आयकर अपील(cid:9)य अ(cid:10)धकरण, ‘बी’ (cid:14)यायपीठ, चे(cid:14)नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI (cid:21)ी जॉज (cid:24) जॉज (cid:24) के , उपा(cid:26)य(cid:27) एव ं (cid:21)ी एस.आर.रघुनाथा, लेखा सद%य के सम(cid:27) BEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND SHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.:1628/Chny/2025 ’नधा(cid:24)रण वष (cid:24) / Assessment Year: 2013-14 ACIT, Maragathamani Shanmugam, Central Circle -2, vs. 54A, Muthu Nagar, Trichy. Sengunthapuram, Karur – 639 002.

[PAN:ABKPS-2816-H]

(अपीलाथ)/Appellant) (*+यथ)/Respondent)

आयकर अपील सं./ITA No.:1629/Chny/2025 ’नधा(cid:24)रण वष (cid:24) / Assessment Year: 2013-14 ACIT, Ramasamy Moolimangalam Central Circle -2, vs. Vaishnava Priya, Trichy. 33, B7 Adhisri Apartments, Kothari Road, Nungambakkam, Chennai – 600 034.

[PAN:ADWPV-0050-A]

(अपीलाथ)/Appellant) (*+यथ)/Respondent)

आयकर अपील सं./ITA No.:1631/Chny/2025 ’नधा(cid:24)रण वष (cid:24) / Assessment Year: 2013-14 ACIT, Karuppanna Gounder Palaniappa Central Circle -1, vs. Gounder Mariappan, Trichy. No.1, 80 Feet Road, Sengunthapuram, Karur – 639 002.

[PAN:AGPPM-2363-M]

(अपीलाथ)/Appellant) (*+यथ)/Respondent)

अपीलाथ) क, ओर से/Appellant by : Shri. Shiva Srinivas, C.I.T.

*+यथ) क, ओर से/Respondent by : Shri. R. Venkata Raman, C.A.

सुनवाई क, तार(cid:9)ख/Date of Hearing : 11.11.2025 घोषणा क, तार(cid:9)ख/Date of Pronouncement : 20.01.2026 आदेश /O R D E R PER S. R. RAGHUNATHA, AM:

These three appeals filed by the Revenue are directed against the respective orders of the Learned Commissioner of Income Tax (Appeals)-19, Chennai [hereinafter referred to as “the Ld. CIT(A)”], arising out of the assessments framed u/s.143(3) r.w.s 153A of the Income-tax Act, 1961 [hereinafter referred to as “the Act”], pertaining to the Assessment Year 2013- 14. Since the issues involved in all the three appeals are common and identical, these appeals were heard together and are being disposed of by this consolidated order for the sake of convenience. The details of the appeals preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

preferred by the Revenue are as under:

2. We find that the aforesaid appeals (ITA Nos.1628 & 1629/Chny/2025) are filed with a delay of 3 days. The AO filed affidavits for condonation of delay stating the reasons for belated filing of the appeals. On hearing both the parties and on examination of the said affidavits, we find the reasons stated by the Revenue are bonafide and no latches can be attributed to them. Hence, the delay of 3 days in filing the appeals are condoned and the cases are adjudicated on merits.

3. With the consent of both the parties, the Revenue’s appeal in ITA No.1629/CHNY/2025 is taken up as the lead case. Our findings recorded, reasons assigned, and adjudication rendered herein shall, mutatis mutandis, apply with equal force to the Revenue’s appeals in ITA Nos.1631 and

1628/CHNY/2025.

ITA No.1629/CHNY/2025

4. The Revenue has raised the following grounds of appeal:-

1. The order of the learned Commissioner of Income Tax (Appeals) is erroneous on facts of the case and in law.

2. The Ld.CIT(A) erred in deleting the addition made on account of unexplained investment for AY 2013-14 as the sources for the said advances remained unexplained u/s.69 of the Act.

3. The Ld.CIT(A) erred in allowing the appeal of the assessee on the issue of jurisdiction u/s 153A without appreciating the provisions of Section 153A(1) of Income Tax Act, 1961, as amended by Finance Act, 2017 (vide circular no.2/2018); Para No.80.4 of the circular clearly states which are the years covered by the new amendment.

4. For these grounds and any other ground including amendment of grounds that ma