SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

gain is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect of sale of 2

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

gain is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect of sale of 2

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

gain is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect of sale of 2

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

127 taxmann.com 813 (Gujarat), the Hon'ble Gujarat High Court held that once debts were written off in books, it was to be allowed without expecting the assessee to prove that debts had actually become bad or they were recoverable or recovered in subsequent years. Head note of the decision is reproduced below: “Section 36(1)(vii) of the Income

DCIT, CC2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

127 taxmann.com 813 (Gujarat), the Hon'ble Gujarat High Court held that once debts were written off in books, it was to be allowed without expecting the assessee to prove that debts had actually become bad or they were recoverable or recovered in subsequent years. Head note of the decision is reproduced below: “Section 36(1)(vii) of the Income

IDFC FINANCIAL HOLDING COMPANY LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE-2(2), HENNAI

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

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

127 ITD 257 (MUM.) Torrential Investments (P.) Ltd. * v. Income-tax Officer, Ward2(3)(3), Mumbai Section 234C of the Income-tax Act, 1961 - Interest, chargeable as - Assessment year 199697 - Capital gains accrued to assessee on account of sale of an asset in months of May 1995 and July 1995 - It filed its return for assessment year 1996-97 showing

ABAN OFFSHORE LIMITED,CHENNAI vs. DCIT, INTL, TAX 1(1), CHENNAI

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

127 taxmann.com 169 High Court\nof Karnataka\n• Decision of Hon'ble Supreme Court in case of GE India\nTechnology Cen. (P.) Ltd. v. Commissioner of Income-tax Civil\nAppeal NOS. 7541-7778 OF 2010\n• Decision of Hon'ble Supreme Court in case of Sedco Forex\nInternational Inc. v. CIT; 87 taxmann.com 29 (SC)\n• Decision

RAMAKRISHNAN PRABHU JYOTHI,,COIMBATORE vs. ACOT, NCC-5, , COIMBATORE

In the result the appeal is dismissed

127 (Del.), held that the assesse had\nentered into an agreement of sale and made payments towards\npurchase consideration within one year of sale of his old flat. Relief u/s\n54 was found admissible though registration of sale deed was made\nsubsequently. The Tribunal held that exemption under section 54 was\navailable as substantial amount of cost of new house

SMT. LINGAMMAL RAMARAJU SHASTRA PRATHISHTA TRUST,RAJAPALAYAM vs. ACIT (EXEMPTIONS), COIMBATORE

In the result, the appeal stands allowed

capital\nexpenditure of Rs.5,56,722/-. The Ld AR accordingly submitted that, the\nfacts on record showed that, the entire surplus from the petrol bunk of\nRs.73,27,209/- had been applied towards the educational activities,\nnamely the music school and library activities of the assessee Trust. In\nlight of these facts, the Ld AR gave us a brief overview

M/S SHRIRAM PROPERTIES LIMITED,CHENNAI vs. PCIT-CENTRAL1, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 431/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

gain on extinguishment of liability and share premium is not a notional entries. He further submitted that, under the provisions of section 263 of the Act, if Assessing Officer not called for any information on the issues then it can be said that it is a case of lack of enquiry. In a case where the Assessing Officer called

LAGGISETTY MANOHAR KARTHIK,CHENNAI vs. ITO NON CORPORATE WARD 15(2), CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 746/Chny/2025 िनधा$रण वष$ / Assessment Year: 2012-13

Capital Gains in the hands of the assessee herein in the capacity of the individual would tantamount to double taxation. The Ld.AR insofar as the claim of deduction in terms of Section 54 of the Act, had argued that the documentary evidences filed before authorities were not considered in proper perspective inasmuch the assessee had substantiated the fact of creation

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

127 (SC) up to AY 2014-15, and thus, even if cost of ITA Nos.1632 to 1638/Chny/2023 :: 8 :: asset has been claimed as application of income, depreciation should be allowed for computing income from property held under Trust. 7. The Assessing Officer, after considering relevant submissions of the assessee and also taken note of factual findings noticed during the course

DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE-10, CHENNAI vs. ARUNCHALAM VEERAIAH, CHENNAI

In the result, the revenue's appeal is dismissed and allow the cross objection\nof the assessee

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri Jagadish\N\Nआयकर अपील सं./ Ita No.2320/Chny/2024\N& C.O.No.78/Chny/2024\N(In Ita No.2320/Chny/2024)\N(निर्धारणवर्ष / Assessment Year: 2011-2012)\N\Nthe Deputy Commissioner Of\Nincome Tax,\Ncorporate Circle 10,\Nchennai\N(Appellant)\Nvs. Arunchalam Veeraiah,\Nno.34, 14B, Beach Home Avenue,\Nbesant Nagar,\Nchennai 600 090.\N[Pan No.Aaipa 9044Q]\N(Respondent/Cross Objector)\N\Nassessee By\N: Shri S. Sridhar, Advocate\Nrevenue By\N: Shri. P.K. Senthil Kumar, Addl. Cit.\N\Nसुनवाई की तारीख/Date Of Hearing\N: 30.01.2025\Nघोषणा की तारीख / Date Of Pronouncement : 14.02.2025\N\Nआदेश / Order\N\Nmanu Kumar Giri ()\N\Nthe Appeal Of The Revenue & Cross Objection By The Assessee Are Arising\Nout Of The Order Dated 21.06.2024 Of The Commissioner Of Income Tax (Appeals),\Nnfac, Delhi (In Short The `Ld. Cit(A)"). The Assessment Order U/S 144 R.W.S 147 Of\Nthe Income Tax Act, 1961 (Hereinafter The 'Act'), Was Passed Vide Order Dated\N19.12.2019.\N\N2.\Nthe Registry Has Noted Delay Of 14 Days In Filing The Appeal By The Revenue.\Nconsidering Reasons Stated In The Affidavit By The Revenue, We Condone The Delay\Nand Admit The Appeal For Adjudication.\N\N3.\Ngrounds Of Appeal Filed By The Revenue Are As Under:\N\N\"1. The Order Of The Cit (A) Is Contrary To The Facts & Circumstances Of The Case\Nand Provisions Of Income Tax Act 1961.\N2. The Id. Cit (A) Erred To Hold That The Notice U/S 148 Was Sent For The Service\Nafter 10 Months Delay & Holding The Assessment Order Dated 19.12.2019 As Time\Nbarred.\N2.

capital gains on\nsale of property at Abhiramapuram in Paragraph 5.1 without assigning proper\nreasons and justification.\n7) The NFAC failed to appreciate that in any event, the entire re-computation of\nLTCG on various facets was wrong, incorrect, invalid and not sustainable both on\nfacts and in law.\n8) The Cross Objector/Assessee craves leave to file additional grounds