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

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

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

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

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

transfer to a new business of machinery or plant previously used for\nany purpose\".\n5.4 The Id.CIT(A) erred in not observing that the assessee purchased the first\nunit K-40 in the FY 2011-12 and this unit was previously owned and used by\nM//s.AmitronicsPvt Ltd, Bangalore and this machine was originally installed

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

transferred to the Jewellers for purchase. There are\nno receipts available for the said cash purchases and no submission as to from which\nJeweller such huge amount of Jewellery has been purchased. In the absence of the\nabove documents evidencing purchase of jewellery, it is evident that the cash withdrawals\nhave been used for some other purpose

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

In the result, the appeals filed by the Revenue in I

transferred to the Jewellers for purchase. There are\nno receipts available for the said cash purchases and no submission as to from which\nJeweller such huge amount of Jewellery has been purchased. In the absence of the\nabove documents evidencing purchase of jewellery, it is evident that the cash withdrawals\nhave been used for some other purpose

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

transferred to the Jewellers for purchase. There are\nno receipts available for the said cash purchases and no submission as to from which\nJeweller such huge amount of Jewellery has been purchased. In the absence of the\nabove documents evidencing purchase of jewellery, it is evident that the cash withdrawals\nhave been used for some other purpose

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

transfer to a new business of machinery or plant previously used for any purpose”. 5.4 The ld.CIT(A) erred in not observing that the assessee purchased the first unit K-40 in the FY 2011-12 and this unit was previously owned and used by M//s.AmitronicsPvt Ltd, Bangalore and this machine was originally installed

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

transfer to a new business of machinery or plant previously used for\nany purpose\".\n5.4 The Id.CIT(A) erred in not observing that the assessee purchased the first\nunit K-40 in the FY 2011-12 and this unit was previously owned and used by\nM//s.AmitronicsPvt Ltd, Bangalore and this machine was originally installed

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing proceedings, the assessee has submitted that Letter of Comfort is a facility to avail credit by Parry America Inc. which is a subsidiary of the assessee company. Therefore, the assessee contented before the TPO that, the above facility is not a guarantee and the adjustment towards guarantee commission would not arise with reference to Section

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing proceedings, the assessee has submitted that Letter of Comfort is a facility to avail credit by Parry America Inc. which is a subsidiary of the assessee company. Therefore, the assessee contented before the TPO that, the above facility is not a guarantee and the adjustment towards guarantee commission would not arise with reference to Section

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

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)

69A of the Act for the AY 2017-18 on merits also. Aggrieved by the order of the ld.CIT(A) the revenue is before us. 7. The ld.DR assailing the action of the ld.CIT(A) stated that the order of the ld.CIT(A) is erroneous in deleting the addition of :-15-: ITA. No: 1982 & 2119/Chny/2024 CO No: 60/Chny/2024 Rs.17.01 Crores

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

69A of the Act. He pointed out various issues by\nraising questions and gave in writing as under:-\nHe pointed out that is there a legal bar in transacting business in SBNs by\nthe Government from 9th November 2016 onwards?\nYes, Government of India vide Gazette of India dated 08.11.2016 had\ndeclared the SBN as not a legal currency with

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

In the result, the appeal of the assessee is dismissed

69A of the Act for the AY 2017-18 on merits also.\nAggrieved by the order of the Id.CIT(A) the revenue is before us.\n7.\nThe Id.DR assailing the action of the Id.CIT(A) stated that the\norder of the Id.CIT(A) is erroneous in deleting the addition of\n-:-14-:\nITA. No: 1982 & 2119/Chny/2024\nCO No: 60/Chny/2024\nRs.17.01

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. SRI RAMA JEWELLERY MART, TRICHY

Appeal stand dismissed

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.3334/Chny/2024 (िनधा'रण वष' / Assessment Year: 2020-21) Dcit Sri Rama Jewellery Mart बनाम/ Vs. Central Circle-2, # 170, Big Bazar Trichy. Trichy-620 008. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabfs-0686-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Ms. Guathami Manivasagam (Jcit) - Ld. Sr. Dr " थ" की ओर से/Respondent By : Shri N. Arjun Raj & Shri S. Girish Kumar (Advocates) - Ld. Ars सुनवाई की तारीख/Date Of Hearing : 08-05-2025 घोषणा की तारीख /Date Of Pronouncement : 27.06.2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Revenue For Assessment Year (Ay) 2020-21 Arises Out Of An Order Passed By Ld. Commissioner Of Income Tax (Appeals), Chennai-19 [Cit(A)] On 29-10-2024 In The Matter Of An Assessment Framed By Ld. Ao U/S 143(3) On 29-09-2022. The Grounds Of Appeal Read As Under: - 1. The Order Of The Learned Commissioner Of Income Tax (Appeals) Is Erroneous On Facts Of The Case & In Law. 2 The Ld. Cit (A) Erred In Deleting The Addition Of Rs.51,80,002/- Made Towards Unexplained Money U/S.69A & In Accepting That The Assessee Was Able To Demonstrate The Availability Of Cash, Including Cash Sales That Were Properly Recorded In The Books Of Accounts & Submitted Relevant Supporting Documents, Including The Cash Book, Which Reflected The Cash Balance Of Rs.51,80,002/-Without Appreciating The Fact That The Cash

transfer of cash from branch office to head office and the discrepancy was stated to be resolved. The Ld. AO doubted the same on the ground that the transactions were shown to have taken place one month before the date of survey and the necessity for keeping such huge cash was not explained with any cogent reasons. The assessee stated

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX , CHENNAI

In the result, all the three appeals of the assessee stand allowed

transferring purchase details into S.S. Retail and\nthereafter to Tally. Accordingly, goods procured without invoices are never capable of\nentering the accounting system.\nThe statements of Managing Partner Shri. Venkateshwaran (pp. 09) and the affidavit\nfiled by the assessee further reinforce that the only manipulation in the software related\nto post-sale reduction of sale values, and had no relation