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“Section 13(6)”

Section References (mined)Section 13Section 13(6)20 judgments

The decision most relied on for Section 13(6) is CIT v. Institute of Banking Personnel Selection (264 ITR 110), cited in 398 judgments on BharatTax.

Leading authorities on Section 13(6)

CIT v. Institute of Banking Personnel Selection
264 ITR 110 · 2003 · High Court
398
citing judgments

Depreciation is allowable on assets for which the cost has been fully allowed as an application of income under Section 11 in previous years, when computing the income of a charitable trust. Charitable trusts are also entitled to carry forward their deficit.

CIT v. Society of the Sisters of St. Anne
146 ITR 28 · 1984 · High Court
195
citing judgments

Depreciation claimed by a charitable trust on its assets is an allowable application of income for computing exemption under Section 11, and this does not constitute a double deduction.

Director of Income-tax (Exemption) v. Framjee Cawasjee Institute
109 CTR 463 · 1993 · High Court
191
citing judgments

A charitable trust is allowed to claim depreciation on its assets for computing its income, even if the capital expenditure incurred on acquiring those assets was treated as an application of income in the year of acquisition.

CIT v. Rajasthan & Gujarati Charitable Foundation Poona
402 ITR 441 · 2018 · Supreme Court
187
citing judgments

Depreciation is allowable as a deduction even if the expenditure for acquiring the capital asset was treated as application of income for charitable purposes. This does not constitute a double benefit.

Lissie Medical Institutions v. CIT
348 ITR 344 · 2012 · High Court
164
citing judgments

The Kerala High Court held that charitable institutions claiming exemption under Section 11 are not entitled to claim depreciation on assets used for charitable purposes, taking a view contrary to most other High Courts.

Kolhapur Canesugar Works Ltd. v. Union of India
2 SCC 536 · 2000 · Reported
117
citing judgments

Section 6 of the General Clauses Act, which preserves rights and liabilities under repealed statutes, does not automatically apply to a mere omission of a statutory provision unless the omitting enactment specifically provides for it, thereby affecting the continuation of pending proceedings.

CIT v. Market Committee, Pipli
330 ITR 16 · 2011 · High Court
113
citing judgments

A charitable trust can claim depreciation on assets when computing the income applied for charitable or religious purposes under Section 11 of the Income Tax Act, for assessment years prior to the introduction of Section 11(6). The restriction on claiming depreciation, as introduced by Section 11(6), is prospective from AY 2015-16.

CIT v. Paradise Holidays
325 ITR 13 · 2010 · High Court
104
citing judgments

Regularly maintained and audited books of account, free from auditor qualifications, are presumed correct. The Revenue bears the onus to prove specific defects or unreliability to justify rejecting such books under Section 145(3) or making additions.

Judgments citing Section 13(6)

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2922/KOL/2025[2022-23]Status: DisposedITAT Kolkata06 Mar 2026AY 2022-23

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER I.T.A

DCIT, CC-2(3), Kolkata vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2921/KOL/2025[2020-21]Status: DisposedITAT Kolkata06 Mar 2026AY 2020-21

Bench: SHRI RAJESH KUMAR (Accountant Member)

Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 148Section 250Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA SHRI RAJESH KUMAR, ACCOUNTANT MEMBER PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER I.T.A

DCIT, Circle-5(1), Kolkata vs. Hindusthan National Glass and Industrieslimited, Kolkata

In the result, the appeal of the Revenue is dismissed as being infructuous

ITA 338/KOL/2024[2011-12]Status: DisposedITAT Kolkata31 Dec 2025AY 2011-12

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 148ASection 14ASection 250

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would not have any jurisdiction to reopen the assessment

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 351/MUM/2024[2017-18]Status: DisposedITAT Mumbai30 Dec 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

that major amount under the head professional fee received is from Encorn Win Farms (India) Ltd. that the payer had, in response to section 13(6)notice admitted(Pg-53 of the PB)that it had not paid any amount to the assessee, that it also ascertained that no professional

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income Tax, Circle 16(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 350/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Dec 2025AY 2013-14

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

that major amount under the head professional fee received is from Encorn Win Farms (India) Ltd. that the payer had, in response to section 13(6)notice admitted(Pg-53 of the PB)that it had not paid any amount to the assessee, that it also ascertained that no professional

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 320/MUM/2024[2015-16]Status: DisposedITAT Mumbai30 Dec 2025AY 2015-16

Bench: Shri Amit Shukla & Shri Girish Agrawal

For Appellant: Shri P.J. Pardiwala, Sr. AdvocateFor Respondent: Shri Krishna Kumar Sr. DR
Section 143(3)Section 37(1)Section 40

that major amount under the head professional fee received is from Encorn Win Farms (India) Ltd. that the payer had, in response to section 13(6)notice admitted(Pg-53 of the PB)that it had not paid any amount to the assessee, that it also ascertained that no professional

DCIT, CC-2(3), Kolkata, Aayakar Bhawan Poorva vs. Maxcab Industries Pvt. Ltd., Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 2590/KOL/2024[2021-22]Status: DisposedITAT Kolkata16 Oct 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Sonjoy Sarma, Jm Dcit, Central Circle-2(3), Maxcab Industries Pvt. Ltd. 4Th Floor, 110 Shantipally, 67/C, Balaram Dey Street, E.M. Bypass, Vs. West Bengal-700006 West Bengal-700107 (Appellant) (Respondent) Pan No. Aancm1997Q Assessee By : Shri Soumitra Choudhury & Ms. Nandini Surekh, Shri Pranabesh Sarkar, Ars Revenue By : Praveen Kishore, Dr Date Of Hearing: 04.09.2025 Date Of Pronouncement: 16.10.2025

For Appellant: Shri Soumitra Choudhury &For Respondent: Praveen Kishore, DR
Section 131Section 132(1)Section 133(6)Section 133ASection 143(1)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI SONJOY SARMA, JM DCIT

Deputy Commissioner of Income Tax, Central Circle-2(3), Kolkata, Aayakar Bhawan Poorva vs. Dailmer Industries Private Limited, Kolkata

In the result, the appeal of the Revenue is dismissed

ITA 276/KOL/2025[2021-22]Status: DisposedITAT Kolkata25 Jul 2025AY 2021-22

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dy. Commissioner Of Income Dailmer Industries Private Tax, Central Circle-2(3), Limited 4Th Floor, Room No. 403, 67/C, Balaram Dey Street, Vs. Kolkata-700107, West Bengal Kolkata-700006, West Bengal (Appellant) (Respondent) Pan No. Aabcd0836D Assessee By : S/Shri Soumitra Choudhury & Nirav Sheth, Ars Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 20.05.2025 Date Of Pronouncement: 25.07.2025

For Appellant: S/Shri Soumitra Choudhury &For Respondent: Shri Raja Sengupta, DR
Section 132(1)Section 132(4)Section 133(6)Section 133ASection 143(1)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM

DCIT, Central Circle 2(2), Kolkata vs. M/S. Ultratech Nathdwara Cement Ltd. (Known As M/S. Binani Cement Ltd.), Kolkata

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 470/KOL/2018[2013-14]Status: DisposedITAT Kolkata28 May 2025AY 2013-14

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would I.T.A. Nos.: 1726/KOL/2014 & 152/KOL/2018 Assessment Years

M/S. Ultratech Nathdwara Cement Ltd.(Formerly Known As M/S. Binani Cement Ltd., Kolkata vs. DCIT, Central Circle - 2(2), Kolkata

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 152/KOL/2018[2013-14]Status: DisposedITAT Kolkata28 May 2025AY 2013-14

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would I.T.A. Nos.: 1726/KOL/2014 & 152/KOL/2018 Assessment Years

ACIT, Cir-14(1), Kolkata vs. M/S. Ultratech Nathdwara Cement Ltd.(Known As M/S Binani Cement Ltd.), Kolkata

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 611/KOL/2015[2010-2011]Status: DisposedITAT Kolkata28 May 2025AY 2010-2011

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would I.T.A. Nos.: 1726/KOL/2014 & 152/KOL/2018 Assessment Years

Binani Cement Ltd., Mumbai vs. D.C.I.T., Central Circle-Xxviii, Kolkata

In the result, all the appeals of the Revenue as well as the assessee are dismissed as infructuous

ITA 1726/KOL/2014[2008-2009]Status: DisposedITAT Kolkata28 May 2025AY 2008-2009

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115JSection 154Section 234BSection 234CSection 250Section 801ASection 92C

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would I.T.A. Nos.: 1726/KOL/2014 & 152/KOL/2018 Assessment Years

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax-16(2), Mumbai

ITA 292/MUM/2024[2014-15]Status: DisposedITAT Mumbai04 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 37(1)Section 40

that major amount under the head professional fee received is from Encorn Win Farms (India) Ltd.,that the payer had, in response to section 13(6)notice,admitted(Pg-53 of the PB)that it had not paid any amount to the assessee, that it also ascertained that no professional

Deloitte Haskins and Sells LLP, Mumbai vs. Assistant Commissioner of Income-Tax - 11(2), Mumbai

ITA 291/MUM/2024[2010-11]Status: DisposedITAT Mumbai04 Feb 2025AY 2010-11

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 37(1)Section 40

that major amount under the head professional fee received is from Encorn Win Farms (India) Ltd.,that the payer had, in response to section 13(6)notice,admitted(Pg-53 of the PB)that it had not paid any amount to the assessee, that it also ascertained that no professional

Deloitte Haskins and Sells LLP, Mumbai vs. Joint Range- 11(2), Mumbai

ITA 289/MUM/2024[2011-12]Status: DisposedITAT Mumbai04 Feb 2025AY 2011-12

Bench: Shri Saktijit Dey & Ms Padmavathy S, Am

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Krishna Kumar, Sr. DR
Section 37(1)Section 40

that major amount under the head professional fee received is from Encorn Win Farms (India) Ltd.,that the payer had, in response to section 13(6)notice,admitted(Pg-53 of the PB)that it had not paid any amount to the assessee, that it also ascertained that no professional

Vashisth Builders and Engineers Pvt. Ltd., New Delhi vs. DCIT, Circle- 26(1), New Delhi

In the result, the appeal filed by the assessee is partly allowed

ITA 6934/DEL/2018[2012-13]Status: DisposedITAT Delhi11 Oct 2024AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Sudhir Pareek, Judicialmember Vashisth Builders & Engineers Pvt. Ltd., Vs. Dcit, Circle-26(1), A-52, 2Nd Floor, Fiee Complex, New Delhi Okhla Industrial Area, Phase-2, New Delhi. (Pan: Aabcv3687L) (Appellant) (Respondent) Assessee By : Dr. Rakesh Gupta, Advocate Revenue By : Shir Vivek K. Upadhyay, Sr. Dr. Date Of Hearing : 27.08.2024 Date Of Order : 11.10.2024 O R D E R Per S. Rifaur Rahman, Am : 1. This Appeal Is Filed By The Assessee Against The Order Of The Ld. Commissioner Of Income Tax (Appeals-10), New Delhi Dated 13.08.2018 For The Assessment Year 2012-13. Aggrieved With The Above Order, Assessee Is In Appeal Before Us By Raising Following Grounds Of Appeal :- I) The Ld. Cit(A) Has Erred In Law & On Facts In Upholding The Assessment Order Passed By The Deputy Commissioner Of Income Tax, Circle 26(1), New Delhi Under Section 143(3) Of The Act, By Making An Addition Of Rs. 7,23,72,000/- Without Appreciating The Facts & 2 Circumstances Of The Case, The Law As Applicable & The Submissions & The Supporting Evidence Produced By The Appellant. Ii) The Ld. Cit(A) Has Erred In Law & On Facts In Upholding The Disallowance / Addition Of Rs. 3,72,000/- Made By The Dcit As Notional Interest On Interest Free Loans Granted By The Appellant Out Of The Interest Expense Claimed By The Appellant Without Appreciating The Facts & Circumstances Of The Case, The Law As Applicable & The Submissions & The Supporting Evidence Produced By The Appellant. Iii) The Ld. Cit(A) Has Erred In Law & On Facts In Upholding The Addition Of Rs. 7,20,000/- Made By The Dcit By Treating The Share Capital Received By The Appellant During The Year As Unexplained Cash- Credit, Without Appreciating The Facts & Circumstances Of The Case, The Law As Applicable & The Submissions & The Supporting Evidence Produced By The Appellant.

For Appellant: Dr. Rakesh Gupta, AdvocateFor Respondent: Shir Vivek K. Upadhyay, Sr. DR
Section 143(3)

0IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “G”, NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

Mcnally Sayaji Engineering Limited, Kolkata vs. DCIT, Circle - 1(1), Kolkata

In the result, both the appeals are dismissed

ITA 899/KOL/2018[2009-10]Status: DisposedITAT Kolkata03 Oct 2024AY 2009-10

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2013-14 Mcnally Sayaji Engineering Deputy Commissioner Of Limited, Income Tax, Circle 1(1), Ecospace, Campus 2B, 11F/12 Aayakar Bhavan, P-7, (Old Plot No. Aa Ii/Blk 3), Chowringhee Square, Vs New Town, Rajarhat, Kolkata - 700069 North 24 Paragans, Kolkata - 7000156 (Pan: Aaccs5491A) (Appellant) (Respondent) Present For: Appellant By : Shri Abhishek Sureka, Ar Respondent By : Shri Rakesh Kumar Das, Cit, Dr Shri Vineet Kumar, Addl. Cit, Sr. Dr Date Of Hearing : 08.07.2024 Date Of Pronouncement : 03.10.2024 O R D E R Per Rakesh Mishra: These Two Appeals Filed By The Assessee Are Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax, Kolkata-I, Kolkata (Hereinafter Referred To As “The Ld. Cit”) Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ays 2009-10 & 2013- 14, Dated 28.02.2018 & 13.03.2018 Respectively. Both The Appeals Were Heard Together & Are Being Disposed Of Vide This Common Order For The Sake Of Brevity & Convenience. Mcnally Sayaji Engineering Limited.: Ays: 2009-10 & 2013-14 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Abhishek Sureka, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 234CSection 250Section 37Section 40

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would not have any jurisdiction to reopen the assessment

Mcnally Sayaji Engineering Limited, Kolkata vs. DCIT, Circle - 1(1), Kolkata

In the result, both the appeals are dismissed

ITA 1145/KOL/2018[2013-14]Status: DisposedITAT Kolkata03 Oct 2024AY 2013-14

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2009-10 & Assessment Year: 2013-14 Mcnally Sayaji Engineering Deputy Commissioner Of Limited, Income Tax, Circle 1(1), Ecospace, Campus 2B, 11F/12 Aayakar Bhavan, P-7, (Old Plot No. Aa Ii/Blk 3), Chowringhee Square, Vs New Town, Rajarhat, Kolkata - 700069 North 24 Paragans, Kolkata - 7000156 (Pan: Aaccs5491A) (Appellant) (Respondent) Present For: Appellant By : Shri Abhishek Sureka, Ar Respondent By : Shri Rakesh Kumar Das, Cit, Dr Shri Vineet Kumar, Addl. Cit, Sr. Dr Date Of Hearing : 08.07.2024 Date Of Pronouncement : 03.10.2024 O R D E R Per Rakesh Mishra: These Two Appeals Filed By The Assessee Are Against The Two Separate Orders Of The Ld. Commissioner Of Income Tax, Kolkata-I, Kolkata (Hereinafter Referred To As “The Ld. Cit”) Passed U/S 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For Ays 2009-10 & 2013- 14, Dated 28.02.2018 & 13.03.2018 Respectively. Both The Appeals Were Heard Together & Are Being Disposed Of Vide This Common Order For The Sake Of Brevity & Convenience. Mcnally Sayaji Engineering Limited.: Ays: 2009-10 & 2013-14 2. The Grounds Of Appeal Raised By The Assessee Are Reproduced As Under:

For Appellant: Shri Abhishek Sureka, ARFor Respondent: Shri Rakesh Kumar Das, CIT, DR
Section 234CSection 250Section 37Section 40

Cylinders Ltd. v. Deputy Commissioner of Income-tax [2024] 165 taxmann.com 332 (Gujarat) that when the NCLT has approved the application filed under section 13(6) of IBC, 2016 and resolution plan submitted by the applicant was approved, the Assessing Officer would not have any jurisdiction to reopen the assessment

Maruti Koatsu Cylinder Limited, Halol, Panchmahal vs. Dy.CIT., Circle-2(1)(2), Baroda

In the result, the appeal of the assessee is dismissed as infructuous

ITA 630/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad18 Sept 2024AY 2013-14

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

For Appellant: Shri S.N. Divetia &For Respondent: Smt. Mamta Singh, Sr. D.R
Section 13(6)Section 143(3)Section 250Section 40Section 43B

addition/disallowance made by the Assessing Officer. As all the claims of the government including that particular income tax department stands extinguished as per section 13(6) of IBC, 2016. Hence, the CIT(A) is not justified in confirming the addition/disallowance. Thus, the appeal of the I.T.A No. 630/Ahd/2023

Vip City, Chennai vs. DCIT, CC-2(2), Chennai

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1711/CHNY/2024[2017-18]Status: DisposedITAT Chennai11 Sept 2024AY 2017-18

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1711/Chny/2024 िनधा"रण वष" / Assessment Year: 2017-18 Vip City, Dcit, 141 Lakshmi Street, V. Central Circle -2(2), Janaki Nagar, Chennai. Valasarvakkam, Chennai – 600 087. [Pan: Aahfv-9469-K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. G. Tarun, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/Date Of Hearing : 04.09.2024 घोषणा की तारीख/Date Of Pronouncement : 11.09.2024

For Appellant: Shri. G. Tarun, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 13(6)Section 139(1)Section 144Section 148Section 69A

आयकर अपीलीय अिधकरण, ‘ बी ’ "यायपीठ, चे"ई IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI "ी एस एस िव"ने