ACIT, CHENNAI vs. SRI BALAJI EDUCATIONAL AMD TRUST CHARITABLE PUBLIC TRUST , CHENNA

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

transfer or receive any Specified Bank Notes. From the above what is clear is that up to the appointed date Le 31.12.2016, there is no prohibition for dealing with Specified Bank Notes. Therefore, in my considered view, the objection of the AO on this regard in light of said Act is devoid of merits. Further, a similar issue had been

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. MS DAR PARADISE PVT. LTD., COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1106/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Dar Paradise Pvt. Ltd., Income Tax, V. 599, Raja Street, Corporate Circle -1, Coimbatore – 641 001. Coimbatore. [Pan: Aafcd-3066-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri. N. Arjun Raj, Ca सुनवाई क" तारीख/Date Of Hearing : 05.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 21.03.2024

cash deposits u/s.68 of the Act. The relevant findings of the ld.CIT(A) are as under: 6.4 After going through the specific findings of the AO in the assessment order, remand report and appellant's submissions, following conclusions can be derived: 6.5 During the appellate proceedings, the appellant has submitted that appellant had received advance against gold product. The gold

PURANI HOSPITAL SUPPLIES PRIVATE LIMITED,COIMBATORE vs. DCIT CORPORATE CIRCLE-2, COIMBATORE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 489/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

price', is ab-initio void as per the provisions of Sec.23 of the Contracts Act, 1872 and thus non- est in the eves of law. Hence, such SBNs cannot be treated as having arisen out of a contract for sale. Hence the sum of cash deposit to an amount of Rs.1,82,37,000/- (Rs.1,82,57,000- Rs.20

GANAPATHY CHANDRASEKARAN,ERODE vs. DCIT, CIRCLE-1, ERODE

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

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 776/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income Ganapathy Chandrasekaran, V. Tax, 93, Erode Main Road, Circle -1, Ganapathypalayam, Erode. Erode – 638 153. [Pan: Abrpc-3073-D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. S. Sridhar, Advocate (Erode) ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 20.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 28.06.2024 आदेश /O R D E R Per S. R. Raghunatha:

transferring or receiving SBNs is only after the 'appointed day' which is 31.12.2016. In view of the above, there is no violation by the assessee of any law in accepting SBNs for the purpose of cash sales and considering it to be a due discharge of debt. Furthermore, even the CBDT had issued various Standard Operating Procedures (SOPs) instructing

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

transfers\nmoney from T.Nagar account and withdraws the same at Cumbum,\nand vice versa. In this scenario, there is no question of verifying\nprior withdrawal in the same bank account. Hence, the AO ought to\nhave considered the deposit and withdrawal of both the banks put\ntogether in addition to other inflows. Hence, the cash withdrawn\nought to be considered

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

transfers\nmoney from T.Nagar account and withdraws the same at Cumbum,\nand vice versa. In this scenario, there is no question of verifying\nprior withdrawal in the same bank account. Hence, the AO ought to\nhave considered the deposit and withdrawal of both the banks put\ntogether in addition to other inflows. Hence, the cash withdrawn\nought to be considered

NEELARAJ VINOTH,PERAMBALUR vs. ACIT, CC-2, , TRICHY

In the result, the appeal of the revenue is dismissed and the CO filed by the assessee is dismissed

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1982/Chny/2024 & C.O.No. 60/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Assistant Commissioner Of Neelaraj Vinoth, Income Tax, V. 274-C, Thuraiyur Road, Central Circle -2, Perambalur – 621 212, Trichy. Tamilnadu. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (Respondent/Cross Objector) आयकर अपील सं./Ita No.: 2119/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Neelaraj Vinoth, Assistant Commissioner Of 274-C, Thuraiyur Road, V. Income Tax, Perambalur – 621 212, Central Circle -2, Tamilnadu. Trichy. [Pan: Ajupv-3588-M] (अपीलाथ"/Appellant) (""यथ"/Respondent)

cash deposits or transfers into the creditors' bank accounts. This is only post search enquiry and not something found at the time of search. It is not as if the ROI was not filed. In fact, 3 ROIs were filed. At best proceedings u/s.148 of the Act could have been resorted to but not an assessment u/s. 153C

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2), , CHENNAI

In the result the appeal of the assessee is partly allowed

transfers\nmoney from T.Nagar account and withdraws the same at Cumbum,\nand vice versa. In this scenario, there is no question of verifying\nprior withdrawal in the same bank account. Hence, the AO ought to\nhave considered the deposit and withdrawal of both the banks put\ntogether in addition to other inflows. Hence, the cash withdrawn\nought to be considered

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. NEELARAJ VINOTH, PERAMBALUR

In the result, the appeal of the assessee is dismissed

transfers from the creditors' bank accounts\nto the assessee's bank accounts were preceded by cash deposits or\ntransfers into the creditors' bank accounts. This is only post search\nenquiry and not something found at the time of search. It is not as\nif the ROI was not filed. In fact, 3 ROIs were filed. At best\nproceedings u/s.148

M/S TAMILNADU STATE MARKETING CORPORATION LIMITED,CHENNAI vs. ACIT, CORPORATE CIRCLE-3(1), CHENNAI

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

transfer (give) and the other party to receive SBNs in the\ncourse of a legal transaction prior to 31.12.2016. On receipt, the\nrecipient bears the risk of realizing the value of SBNs received as\nsale consideration. TASMAC received SBNs in the course of sale of\nliquor prior to 31.12.2016 and such transaction of receiving SBNs\nprior

SHRI RAJU P. MEHTA,,CHENNAI vs. DCIT, CENTRAL CIRCLE - II (1),, CHENNAI

In the result, appeals filed by assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G.Manjunathaआयकरअपीलसं./I.T.A Nos. 168 To 173/Chny/2020 ("नधा"रणवष" / Assessment Years: 1999-2000, 2001-02, 2002-03, 2003-04, 2004-05 & 2005-06) Mr. Raju P.Mehta, Vs The Deputy Commissioner Of 40, Barnaby Road, Income Tax, Kilpauk, Central Circle Ii(1), Chennai-600 010. Chennai-600 034. Pan : Aafpm 1912N (अपीलाथ"/Appellant) ""यथ"/Respondent/

price) - 2,24.76.420 Less: GP at the rate of 5% as staled - - 11,23,821 Closing stock including accounted stock 2,13,52,599 Opening stock as per accounts 37,22,888 Add: Purchase accounted 16,39,659 53,62,541 Less: cost of goods sold : Sales as per book: 24,08,964 Less

SHRI RAJU P. MEHTA,,CHENNAI vs. DCIT, CENTRAL CIRCLE - II (1),, CHENNAI

In the result, appeals filed by assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G.Manjunathaआयकरअपीलसं./I.T.A Nos. 168 To 173/Chny/2020 ("नधा"रणवष" / Assessment Years: 1999-2000, 2001-02, 2002-03, 2003-04, 2004-05 & 2005-06) Mr. Raju P.Mehta, Vs The Deputy Commissioner Of 40, Barnaby Road, Income Tax, Kilpauk, Central Circle Ii(1), Chennai-600 010. Chennai-600 034. Pan : Aafpm 1912N (अपीलाथ"/Appellant) ""यथ"/Respondent/

price) - 2,24.76.420 Less: GP at the rate of 5% as staled - - 11,23,821 Closing stock including accounted stock 2,13,52,599 Opening stock as per accounts 37,22,888 Add: Purchase accounted 16,39,659 53,62,541 Less: cost of goods sold : Sales as per book: 24,08,964 Less

SHRI RAJU P. MEHTA,,CHENNAI vs. DCIT, CENTRAL CIRCLE - II (1),, CHENNAI

In the result, appeals filed by assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G.Manjunathaआयकरअपीलसं./I.T.A Nos. 168 To 173/Chny/2020 ("नधा"रणवष" / Assessment Years: 1999-2000, 2001-02, 2002-03, 2003-04, 2004-05 & 2005-06) Mr. Raju P.Mehta, Vs The Deputy Commissioner Of 40, Barnaby Road, Income Tax, Kilpauk, Central Circle Ii(1), Chennai-600 010. Chennai-600 034. Pan : Aafpm 1912N (अपीलाथ"/Appellant) ""यथ"/Respondent/

price) - 2,24.76.420 Less: GP at the rate of 5% as staled - - 11,23,821 Closing stock including accounted stock 2,13,52,599 Opening stock as per accounts 37,22,888 Add: Purchase accounted 16,39,659 53,62,541 Less: cost of goods sold : Sales as per book: 24,08,964 Less

SHRI RAJU P. MEHTA,,CHENNAI vs. DCIT, CENTRAL CIRCLE - II (1),, CHENNAI

In the result, appeals filed by assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G.Manjunathaआयकरअपीलसं./I.T.A Nos. 168 To 173/Chny/2020 ("नधा"रणवष" / Assessment Years: 1999-2000, 2001-02, 2002-03, 2003-04, 2004-05 & 2005-06) Mr. Raju P.Mehta, Vs The Deputy Commissioner Of 40, Barnaby Road, Income Tax, Kilpauk, Central Circle Ii(1), Chennai-600 010. Chennai-600 034. Pan : Aafpm 1912N (अपीलाथ"/Appellant) ""यथ"/Respondent/

price) - 2,24.76.420 Less: GP at the rate of 5% as staled - - 11,23,821 Closing stock including accounted stock 2,13,52,599 Opening stock as per accounts 37,22,888 Add: Purchase accounted 16,39,659 53,62,541 Less: cost of goods sold : Sales as per book: 24,08,964 Less

SHRI RAJU P. MEHTA,,CHENNAI vs. DCIT, CENTRAL CIRCLE - II (1),, CHENNAI

In the result, appeals filed by assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G.Manjunathaआयकरअपीलसं./I.T.A Nos. 168 To 173/Chny/2020 ("नधा"रणवष" / Assessment Years: 1999-2000, 2001-02, 2002-03, 2003-04, 2004-05 & 2005-06) Mr. Raju P.Mehta, Vs The Deputy Commissioner Of 40, Barnaby Road, Income Tax, Kilpauk, Central Circle Ii(1), Chennai-600 010. Chennai-600 034. Pan : Aafpm 1912N (अपीलाथ"/Appellant) ""यथ"/Respondent/

price) - 2,24.76.420 Less: GP at the rate of 5% as staled - - 11,23,821 Closing stock including accounted stock 2,13,52,599 Opening stock as per accounts 37,22,888 Add: Purchase accounted 16,39,659 53,62,541 Less: cost of goods sold : Sales as per book: 24,08,964 Less

SHRI RAJU P. MEHTA,,CHENNAI vs. DCIT, CENTRAL CIRCLE - II (1),, CHENNAI

In the result, appeals filed by assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G.Manjunathaआयकरअपीलसं./I.T.A Nos. 168 To 173/Chny/2020 ("नधा"रणवष" / Assessment Years: 1999-2000, 2001-02, 2002-03, 2003-04, 2004-05 & 2005-06) Mr. Raju P.Mehta, Vs The Deputy Commissioner Of 40, Barnaby Road, Income Tax, Kilpauk, Central Circle Ii(1), Chennai-600 010. Chennai-600 034. Pan : Aafpm 1912N (अपीलाथ"/Appellant) ""यथ"/Respondent/

price) - 2,24.76.420 Less: GP at the rate of 5% as staled - - 11,23,821 Closing stock including accounted stock 2,13,52,599 Opening stock as per accounts 37,22,888 Add: Purchase accounted 16,39,659 53,62,541 Less: cost of goods sold : Sales as per book: 24,08,964 Less

NAREN RAJAN,COIMBATORE vs. ACIT, COIMBATORE

In the result, the appeal filed by the assessee for assessment year 2012-13 is partly allowed and appeal filed by the Revenue for assessment year 2012-13 is dismissed

Bench: Shri Mahavir Singh & Shri G. Manjunatha

price remains unpaid at the end of the previous year. Under those facts, the Hon’ble High Court came to the conclusion that amount due to the company as an advance to the director falling 29 I.T.A. Nos.1002 & 1161/Chny/2018 & 743/Chny/2015 within the mischief of section 2(22)(e) of the Act. In this case, the concern in which assessee

ACIT CORPORATE CIRCLE 2, COIMBATORE vs. LATE SHRI NAREN RAJAN, REP.BY L/H SMT. PADMINI V.R, COIMBATORE

In the result, the appeal filed by the assessee for assessment year 2012-13 is partly allowed and appeal filed by the Revenue for assessment year 2012-13 is dismissed

Bench: Shri Mahavir Singh & Shri G. Manjunatha

price remains unpaid at the end of the previous year. Under those facts, the Hon’ble High Court came to the conclusion that amount due to the company as an advance to the director falling 29 I.T.A. Nos.1002 & 1161/Chny/2018 & 743/Chny/2015 within the mischief of section 2(22)(e) of the Act. In this case, the concern in which assessee

PADMINI RAJAN, L/R OF LATE (SHRI) NAREN RAJAN,COIMBATORE vs. DCIT CORPORATE CIRCLE 2, COIMBATORE

In the result, the appeal filed by the assessee for assessment year 2012-13 is partly allowed and appeal filed by the Revenue for assessment year 2012-13 is dismissed

Bench: Shri Mahavir Singh & Shri G. Manjunatha

price remains unpaid at the end of the previous year. Under those facts, the Hon’ble High Court came to the conclusion that amount due to the company as an advance to the director falling 29 I.T.A. Nos.1002 & 1161/Chny/2018 & 743/Chny/2015 within the mischief of section 2(22)(e) of the Act. In this case, the concern in which assessee