ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

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

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

ACIT, NUNGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

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

prices are highly volatile. Timely\nlifting, transportation, storage, and export were critical, as delays could\nresult in substantial demurrage and dead freight costs. Since transport\noperators lacked adequate incentive to ensure timely delivery, the\nassessee assumed responsibility for resolving logistical impediments\nthrough direct intervention involving facilitation payments at various\nstages.\n11. Similar challenges were faced in the sourcing and supply

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

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

prices are highly volatile. Timely\nlifting, transportation, storage, and export were critical, as delays could\nresult in substantial demurrage and dead freight costs. Since transport\noperators lacked adequate incentive to ensure timely delivery, the\nassessee assumed responsibility for resolving logistical impediments\nthrough direct intervention involving facilitation payments at various\nstages.\n11. Similar challenges were faced in the sourcing and supply

ACIT, NUNAGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

prices are highly volatile. Timely\nlifting, transportation, storage, and export were critical, as delays could\nresult in substantial demurrage and dead freight costs. Since transport\noperators lacked adequate incentive to ensure timely delivery, the\nassessee assumed responsibility for resolving logistical impediments\nthrough direct intervention involving facilitation payments at various\nstages.\n11. Similar challenges were faced in the sourcing and supply

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

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

prices are highly volatile. Timely\nlifting, transportation, storage, and export were critical, as delays could\nresult in substantial demurrage and dead freight costs. Since transport\noperators lacked adequate incentive to ensure timely delivery, the\nassessee assumed responsibility for resolving logistical impediments\nthrough direct intervention involving facilitation payments at various\nstages.\n11. Similar challenges were faced in the sourcing and supply

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

transfer monies to the bank account(s) of his\nthirty eight (38) firms, which Shri CPA would withdraw in cash and hand\nover to the assessee. Shri CPA however expressed his unknowingness to\nthe manner and mode in which the coal companies would allegedly pay\nmonies to Shri PLA but submitted that somehow he would receive the\nmonies

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

transfer monies to the bank account(s) of his\nthirty eight (38) firms, which Shri CPA would withdraw in cash and hand\nover to the assessee. Shri CPA however expressed his unknowingness to\nthe manner and mode in which the coal companies would allegedly pay\nmonies to Shri PLA but submitted that somehow he would receive the\nmonies

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

transfer monies to the bank account(s) of his\nthirty eight (38) firms, which Shri CPA would withdraw in cash and hand\nover to the assessee. Shri CPA however expressed his unknowingness to\nthe manner and mode in which the coal companies would allegedly pay\nmonies to Shri PLA but submitted that somehow he would receive the\nmonies

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

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

transfer monies to the bank account(s) of his thirty eight (38) firms, which Shri CPA would withdraw in cash and hand over to the assessee. Shri CPA however expressed his unknowingness to the manner and mode in which the coal companies would allegedly pay monies to Shri PLA but submitted that somehow he would receive the monies

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

transfer monies to the bank account(s) of his\nthirty eight (38) firms, which Shri CPA would withdraw in cash and hand\nover to the assessee. Shri CPA however expressed his unknowingness to\nthe manner and mode in which the coal companies would allegedly pay\nmonies to Shri PLA but submitted that somehow he would receive the\nmonies

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

292C\nis only a presumption which is rebuttable and in the light of\nthe overwhelming evidence to show that the books do not\nbelong to the firm, the presumption u/s.292C cannot be\npressed into service to treat the books as belonging to the\nfirm.\nWithout prejudice to the above, even if it is presumed that the\nseized material belong

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P.P. CONSTRUCTIONS, KARUR

section 115BBE\nincreasing the rate of tax to 60% is not retrospectively\napplicable. The Hon’ble Madras High Court in S.M.I.L.E\nMicrofinance Limited v ACIT 2024 SCC OnLine Mad 8416 (Pages\n248 – 259 of Case Law Book 1) has categorically held that the\nrate of 60 percent is to be imposed only for the transactions\nfrom 01.04.2017. The above order

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

section 115BBE, which prescribe higher rates of tax, cannot be\ninvoked for assessment years prior to AY 2018-19. Although this\nissue has become academic, following the decision of the Hon’ble\nMadras High Court in S.M.I.L.E Microfinance Limited v. ACIT (SCC\nOnLine Mad 8416), we have held in the case of P. Palanisamy that\nthe enhanced rate

M/S. P.P. FINANCIERS,KARUR 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

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

section 115BBE\nincreasing the rate of tax to 60% is not retrospectively\napplicable. The Hon’ble Madras High Court in S.M.I.L.E\nMicrofinance Limited v ACIT 2024 SCC OnLine Mad 8416 (Pages\n248 – 259 of Case Law Book 1) has categorically held that the\nrate of 60 percent is to be imposed only for the transactions\nfrom 01.04.2017. The above order

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

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

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

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. 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

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

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

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