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

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

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

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

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

Bench: Shri Aby T Varkey & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.: 1253, 1264 & 1271/Chny/2025 निर्धारण वर्ष / Assessment Year: 2017-18 Dcit, Central Circle -2(3), Chennai. (अपीलार्थी/Appellant) Vs. Jagathrakshakan Srinisha, 1St Main Road, Adyar, Besant Nagar, Chennai - 600 020. Tamil Nadu. [Pan: Abfps-1422-E] (प्रत्यर्थी/Respondent) निर्धारिती की ओर से/Assessee By : Shri. B. Ramakrishnan, Fca & Shri. Shrenik Chordia, Ca. राजस्व की ओर से / Revenue By : Shri. C.N. Bipin, C.I.T. सुनवाई की तारीख /Date Of Hearing : 07.11.2025 घोषणा की तारीख/Date Of Pronouncement : 18.11.2025 आदेश /Order Per S.R.Raghunatha, Am: The Present Appeal Is Preferred By The Revenue Against The Order Dated 06.02.2025 Passed By The Commissioner Of Income Tax (Appeals)-19 (Hereinafter Referred To As Ld.Cit(A), Chennai, In Respect Of The Assessment Order Dated 01.03.2019 Passed By The Deputy Commissioner Of Income Tax, Central Circle -2(3) (Hereinafter Referred To As Ao) For The Assessment Year 2017-18 (Hereinafter Referred To As The Impugned Assessment Year) U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter Referred To As The Act). :-2-:

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

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

69C of the Income-tax Act, 1961, when for the purposes of assessment order u/s. 158BC of the Income-tax Act, the income which is disclosed in the income-tax returns has only to be considered as per the provisions of section 158BB(1) of the Act ?" Chapter XIV-B of the Act essentially proceeds on the basis that where

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

69C of the Income-tax Act, 1961, when for the purposes of assessment order u/s. 158BC of the Income-tax Act, the income which is disclosed in the income-tax returns has only to be considered as per the provisions of section 158BB(1) of the Act ?" Chapter XIV-B of the Act essentially proceeds on the basis that where

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

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

69C of the Act. On the issue of suppressed sales, th issue of suppressed sales, the Ld. CIT(A) directed that the same be added e Ld. CIT(A) directed that the same be added to the reported turnover of the assessee and that the profits of 2.21% be to the reported turnover of the assessee and that the profits

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

69C of the Act. On the issue of suppressed sales, th issue of suppressed sales, the Ld. CIT(A) directed that the same be added e Ld. CIT(A) directed that the same be added to the reported turnover of the assessee and that the profits of 2.21% be to the reported turnover of the assessee and that the profits

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

69C of the Act. On the issue of suppressed sales, th issue of suppressed sales, the Ld. CIT(A) directed that the same be added e Ld. CIT(A) directed that the same be added to the reported turnover of the assessee and that the profits of 2.21% be to the reported turnover of the assessee and that the profits

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

69C of the Act. On the issue of suppressed sales, th issue of suppressed sales, the Ld. CIT(A) directed that the same be added e Ld. CIT(A) directed that the same be added to the reported turnover of the assessee and that the profits of 2.21% be to the reported turnover of the assessee and that the profits

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

69C of the Act. The assessee is noted to have furn The assessee is noted to have furnished their response vide letter ished their response vide letter 8.4 dated 02-02-2023. The assessee had first explained that, the purported 2023. The assessee had first explained that, the purported 2023. The assessee had first explained that, the purported data which

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

69C of the Act. The assessee is noted to have furn The assessee is noted to have furnished their response vide letter ished their response vide letter 8.4 dated 02-02-2023. The assessee had first explained that, the purported 2023. The assessee had first explained that, the purported 2023. The assessee had first explained that, the purported data which

M/S. LALITHA JEWELLERY MART LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, all the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

69C of the Act. The assessee is noted to have furn The assessee is noted to have furnished their response vide letter ished their response vide letter 8.4 dated 02-02-2023. The assessee had first explained that, the purported 2023. The assessee had first explained that, the purported 2023. The assessee had first explained that, the purported data which

ACIT, TRICHY vs. P.MURUGESAN, THANJAVUR

Bench: Shri Chandra Poojari & Shri V. Durga Rao

transferred from purchase account. No books of accounts were produced for the general account i.e., transactions other than PR & Sons hence the sources for credits to capital account in PR & Sons cannot be verifiable. Since the assessee has not produced purchase bills the above transactions cannot be verifiable. Therefore, the lower authorities has taken a correct decision in considering

SRI PONNAIYAH RAMAJAYATHAMMAL EDUCTIONAL & CHARITABLE TRUST,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

transferred from purchase account. No books of accounts were produced for the general account i.e., transactions other than PR & Sons hence the sources for credits to capital account in PR & Sons cannot be verifiable. Since the assessee has not produced purchase bills the above transactions cannot be verifiable. Therefore, the lower authorities has taken a correct decision in considering

P.MURUGESAN,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

transferred from purchase account. No books of accounts were produced for the general account i.e., transactions other than PR & Sons hence the sources for credits to capital account in PR & Sons cannot be verifiable. Since the assessee has not produced purchase bills the above transactions cannot be verifiable. Therefore, the lower authorities has taken a correct decision in considering

ACIT, TRICHY vs. SHRI R.VISWANATHAN, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

transferred from purchase account. No books of accounts were produced for the general account i.e., transactions other than PR & Sons hence the sources for credits to capital account in PR & Sons cannot be verifiable. Since the assessee has not produced purchase bills the above transactions cannot be verifiable. Therefore, the lower authorities has taken a correct decision in considering

ACIT, TRICHY vs. SHRI P.JANAKAR, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

transferred from purchase account. No books of accounts were produced for the general account i.e., transactions other than PR & Sons hence the sources for credits to capital account in PR & Sons cannot be verifiable. Since the assessee has not produced purchase bills the above transactions cannot be verifiable. Therefore, the lower authorities has taken a correct decision in considering