VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

65B of the Indian Evidence Act. The assessee had therefore claimed that no addition could Evidence Act. The assessee had therefore claimed that no addition could Evidence Act. The assessee had therefore claimed that no addition could have been made on the basis of such unreliable material. Accordingly, the have been made on the basis of such unreliable material. Accordingly

DCIT, CIRCLE - 2 (1), INTERNATIONAL TAXATION,, CHENNAI vs. M/S. PETROFAC ENGINEERING SERVICES INDIA PVT. LTD.,, CHENNAI

In the result, appeals filed by the revenue for both

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.656 & 657/Chny/2020 ("नधा"रणवष" / Assessment Years: 2011-12 & 2012-13) Vs M/S. Petrofac Engineering The Deputy Commissioner Of Income Tax, Services Pvt.Ltd. 7Th Floor, Block 9A Circle-2(1), International Taxation, Chennai. Dlf Infocity Sez 1/124 Shivaji Gardens, Nandambakkam Post Manapakkam, Chennai-600089. Pan: Aaecp 1211H (अपीलाथ"/Appellant) (""यथ"/Respondent)

price of the computer programme as goods, either in a medium which stores the software or in a medium by which software is embedded in hardware, which may be then further resold by the distributor to the end-user in India, the distributor making a profit on such resale. Importantly, the distributor does not get the right

DCIT, CIRCLE - 2 (1), INTERNTIONAL TAXATION, CHENNAI vs. M/S. PETROFAC ENGINEERING SERVICES INDIA PVT. LTD,,, CHENNAI

In the result, appeals filed by the revenue for both

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.656 & 657/Chny/2020 ("नधा"रणवष" / Assessment Years: 2011-12 & 2012-13) Vs M/S. Petrofac Engineering The Deputy Commissioner Of Income Tax, Services Pvt.Ltd. 7Th Floor, Block 9A Circle-2(1), International Taxation, Chennai. Dlf Infocity Sez 1/124 Shivaji Gardens, Nandambakkam Post Manapakkam, Chennai-600089. Pan: Aaecp 1211H (अपीलाथ"/Appellant) (""यथ"/Respondent)

price of the computer programme as goods, either in a medium which stores the software or in a medium by which software is embedded in hardware, which may be then further resold by the distributor to the end-user in India, the distributor making a profit on such resale. Importantly, the distributor does not get the right

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

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, 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

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

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

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

In the result, ITA Nos.695 to 702/Chny/2023 stands dismissed

price. \nThe Ld. CIT(A) re-worked the same and excluded the profit element from \nvaluation. It could be seen that after excluding the profit element, the \nvaluation would come down to Rs.412.29 Lacs as against Rs.435.54 \n\n24\n\nLacs as already disclosed by the assessee. In such a case, the addition \nof Rs.38.86 Lacs and Rs.22.34 Lacs

SHRI. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

65B of the Indian Evidence Act, 1872. The relevant scanned images of the Profit & Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated

SHIR. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

65B of the Indian Evidence Act, 1872. The relevant scanned images of the Profit & Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated

SHRI. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CRICLE 2, MADURAI, MADURAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

65B of the Indian Evidence Act, 1872. The relevant scanned images of the Profit & Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated

SHRI. IRULANDI THEVAR VETRIVEL ,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

65B of the Indian Evidence Act, 1872. The relevant scanned images of the Profit & Loss Account extracted from the seized tally software was reproduced by the AO in the impugned assessment orders. 4. Upon analysis of the above seized material i.e. the tally software, the AO was of the view that, the tally data revealed that, the assessee had understated

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm

price. The Ld. CIT(A) re-worked the same and excluded the profit element from valuation. It could be seen that after excluding the profit element, the valuation would come down to Rs.412.29 Lacs as against Rs.435.54 Lacs as already disclosed by the assessee. In such a case, the addition of Rs.38.86 Lacs and Rs.22.34 Lacs has correctly been deleted

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

In the result, ITA Nos.695 to 702/Chny/2023 stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं. / Ita No.695/Chny/2023 (िनधा(रणवष( / Assessment Year: 2011-12) & 2. आयकरअपील सं. / Ita No.696/Chny/2023 (िनधा(रणवष( / Assessment Year: 2012-13) & 3. आयकरअपील सं. / Ita No.697/Chny/2023 (िनधा(रणवष( / Assessment Year: 2013-14) & 4. आयकरअपील सं. / Ita No.698/Chny/2023 (िनधा(रणवष( / Assessment Year: 2014-15) & 5. आयकरअपील सं. / Ita No.699/Chny/2023 (िनधा(रणवष( / Assessment Year: 2015-16) & 6. आयकरअपील सं. / Ita No.700/Chny/2023 (िनधा(रणवष( / Assessment Year: 2016-17) & 7. आयकरअपील सं. / Ita No.701/Chny/2023 (िनधा(रणवष( / Assessment Year: 2017-18) & 8. आयकरअपील सं. / Ita No.702/Chny/2023 (िनधा(रणवष( / Assessment Year: 2018-19) Dcit Shri C. Vijayabaskar बनाम/ Central Circle-2(1) #14/28-1, Sowrastra Street, Chennai. Illupur, Pudukottai-622 102. Vs.

price. The Ld. CIT(A) re-worked the same and excluded the profit element from valuation. It could be seen that after excluding the profit element, the valuation would come down to Rs.412.29 Lacs as against Rs.435.54 Lacs as already disclosed by the assessee. In such a case, the addition of Rs.38.86 Lacs and Rs.22.34 Lacs has correctly been deleted

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

In the result, ITA Nos.695 to 702/Chny/2023 stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं. / Ita No.695/Chny/2023 (िनधा(रणवष( / Assessment Year: 2011-12) & 2. आयकरअपील सं. / Ita No.696/Chny/2023 (िनधा(रणवष( / Assessment Year: 2012-13) & 3. आयकरअपील सं. / Ita No.697/Chny/2023 (िनधा(रणवष( / Assessment Year: 2013-14) & 4. आयकरअपील सं. / Ita No.698/Chny/2023 (िनधा(रणवष( / Assessment Year: 2014-15) & 5. आयकरअपील सं. / Ita No.699/Chny/2023 (िनधा(रणवष( / Assessment Year: 2015-16) & 6. आयकरअपील सं. / Ita No.700/Chny/2023 (िनधा(रणवष( / Assessment Year: 2016-17) & 7. आयकरअपील सं. / Ita No.701/Chny/2023 (िनधा(रणवष( / Assessment Year: 2017-18) & 8. आयकरअपील सं. / Ita No.702/Chny/2023 (िनधा(रणवष( / Assessment Year: 2018-19) Dcit Shri C. Vijayabaskar बनाम/ Central Circle-2(1) #14/28-1, Sowrastra Street, Chennai. Illupur, Pudukottai-622 102. Vs.

price. The Ld. CIT(A) re-worked the same and excluded the profit element from valuation. It could be seen that after excluding the profit element, the valuation would come down to Rs.412.29 Lacs as against Rs.435.54 Lacs as already disclosed by the assessee. In such a case, the addition of Rs.38.86 Lacs and Rs.22.34 Lacs has correctly been deleted

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

In the result, ITA Nos.695 to 702/Chny/2023 stands dismissed

price. \nThe Ld. CIT(A) re-worked the same and excluded the profit element from \nvaluation. It could be seen that after excluding the profit element, the \nvaluation would come down to Rs.412.29 Lacs as against Rs.435.54 \nLacs as already disclosed by the assessee. In such a case, the addition \nof Rs.38.86 Lacs and Rs.22.34 Lacs has correctly been deleted