आयकर अपीलीय अिधकरण, ‘ए’ (cid:1)यायपीठ, चे(cid:9)ई।

IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: CHENNAI (cid:1)ी एबी टी. वक(cid:10), (cid:11)ाियक सद(cid:17) एव ं

(cid:1)ी एस. आर. रघुनाथा, लेखा सद(cid:9) के सम(cid:27)

BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI S.R.RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.1488 & 1489/Chny/2025 िनधा(cid:14)रण वष(cid:14)/Assessment Years: 2015-16 & 2016-17 Periyasamy Anbunathan, v. The DCIT, No.10/97C, Ayyampalayam, Central Circle-1(4), Thottakurichi Post, Chennai.

Karur-639 113.

[PAN: AHMPA 6511 H (अपीलाथ(cid:22)/Appellant) ((cid:23)(cid:24)यथ(cid:22)/Respondent)

आयकर अपील सं./ITA Nos.1529, 1536, 1595 & 1596/Chny/2025 िनधा(cid:14)रण वष(cid:14)/Assessment Years: 2014-15, 2017-18, 2015-16 & 2016-17 &

Cross-Objection Nos.45 & 46/Chny/2025 [in ITA Nos.1595 & 1596/Chny/2025]

िनधा(cid:14)रण वष(cid:14)/Assessment Years: 2015-16 & 2016-17 The DCIT, v. Periyasamy Anbunathan, Central Circle-1(4), No.10/97C, Ayyampalayam, Chennai. Thottakurichi Post, Karur-639 113.

[PAN: AHMPA 6511 H (अपीलाथ(cid:22)/Appellant) ((cid:23)(cid:24)यथ(cid:22)/Respondent/Cross Objector)

अपीलाथ(cid:13) की ओर से/ Assessee by : Mr.J.K. Reddy, CA (cid:17)(cid:18)थ(cid:13) की ओर से /Department by : Ms.E. Pavuna Sundari, CIT सुनवाईक(cid:28)तारीख/Date of Hearing : 29.10.2025 घोषणाक(cid:28)तारीख /Date of Pronouncement : 23.01.2026 आदशे / O R D E R PER BENCH:

These appeals preferred by the Revenue arise from the orders passed by the Learned Commissioner of Income Tax (Appeals)-18 (hereinafter referred to as ‘Ld.CIT(A)‘), Chennai, dated 29.03.2025 for Assessment Years (hereinafter referred to as ‘AY‘) 2014-15 to 2017-18 u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘). The assessee has preferred appeals and cross objections in relation to the order(s) passed by the Ld. CIT(A) for AYs 2015-16 & 2016-17.

2. Since issues involved are common, all the appeals for all the AYs were heard together. Both the parties also argued them together raising similar arguments on these issues. Accordingly, for the sake of convenience and brevity, we dispose all the appeals by this consolidated order.

3. Before we advert to the grounds taken in the cross-appeals, it would first be relevant to cull out the basic background facts of the case. Search was conducted u/s 132 of the Act upon the assessee on 22.04.2016 in the course of which, inter alia, six (6) account book(s) were found and seized vide ANN/FAY/CPA/B&D/S-1 and also cash of Rs.4.77 crores was found. When enquired regarding the contents of these account books, the assessee, in his statement u/s 132(4) of the Act had admitted that, these account books related to his real estate and finance commission business, and that the cash found was also generated in his own business, which was not shown in his books of accounts. In his subsequent statement dated 02.07.2016, the assessee was enquired about the monies received by several finance firms controlled by him, to which, he is found to have stated that, these were business loans taken by him from the entities of one Shri Parasmal Lodha [in short ‘PLA’] against his personal guarantee. Reading of his several statements recorded in the course of search and the post-search enquiries, it is seen that, the assessee had, at all times, maintained that, he was engaged in real estate & finance business and that, the account book(s) ID marked ANN/FAY/CPA/B&D/S-1 seized from his premises contained entries of his business activities. Thereafter, much later (after a gap of one year) on 03.04.2017, the assessee is noted to have been again summoned by the Revenue u/s 131 of the Act. In his statement recorded on 03.04.2017, the assessee is first noted to have partially retracted all his previous statement(s) and, this time around, he stated that, the account book(s) and the amounts mentioned against ‘RV’, ‘RV-I’, ‘RV-III’, ‘RV-IV’, ‘RV Gopi’, ‘RV Wife’ denoted one Shri Natham R Vishwanathan [in short ‘NRV’]. The assessee further stated