STATE BANK OF INDIA,CHENNAI vs. ACIT TDS, CHENNAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1465/Chny/2024 िनधा"रण वष"/Assessment Year: 2015-16 State Bank Of India Vs. The Assistant Commissioner Of Industrial Finance Branch, Income Tax, 103, Mount Road, Chennai 600 002. Tds Circle 3(1), [Tan:Ches02510E] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. G. Vardini Karthik, Advocate (Virtual) ""थ" की ओर से/Respondent By : Shri N. Madan Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.04.2025 घोषणा की तारीख /Date Of Pronouncement : 27.06.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.03.2024 Passed By The Addl/Jcit(1)-1, Coimbatore For The Assessment Year 2015-16. 2. The Assessee Raised 17 Grounds Of Appeal, Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Confirming The Order Passed Under Section 201/201(1A) Of The Income Tax Act, 1961 [“Act” In Short] In The Facts & Circumstances Of The Case.

section 201(1) and 201(1A) of the Act. 9. Coming to the next aspect regarding the sequence of events and position after 24.06.2022 as discussed by the ld. CIT(A) in para 5.10 at page 15 of the impugned order, which is reproduced hereunder: 5.10 The sequence of events and position after 24-06-2002 is as under

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

REVATHIKUMAR SUDHA,CHENNAI vs. ACIT, NCW-19(1), CHENNAI

In the result the appeals of the assessee in ITA No

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकर अपीलसं./Ita Nos.: 304 & 305/Chny/2025 िनधा"रण वष" / Assessment Year: 2015-16 Revathikumar Sudha, Vs. The Assistant Commissioner Of 29, 3Rd Main Road, Thilaiganga Income Tax, Nagar, Chennai 600 061. Non Corporate Ward –19(1), Chennai. [Pan: Aztps-8926-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Both Dated 12.12.2024 Pertains To The Assessment Year 2015-16 Towards Quantum Addition As Well As Penalty Levied Under Section 271(1)(C) Of The Act.

TDS under section 194IA of the Act was to be deducted @1% which was not done by the assessee. Since the Assessing Officer satisfied that the income arised out of difference of stamp duty value and purchase consideration of immovable property chargeable to tax has escaped assessment, proceedings under section 147 of the Act was initiated by issuing notice under

REVATHIKUMAR SUDHA,CHENNAI vs. ACIT, NCW-19(1, CHENNAI

In the result the appeals of the assessee in ITA No

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकर अपीलसं./Ita Nos.: 304 & 305/Chny/2025 िनधा"रण वष" / Assessment Year: 2015-16 Revathikumar Sudha, Vs. The Assistant Commissioner Of 29, 3Rd Main Road, Thilaiganga Income Tax, Nagar, Chennai 600 061. Non Corporate Ward –19(1), Chennai. [Pan: Aztps-8926-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Both Dated 12.12.2024 Pertains To The Assessment Year 2015-16 Towards Quantum Addition As Well As Penalty Levied Under Section 271(1)(C) Of The Act.

TDS under section 194IA of the Act was to be deducted @1% which was not done by the assessee. Since the Assessing Officer satisfied that the income arised out of difference of stamp duty value and purchase consideration of immovable property chargeable to tax has escaped assessment, proceedings under section 147 of the Act was initiated by issuing notice under

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction

M/S. ARULMIGU EKAMBARANATHAR TEMPLE,KANCHIPURAM vs. ITO, WARD-2 (EXEMPTIONS), CHENNAI

In the result, the grounds of appeal raised by the assessee are allowed for statistical

Bench: Shri Ss Viswanethra Ravi & Shri Ratnesh Nandan Sahaym/S Arulmigu Ekambaranathar I.T.O., Temple, Vs. Ward-2 (Exemptions), No. 121, T.S. No. 2796, Ekambaranathar Mahatma Gandhi Road, Sannadhi St., Nungambakkam, Kanchipuram-631502. Chennai-600034. Pan No. Aaaja 1794 K Appellant/ Assessee Respondent/ Revenue

TDS return. Notice under Section 148 of the Income Tax Act, 1961 (in short, the Act) was issued to the assessee asking for filing return of income but in response of notice under Section 148 of the Act, the assessee has neither filed return of income nor reply has been submitted. Other statutory notices were issued by the Assessing Officer

JCR TRADERS,KEELAMATHUR vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1) TRICHY, TRICHY

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.333/Chny/2025 िनधा"रण वष"/Assessment Year: 2017-18 Jcr Traders, Vs. The Deputy Commissioner Of 2/117, Thittakudi Road, Income Tax, Keelamathur, Tamil Nadu 621 173. Circle 1(1), Trichy. [Pan:Aalfj6942K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Ms. Deeptha, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.04.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.08.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 93 Days. The Assessee Filed An Affidavit For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit

section 144 of the Act, but, however, there is no compliance to the above show-cause notice. The Assessing Officer, on examination of the return, noted that the assessee has debited expenses under the heard (i) audit fee of ₹.1,95,000/- and interest & finance charges at ₹.3,71,550/-, but, however, the assessee has not deducted TDS

IDUMBEN KNITTERS, ,TIRUPUR CHENNAI vs. ACIT, CIRCLE-1TIRUPUR, TIRUPUR, CHENNAI

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

Bench: Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 711/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Idumban Knitters Assistant Commissioner Of S.F. No. 440, 443, Sbi Colony, V. Income Tax, Gandhi Nagar Post, Circle-1, Tirupur – 641 603. Tirupur. [Pan: Aaafi-7635-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. M A Srinivasan, Fca ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 01.08.2023 घोषणा क" तारीख/Date Of Pronouncement : 11.08.2023

144 of Income Tax Act, 1961 on 03/09/2021 vide DIN NO: ITBA/AST/S/147/2021- :-3-: ITA. No:711/Chny/2023 22/1035283255(1), making addition of Rs.7,95,000/-, being 30% of Rs.26,50,000/-, paid to Mr.U.S.Dinesh, one of the employee of the appellant I assessee herein, for not complying with the TDS provisions u/s 194J, which have already been subjected to taxation, with

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

VENKATESAN RAVI,CHENNAI vs. ACIT NON CORPORATE CIRCLE-7(1), CHENNAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.2388/Chny/2019 िनधा"रण वष"/Assessment Year: 2011-12 Shri Venkatesan Ravi, Vs. The Assistant Commissioner Of 14A, Balu Nagar, Mogappair East, Income Tax, Chennai 600 037. Non Corporate Circle 7(1), Chennai – 34. [Pan:Adwpr8864L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V.S. Jayakumar, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 29.11.2022 घोषणा की तारीख /Date Of Pronouncement : 02.12.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 7, Chennai Dated 25.06.2019 Relevant To The Assessment Year 2011-12. 2. The Only Ground Raised By The Assessee Before The Tribunal Is That “The Assessing Officer Ought To Have Been Passed Assessment Order Under Section 153C Of The Income Tax Act, 1961 [“Act” In Short] & Not Under Section 144 R.W.S. 147 Of The Act. The Issue Raised

TDS credit as per Form 26AS. a) Issue of notice being issued u/s 147 of the Act and not u/s 153C thereby raising questions of legality of the assessment proceedings. Though both provisions of the Act, viz: Section 147 and Section 153C empower the A.O. to assessment and re-assessment the income escaped from assessment, both section are dealing with

BHURMAL GAUTHAMCHAND GANDHI,CHENNAI vs. ITO NON CORPORATE WARD 11 (4), CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 762/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 Shri Bhurmal Gautamchand Gandhi, The Income Tax Officer, No. 69, Godown Street, George Town, Vs. Non Corporate Ward 11(4), Chennai 600 001. Chennai. [Pan:Aafpj8748R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, C.A. ""थ" की ओर से/Respondent By : Shri G.Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 28.04.2021 घोषणा की तारीख /Date Of Pronouncement : 06.05.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 13, Chennai, Dated 22.09.2017 Relevant To The Assessment Year 2014-15. In The Grounds Of Appeal, The Assessee Has Challenged The Confirmation Of Assessment Order Passed Under Section 144 Of The Income Tax Act, 1961 [“Act” In Short].

TDS on the interest and rental payment as well as confirmation from the sundry creditors, the ld. CIT(A) confirmed the assessment order passed under section 144

A-ONE LEATHERS,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 4(1), CHENNAI, CHENNAI

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 4148/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 M/S. A-One Leathers, The Assistant Commissioner No.15/8, Vepery High Road, Vs. Of Income Tax, Periamet, Non-Corporate Circle 4(1), Chennai – 600 003. Chennai. Pan: Aaafa 4576H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri S. Anandh, Advocate ""यथ" क" ओर से/Respondent By : Shri Aroon Praasad, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 26.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 03.03.2026 आदेश/ O R D E R Per George George K: This Appeal Filed By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 14.10.2025 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2015-16. 2. The Grounds Raised Read As Follows:- :- 2 -:

section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2015-16. 2. The grounds raised read as follows:- :- 2 -: 1. The Order of National Faceless Appeals Centre is contrary to the law, facts and circumstances of the case and in any case violative of the principles of equity and natural justice