P PALANISMAY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

search parties u/s.132(4) also proved the loan\namounts were entered in the loan accounts in the books of the firms\nwith two-digit suppression.\nShri Palianisamy established total control of the businesses of various\nfirms that were established at different places by making sure that\nevery month the books of accounts were sent to Bangalore, the place\nof residence

PALANISAMY RAGHUPATHY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3, COIMBATORE

search find brought out\nby the Assessing Officer during the assessment proceedings of which\nthe sample documents were scanned and made part of the assessment\norder, along with the Sworn statements recorded from the partners,\nemployees and debtors in each of the firms. It is to be noted that in\nevery statement recorded during the search u/s.132

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRI JAYA PRADEEP, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

seizure of certain books of account, loose sheets and\ndocuments. The statement of Shri Ganesan Saravanakumar, Director of the\nsaid company, was recorded with reference to the seized materials.\n4. Among the documents seized were loose sheets, books and documents\nmarked as ANN/KP/GS/LS/S and ANN/SJ/GS/B&D/S. The AO while framing the\nassessment, reproduced the relevant portions of these seized documents

P. PALANISAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

search in different firms and the statements were recorded u/s.\n132(4) of the Income Tax Act 1961. In the sworn statement recorded\nu/s 132(4) from N Sundaramoorthy, partner of PP Enterprises\nOddanchatram dated 11.08.2017 in Q No. 18, the partner has\nconfirmed the two-digit suppression system with example. The same\nwas confirmed by Shri Palanisamy

PALANISAMY RAGHUPATHY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

search find brought out \nby the Assessing Officer during the assessment proceedings of which \nthe sample documents were scanned and made part of the assessment \norder, along with the Sworn statements recorded from the partners, \nemployees and debtors in each of the firms. It is to be noted that in \nevery statement recorded during the search u/s.132

M/S. P.P. FINANCIERS,CHENNAI vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

search find brought out\nby the Assessing Officer during the assessment proceedings of which\nthe sample documents were scanned and made part of the assessment\norder, along with the Sworn statements recorded from the partners,\nemployees and debtors in each of the firms. It is to be noted that in\nevery statement recorded during the search u/s.132

ST.JOSEPH'S EDUCATIONAL TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner, (a) the order is passed without making inquiries or verification which should have been made

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner, (a) the order is passed without making inquiries or verification which should have been made

P KUPPUCHAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3, , COIMBATORE

search in different firms and the statements were recorded u/s. 132(4) of the Income Tax Act 1961. In the sworn statement recorded u/s 132(4) from N Sundaramoorthy, partner of PP Enterprises Oddanchatram dated 11.08.2017 in Q No. 18, the partner has confirmed the two-digit suppression system with example. The same was confirmed by Shri Palanisamy

P PALANISAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3, COIMBATORE

search in different firms and the statements were recorded u/s.\n132(4) of the Income Tax Act 1961. In the sworn statement recorded\nu/s 132(4) from N Sundaramoorthy, partner of PP Enterprises\nOddanchatram dated 11.08.2017 in Q No. 18, the partner has\nconfirmed the two-digit suppression system with example. The same\nwas confirmed by Shri Palanisamy

M/S. GRT JEWELLERS INDIA PRIVATE LIMITED,CHENNAI vs. DCIT,. CENTRAL CIRCLE-3(3), CHENNAI

In the result, appeal filed by the assessee is partly

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita No.: 113/Chny/2024 िनधा"रणवष" / Assessment Year: 2014-15

seizure operation u/s. 132 of the Act, was carried out in the GRT Group of cases on 16.05.2013. The assessee was also covered u/s. 132 of the Act. Consequent to search, notice u/s. 153A of the Act, was issued and served on the :-7-: ITA. No: 113/Chny/2024 assessee. The assessee had filed its return of income on 29.09.2014, declaring

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)

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

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

M/S. SRI BALAJI EDUCATIONAL AND CHARITABLE PUBLIC TRUST,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(4), CHENNAI

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, CHENNAI vs. SHRIPROP PROPERTIES PRIVATE LIMITED, BANGALORE

Bench: Shri George George K & Ms Padmavathy S, Am

search and seizure u/s 132 was conducted on 10-2-2001 pursuant to which the assessment order for the block period from 1-4-1989 to 10-2-2000 was passed on 28-02-2002 at a total undisclosed income of Rs. 85,00,000/-. The tax was charged as prescribed in section 113 of the Act. Subsequently, a proviso

SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

search and seizure u/s 132 was conducted on 10-2-2001 pursuant to which the assessment order for the block period from 1-4-1989 to 10-2-2000 was passed on 28-02-2002 at a total undisclosed income of Rs. 85,00,000/-. The tax was charged as prescribed in section 113 of the Act. Subsequently, a proviso

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SPL SHELTERS PRIVATE LIMITED, CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

search and seizure u/s 132 was conducted on 10-2-2001 pursuant to which the assessment order for the block period from 1-4-1989 to 10-2-2000 was passed on 28-02-2002 at a total undisclosed income of Rs. 85,00,000/-. The tax was charged as prescribed in section 113 of the Act. Subsequently, a proviso

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