DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

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

unexplained\nincome as that stands explained.\n5. With regards to the jewellery claimed to have been offered under VDIS to an\nextent of 1,878.45 gms of gold jewellery:\n5. 1. As brought out by Ld AO, that none of the jewellery under the VDIS have been\nfound part of the jewellery found and seized during the course of search

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

unexplained\nincome as that stands explained.\n5. With regards to the jewellery claimed to have been offered under VDIS to an\nextent of 1,878.45 gms of gold jewellery:\n5.1. As brought out by Ld AO, that none of the jewellery under the VDIS have been\nfound part of the jewellery found and seized during the course of search

DCIT, CHENNAI vs. JAGATHRAKSHAKAN SRINISHA, CHENNAI

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

unexplained\nincome as that stands explained.\n5. With regards to the jewellery claimed to have been offered under VDIS to an\nextent of 1,878.45 gms of gold jewellery:\n5. 1. As brought out by Ld AO, that none of the jewellery under the VDIS have been\nfound part of the jewellery found and seized during the course of search

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

Investments, the shares should be issued to foreign investors only at a price equal to or higher of the value determined under the DCF\nmethod. The year wise details of the shares issued are given in\nthe below table:\nName FY\nAY\nNo.of\nshares\nissued\nShare\ncapital\n(Rs. in\ncrores)\nShare\npremium\n(Rs.in\ncrores)\nof\nParty\nMJC\n2009

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

price is not exact\nmultiple of Rs 500/-), one part of sale consideration received in\nSBNs cannot be considered as unexplained while the balance\nreceived in other currency from the same customer is treated as the\nsource being explained. In case of TASMAC, AO has made the\naddition of unexplained investment under sec 69of the Act. Addition\ncannot be made

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

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

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

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

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

price received by the seller of the goods for the acquisition seller of the goods for the acquisition of which it has already incurred of which it has already incurred the cost. It is the the cost. It is the realization of excess over the cost incurred of excess over the cost incurred thatonlyforms part of the profit included

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

unexplained investment u/s.69 of the Act, in our considered opinion, is\nclearly dehors the scope of the limited scrutiny assessment. By making the said\naddition, the AO has evidently travelled beyond the issues for which the case\nwas selected under the CASS for limited scrutiny. In effect, the AO has assumed\njurisdiction to conduct a complete scrutiny assessment, despite

PURANI HOSPITAL SUPPLIES PRIVATE LIMITED,COIMBATORE vs. DCIT CORPORATE CIRCLE-2, COIMBATORE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 489/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

price', is ab-initio void as per the provisions of Sec.23 of the Contracts Act, 1872 and thus non- est in the eves of law. Hence, such SBNs cannot be treated as having arisen out of a contract for sale. Hence the sum of cash deposit to an amount of Rs.1,82,37,000/- (Rs.1,82,57,000- Rs.20

ASSISTANT COMMISSIONER OF ICNOME TAX, CHENNAI vs. CHANDRASEKARAN JOSEPH VIJAY, CHENNAI

The appeals stand dismissed

price mentioned in the documents.\n2.9 Finally, the differential amounts were added in respective\n assessment years as unexplained investment u/s 69. The impugned\naddition for this year was Rs.260 Lacs. Similar additions were made in\nother years. Aggrieved, the assessee preferred further appeal before Ld.\nCIT(A).\n3.\nAppellate Proceedings\n3.1 During appellate proceedings, the assessee assailed impugned\naddition

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

unexplained investment in the ornaments was required to be treated as undisclosed income for the assessment year 1994-95. The same reasoning has been given by the Assessing Officer with regard to the silver articles and utensils which came to be detected during the above search. However, the Tribunal found that all the above- mentioned articles had been declared

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

unexplained investment in the ornaments was required to be treated as undisclosed income for the assessment year 1994-95. The same reasoning has been given by the Assessing Officer with regard to the silver articles and utensils which came to be detected during the above search. However, the Tribunal found that all the above- mentioned articles had been declared

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRI JAYA PRADEEP, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

prices in his notebook. He further stated that he recorded month-\nwise receipts and payments for reference and to compute his commission. He\nclarified that high-value entries pertained to land transactions of his clients\ncommunicated to him telephonically. Thus, according to the AO, the authorship\nof the notebook and its connection to the land dealings stood established

YCH LOGISTICS LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 944/Chny/2015 िनधा"रण वष"/Assessment Year:2010-11 M/S. Ych Logistics (India) Private The Deputy Commissioner Of Limited, Plot No. Dv1, Sipcot Hi-Tech Vs. Income Tax, Sez, Phase Ii, Sirumangadu Village, Corporate Circle 3(2), Sriperumbudur Taluk, Kancheepuram Chennai. District, Tamil Nadu 602 105. [Pan:Aaacy2873L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ajit Kumar Jain, Ca ""थ" की ओर से/Respondent By : Shri S. Palanikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 07.07.2022 घोषणा की तारीख /Date Of Pronouncement : 30.08.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Assessment Order Passed Under Section 143(3) R.W.S. 144C(5) Of The Income Tax Act, 1961 [“Act” In Short] Dated 14.01.2015 Relevant To The Assessment Year 2010-11. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Providing Logistics Services & Filed Its Return Of Income On 20.07.2011 For The Assessment Year 2010-11 Admitting Loss Of 2

transfer pricing wherever it is possible it is important to benchmark the AE transactions separately for a better comparability. The assessee may have many transactions viz., Sales, purchases loan, guarantee, etc., but combining them and studying under a single method would not be fit to call as "Most Appropriate Method". The term 'Most Appropriate method' is of high superlative language