आयकर अपीलीय अिधकरण, ’A’ (cid:586)ायपीठ, चे(cid:580)ई IN THE INCOME-TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI (cid:373)ी एस.एस. िव(cid:695)ने(cid:361) रिव, (cid:586)ाियक सद(cid:735) एवं (cid:373)ी एस.आर. रगुनाथॎ, लेखा सद(cid:735) के सम(cid:407)

Before Shri S.S. Viswanethra Ravi, Judicial Member &

Shri S.R. Raghunatha, Accountant Member आयकर अपील सं./I.T.A. Nos. 1458, 1950 & 2889/Chny/2024 िनधा(cid:330)रण वष(cid:330)/Assessment Years: 2020-21, 2017-18 & 2012-13 The Deputy Commissioner of Vs. M/s. Sify Technologies Limited, Income Tax/ACIT, II Floor, Tidel Park No. 4, TTT1 Large Taxpayer Unit Circle 1, Taramani S.O., Taramani, Chennai. Chennai 600 113.

[PAN:AAACS9032R]

(अपीलाथ(cid:334)/Appellant) ((cid:366)(cid:529)थ(cid:334)/Respondent)

अपीलाथ(cid:334) की ओर से / Appellant by : Shri Shivanand K Kalakeri, CIT (cid:366)(cid:529)थ(cid:334) की ओर से/Respondent by : Shri S.P. Chidambaram, Advocate सुनवाई की तारीख/ Date of hearing : 13.03.2025 घोषणा की तारीख /Date of Pronouncement : 17.04.2025 आदेश /O R D E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER:

These three appeals filed by the Revenue are directed against separate orders dated 19.02.2024, 07.08.2023 & 08.08.2023 passed by the ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [NFAC], Delhi for the assessment years 2020-21, 2017-18 &

2012-13.

2. Since issues raised in these appeals are similar based on the same identical facts, with the consent of both the parties, we proceed to hear the appeals together and pass consolidated order for the sake of convenience.

3. First, we shall take appeal in I.T.A. No. 1458/Chny/2024 for AY

2020-21 for adjudication.

4. We find that this appeal is filed with a delay of 27 days. The Appellant-Revenue filed an affidavit for condonation of delay stating the reasons. Upon hearing both the parties and on examination of the said affidavit, we find the reasons stated by the Revenue are bonafide, which really prevented in filing the appeal in time. Thus, the delay is condoned and admitted the appeal for adjudication.

5. Ground No. 1 raised by the Appellant-Revenue is general in nature and requires no adjudication.

6. Ground No. 2 (2.1 & 2.2) raised by the Appellant-Revenue in challenging the action of the ld. CIT(A) in deleting the addition of ₹.6,00,000/- made on account of unearned income not offered for taxation in the facts and circumstances of the case.

7. At the outset, we note that the assessee company filed its return of income declaring income of ₹.98,53,74,050/- and the case of the assessee was selected for complete scrutiny. After examining the details furnished by the assessee against statutory notices, the Assessing Officer noted that the assessee has shown an amount of ₹.6,00,000/- as unearned income and not offered for taxation. The Assessing Officer asked the assessee to explain as to why the said amount should not be treated as income of the assessee for the current assessment year 2020- 21. After considering the submissions of the assessee and relying upon the assessment for AYs 2018-19, 2017-18 & 2016-17, the Assessing Officer added the unearned income of ₹.6,00,000/- to the total income of the assessee for taxation. On appeal, the ld. CIT(A), by following the decision of the ITAT in assessee’s own case for the assessment years 2012-13 to 2015-16 in ITA No. 1505, 1506 & 1507/Chny/2017 & ITA No. 2735/Chny/2018 vide order dated 06.09.2022 , deleted the addition made by the Assessing Officer. Not satisfied with the order of the ld. CIT(A), the Revenue is in appeal before the Tribunal.

8. The ld. DR Shri Shivanand K. Kalakeri, CIT relied on the order of the Assessing Officer.

9. The ld. AR Shri S.P. Chidambaram, Advocate drew our attention to the chart consisting summary of issues and relied on the order of the ld.

CIT(A).

10. Heard both the parties and perused the material available on record. In the assessment order, relying upon the assessment for AYs 2018-19, 2017-18 & 2016-17, the Assessing Officer added the unearned income