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

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

(cid:1)ी अिमताभ शु(cid:24)ा, लेखा सद(cid:9) के सम(cid:27)

BEFORE SHRI ABY T. VARKEY, JUDICIAL MEMBER AND SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.1251 & 1252/Chny/2025 &

Cross-Objection Nos.43 & 44/Chny/2025 िनधा(cid:14)रण वष(cid:14)/Assessment Years: 2021-22 & 2022-23 The DCIT, v. Jayapriya Company, Central Circle-2(2), 37, Sivavishnu Complex, Chennai. II Floor, T. Nagar H.O, Chennai-600 017.

[PAN: AAHFJ 0958 M (अपीलाथ(cid:22)/Appellant) ((cid:23)(cid:24)यथ(cid:22)/Respondent/Cross-

Objector)

Department by : Mrs. Yamuna, CIT Assessee by : Mr.G. Baskar, Advocate सुनवाईक(cid:28)तारीख/Date of Hearing : 16.07.2025 घोषणाक(cid:28)तारीख /Date of Pronouncement : 12.09.2025 आदशे / O R D E R PER ABY T. VARKEY, JM:

These appeals preferred by the Revenue and the cross-objections of the assessee are against the orders passed by the Learned Commissioner of Income Tax (Appeals)-19, (hereinafter referred to as ‘Ld. CIT(A)‘), Chennai, both dated 12.02.2025, for the Assessment Years (hereinafter Jayapriya Company referred to as ‘AY‘) 2021-22 & 2022-23 u/s. 250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act‘)

2. Since the issues involved in both these appeals are common, they 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 both these appeals by this consolidated order.

3. The background facts are that, the assessee is a partnership firm which was formed on 01.04.2009. The assessee is carrying on several businesses inter alia including the business of real estate under the name & style of M/s Jayapriya Property Developers. The assessee firm is also involved in the business of money lending which is carried out in the name & style of M/s Jayapriya Financiers. The assessee also operates a guest house and theatre by the name of M/s Jayapriya Guest House and M/s Jayapriya Theatre respectively. A search action u/s 132 of the Act was conducted upon the assessee on 16.12.2021 in the course of which, several incriminating material concerning the unaccounted income generated from real estate business and unaccounted payments made for purchase of lands was found. Before the AO, the assessee vide letter Jayapriya Company dated 14.03.2022 is found to have quantified and offered to tax the following additional income across AYs 2013-14 to 2022-23:

4. The AO in the assessment order(s) is noted to have extensively examined the electronic data found from cloud server and material seized from the several premises of the assessee. Upon such examination, the AO found the quantification of the above additional income offered by the assessee to be in order. Upon being questioned as to whether the above additional income had been offered to tax, the assessee explained that the same was considered and offered to tax in the returns of income filed u/s 147 of the Act for AYs 2013-14 to 2020-21, which are noted to be as follows:-

Jayapriya Company

5. The assessee further demonstrated before the AO that, the additional income offered qua AYs 2021-22 & 2022-23 were appropriately incorporated in the financial statements and disclosed in the return(s) of income filed u/s 139 of the Act subsequent to completion of the search. The AO is found to have examined the details furnished by the assessee and recorded a categorical finding that, the assessee had disclosed the suppressed business income unearthed during the course of search across the AYs, as tabulated earlier above. The AO accordingly did not make any further addition/disallowance in this regard.

6. The AO is noted to have made disallowances/ additions on account of bad debts u/s 36(1)(vii) of the Act, interest expenditure u/s 36(1)(iii) of the Act, short credit of interest income etc. in AYs 2021-22 & 2022-23,