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

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)

unexplained money u/s.69A of the Act, since the assessee has not satisfactorily explained the source for payment made to SEBI as bid money for purchase of immovable property in auction. The ld.DR submitted that the Ld.CIT(A) erred in holding that the letter received from SEBI seized in the premises of assessee's father cannot be treated as incriminating material

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, 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

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

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

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

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

PALANISAMY RAGHYPATHY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

unexplained income in\nthe firm’s hands.\n With reference to the seized material provided by the\nDepartment during the course of hearing before the Hon’ble\nIncome Tax Appellate Tribunal, the assessee wishes to submit\nthat copy of seized material in “A-A3PP-1” as named in the Pen\nDrive given by the Department and referred in the Assessment

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

M/S. AMBATTUR DEVELOPERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(1), CHENNAI

In the result the appeal of the assessee is allowed

unexplained money\ninflows. In the instant case, neither the AO nor the Id.CIT(A) have held or alleged\nthat unaccounted money has been introduced by the Assessee. In fact, their\nonly case is that the figures adopted for the purpose of valuation is not\nacceptable to them. The major subscriber to the shares is the holding company\nAmbattur Clothing Limited

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

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. MS DAR PARADISE PVT. LTD., COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1106/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Dar Paradise Pvt. Ltd., Income Tax, V. 599, Raja Street, Corporate Circle -1, Coimbatore – 641 001. Coimbatore. [Pan: Aafcd-3066-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri. N. Arjun Raj, Ca सुनवाई क" तारीख/Date Of Hearing : 05.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 21.03.2024

price. All the trade advance have been transferred to Sales Account and formed part of the profit and loss account and offered for taxation. The moment they were shown as sales and offered as income, onus part is completely discharged. The appellant has further submitted that the total gold advances received before demonetization and which were converted into gold sales

SUNITHA,COIMBATORE vs. PCIT -1, COIM,BATORE

In the result, appeal filed by the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2013/Chny/2024 (िनधा"रणवष" / Assessment Year: 2018-2019) Sunitha, Vs. The Principal Commissioner Of No.30, Sivaji Colony, Income Tax -1, Thadagam Road, Coimbatore Edayarpalayam, Coimbatore 641 025. [Pan: Bhqps 4789G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N.V. Balaji, Advocate ""यथ" क" ओर से /Respondent By : Shri R. Clement Ramesh Kumar, Irs, Cit. सुनवाई क" तार"ख/Date Of Hearing : 26.11.2024 घोषणा क" तार"ख /Date Of Pronouncement : 10.12.2024 आदेश / O R D E R Per Manu Kumar Giri ()

money lender (Financial intermediation) and for the purpose of her business, the available funds were Rs.14.37 crores, whereas, the loans advanced to various parties was shown at Rs.43,26,46,526. Prima facie perusal of the submissions reveal that there is shortfall/unexplained amount of Rs.28,88,62,523 (Rs.43,26,46,526 - 14,37,84,003) in advancing the loans

MADHAN HUF,TRICHY vs. DCIT, CENTRAL CIRCLE-1, TRICHY

In the result the appeal of the assessee is allowed for statistical purpose

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 975/Chny/2023 िनधा"रणवष" / Assessment Year: 2015-16 Dcit/Acit, Madhan Huf, V. Central Circle 1, 284 Lawsons Road, Trichy. Cantonment, Trichy – 600 001. [Pan: Aaqhm-0598-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. N. Arjun Raj, Advocate ""यथ"क"ओरसे/Respondent By : Shri. N. Sanjay Gandhi, Jcit सुनवाई क" तारीख/Date Of Hearing : 11.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 04.09.2024 आदेश /O R D E R

transferred to Madan Mohan HUF at the time of registration. 2.4 The A.O. has issued a commission u/s 131. to the DCIT, Benami Prohibition Unit, Kolkata, to enquire about the genuineness of the transaction. The DCIT, BPU, Kolkata, has recorded the statement from one Shri Anand Kumar Sharma, Key Management Personnel, of Ms. Trinetra Real Estate

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

The appeals stand dismissed

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 by way of elaborate written submissions which have already\nbeen extracted in the impugned order. The assessee submitted