" तार"ख/Date of Hearing : 02.05.2024 घोषणा क" तार"ख /Date of Pronouncement : 06.05.2024 आदेश / O R D E R MANU