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

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

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

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P P ENTERPRISES, BENGALURU

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

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

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

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

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

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

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

M/S. P.P. ENTERPRISES,BENGALURU vs. ACIT< CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

SELLAMUTHU KABILAN,BENGALURU vs. ACIT, CENTRAL CRICLE 3, COIMBATORE, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

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

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

L KARUPPUSAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

153D raised by the assessee is, therefore, not adjudicated at present and is kept open. 44. Since the assessments are quashed on the basis of Grounds No.3, the other grounds raised by the assessee are not required to be adjudicated and are accordingly left open. 45. We note that although the ld.AR raised several grounds on merits, no substantive submissions

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P P ENTERPRISES, BENGALURU

In the result, appeal filed by the assessee and department are\nallowed or dismissed as per chart below

153D of the Act, we\nnote that the said affidavit seeks to explain the procedure followed\nin the search assessment proceedings and delineates the respective\nroles of the Assessing Officer and the Range Head. The ld.AR has,\non the other hand, invited our attention to certain alleged clerical\nITA No.1119/Chny/2025 & ‘60’ Others\nMr. P. Palanisamy\nM/s. P.P. Financiers

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P P ENTERPRISES, BENGALURU

Section 292C uses\nthe words “it may be presumed” and the Hon’ble Apex Court in P. R.\nMetrani v. CIT 287 ITR 209 (SC) explained the concept of\npresumptions and expression "may be presumed" as under-\n\n\"22. A presumption is an inference of fact drawn from other\nknown or proved facts. It is a rule

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

Section 292C uses\nthe words “it may be presumed” and the Hon’ble Apex Court in P. R.\nMetrani v. CIT 287 ITR 209 (SC) explained the concept of\npresumptions and expression "may be presumed" as under-\n\"22. A presumption is an inference of fact drawn from other\nknown or proved facts. It is a rule of law under

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

section 115BBE increasing the rate of tax to 60% is not retrospectively applicable. The Hon’ble Madras High Court in S.M.I.L.E Microfinance Limited v ACIT 2024 SCC OnLine Mad 8416 (Pages 248 – 259 of Case Law Book 1) has categorically held that the rate of 60 percent is to be imposed only for the transactions from 01.04.2017. The above order

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

Section 292C uses\nthe words “it may be presumed” and the Hon’ble Apex Court in P. R.\nMetrani v. CIT 287 ITR 209 (SC) explained the concept of\npresumptions and expression "may be presumed" as under-\n==End of OCR for page 77==\n"22. A presumption is an inference of fact drawn from other\nknown or proved facts

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

Section 292C uses\nthe words “it may be presumed” and the Hon’ble Apex Court in P. R.\nMetrani v. CIT 287 ITR 209 (SC) explained the concept of\npresumptions and expression "may be presumed" as under-\n"22. A presumption is an inference of fact drawn from other\nknown or proved facts. It is a rule of law under

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

Section 292C uses\nthe words “it may be presumed” and the Hon’ble Apex Court in P. R.\nMetrani v. CIT 287 ITR 209 (SC) explained the concept of\npresumptions and expression "may be presumed" as under-\n.. 77 ::\n"22. A presumption is an inference of fact drawn from other\nknown or proved facts. It is a rule

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

Section 292C uses\nthe words “it may be presumed” and the Hon'ble Apex Court in P. R.\nMetrani v. CIT 287 ITR 209 (SC) explained the concept of\npresumptions and expression "may be presumed" as under-\n==End of OCR for page 77== ==Start of OCR for page 78== "22. A presumption is an inference of fact drawn from