M/S. SRI BALAJI EDUCATIONAL AND CHARITABLE PUBLIC TRUST,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(4), CHENNAI

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

transfer or receive any Specified Bank Notes. From the above what is clear is that up to the appointed date Le 31.12.2016, there is no prohibition for dealing with Specified Bank Notes. Therefore, in my considered view, the objection of the AO on this regard in light of said Act is devoid of merits. Further, a similar issue had been

ACIT, CHENNAI vs. SRI BALAJI EDUCATIONAL AMD TRUST CHARITABLE PUBLIC TRUST , CHENNA

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

transfer or receive any Specified Bank Notes. From the above what is clear is that up to the appointed date Le 31.12.2016, there is no prohibition for dealing with Specified Bank Notes. Therefore, in my considered view, the objection of the AO on this regard in light of said Act is devoid of merits. Further, a similar issue had been

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2), , CHENNAI

In the result the appeal of the assessee is partly allowed

credits in the bank account of M/s.Saraswathi Bhavanam, which were\nmostly by way of cash deposits as discussed in para 1 above. In response\nto the summons Smt.Jayanthi Seeman appeared on 05-09-2014 and a\nSworn Statement was recorded. Vide question No.4 of the statement\nSmt.Jayanthi Seeman was required to explain the details of cash deposits\nin her account

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

credits in the bank account of M/s.Saraswathi Bhavanam, which were\nmostly by way of cash deposits as discussed in para 1 above. In response\nto the summons Smt.Jayanthi Seeman appeared on 05-09-2014 and a\nSworn Statement was recorded. Vide question No.4 of the statement\nSmt.Jayanthi Seeman was required to explain the details of cash deposits\nin her account

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

credits in the bank account of M/s.Saraswathi Bhavanam, which were\nmostly by way of cash deposits as discussed in para 1 above. In response\nto the summons Smt.Jayanthi Seeman appeared on 05-09-2014 and a\nSworn Statement was recorded. Vide question No.4 of the statement\nSmt.Jayanthi Seeman was required to explain the details of cash deposits\nin her account

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

cash credits u/s.68 of the Act;\nb. addition on account of unexplained investment u/s.69 of the Act; and\nc. disallowance of expenses allegedly incurred for earning exempt income\nu/s.14A of the Act.\n76. Before adverting to the merits of the additions so made, we deem it\nappropriate, at the threshold, to examine the jurisdiction and scope of enquiry\npermissible

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

Cash Flow (DCF) method (for AY 2010-11, it is as per CCI guidelines) was done only to comply with the requirements of RBI Guidelines pertaining to allotments made to Non- Residents. As per the FEMA Regulations dealing with Foreign Direct Investments, shares should be issued to foreign investors only at a price equal to or higher than the value

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)

credit in the hands of the creditor (after making due enquiries from such creditor)". 6.6.9 From the above bank statement, it can be seen that the Appellant has repaid the loans taken from the creditors, thus, there exists no question to treat the creditors as bogus and making addition as unexplained as per the provisions of section

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

Cash Flow\n(DCF) method (for AY 2010-11, it is as per CCI guidelines)\nwas done only to comply with the requirements of RBI\nGuidelines pertaining to allotments made to Non-\nResidents. As per the FEMA Regulations dealing with\nForeign Direct Investments, shares should be issued to\nforeign investors only at a price equal to or higher than\nthe

THE INDIA CEMENTS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1) CHENNAI, CHENNAI

transfer pricing\nadjustment and allow this ground raised by the assessee.\n11. Ground No.10 raised by the assessee is against the addition made\nby the AO u/s 68 of the Act, in respect of deposit of Specified Bank Notes\n[in short `SBNs'] to the extent of ₹41,06,000/- during the period of\nNovember-December 2016. The facts relating

DCIT CENTRAL CIRCLE 2(1), CHENNAI vs. M/S. KAG INDIA PVT. LTD, CHENNAI

The appeal stand dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपीलसं./ Ita No.669/Chny/2023 (िनधा9रणवष9 / Assessment Year: 2012-13) Dcit M/S. Kag India Private Limited बनाम/ Central Circle-2(1), 264/15-1, Sathiyanathan Complex, Chennai. Velachery Road,East Tambaram, Vs. Chennai-600 059. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aadck-5381-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Y. Sridhar (Fca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 18-06-2024 घोषणाकीतारीख /Date Of Pronouncement : 10-07-2024 आदेश / O R D E R

unexplained cash credit u/s 68. Appellate Proceedings 4.1 During appellate proceedings, the assessee submitted that no incriminating material was found with respect to impugned additions. The regular assessment was framed u/s 143(3) after due enquiries. Another argument was that this period was beyond six years as contemplated u/s 153A and there was no underlying asset as per Explanation

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

credit\n:-3-:\nITA. No: 1632/Chny/2025\nbill for Rs.800/- as against the actual sale price of Rs.1,450/-. He further stated\nthat it was the regular practice of the assessee to issue bills for a lower value.\nIn her sworn statement recorded during the survey, the assessee admitted the\ntotal turnover for the relevant assessment year, as on the date

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

A.GOVINDARAJ, DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, CENTRAL RANGE, MADURAI vs. IRULANDI THEVAR VETRIVEL, PALAMEDU MAIN ROAD MADURAI

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

unexplained cash expenditure, parallel books of\naccounts etc. was found. We thus find merit in the Ld. CIT(A)'s\nobservations that, in the absence of unearthing of any evidence during\nthe search regarding the deployment of huge quantum of undisclosed\nincome alleged to have been generated by the assessee by booking of\nbogus expenses\ntowards any undisclosed assets/ investments

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

unexplained cash expenditure, parallel books of\naccounts etc. was found. We thus find merit in the Ld. CIT(A)'s\nobservations that, in the absence of unearthing of any evidence during\n==End of OCR for page 46==\nthe search regarding the deployment of huge quantum of undisclosed\nincome alleged to have been generated by the assessee by booking

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

In the result, the appeal of the assessee is dismissed

transfer from bank\naccounts of group concerns. Since the assessee had not proved the\ngenuniness of source for the transaction in the seized material, it\npartakes the character of incriminating material and the AO has\nrightly initiated proceedings u/s.153C.\n7.2 Further, the Id.DR argued that the Ld.CIT(A) erred in\nobserving that on cancellation of transaction, SEBI returned

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

unexplained cash expenditure, parallel books of accounts etc. was found. We thus find merit in the Ld. CIT(A)’s observations that, in the absence of unearthing of any evidence during ITA Nos.131 to 136/Chny/2024 (AYs 2016-17 to 2021-22) ITA Nos.235 to 240/Chny/2024 (AYs 2016-17 to 2021-22) Shri Irulandi Thevar Vetrivel :: 47 :: the search regarding

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

unexplained cash expenditure, parallel books of accounts etc. was found. We thus find merit in the Ld. CIT(A)’s observations that, in the absence of unearthing of any evidence during ITA Nos.131 to 136/Chny/2024 (AYs 2016-17 to 2021-22) ITA Nos.235 to 240/Chny/2024 (AYs 2016-17 to 2021-22) Shri Irulandi Thevar Vetrivel :: 47 :: the search regarding

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

unexplained cash expenditure, parallel books of accounts etc. was found. We thus find merit in the Ld. CIT(A)’s observations that, in the absence of unearthing of any evidence during ITA Nos.131 to 136/Chny/2024 (AYs 2016-17 to 2021-22) ITA Nos.235 to 240/Chny/2024 (AYs 2016-17 to 2021-22) Shri Irulandi Thevar Vetrivel :: 47 :: the search regarding