INCOME TAX OFFICER- WARD-1/JAO, NAGERCOIL vs. ARULANANDHAM BER SYRIL ANTOW, NAGERCOIL

In the result the appeal filed by the Revenue is dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

144B of the Act on 28.03.2022, making the following additions: i) Disallowance u/s.40(a)(ia) of Rs.2,68,449/- for alleged non-deduction of TDS on interest paid of Rs.8,94,831/- to M/s.Cholamandalam Finance Ltd. ii) Addition of Rs.10,18,03,600/- by treating sale of land situated at Villukuri Village, Kanyakumari District as taxable long-term capital gain

SIVASUNDAR SELVAKUMARI,CHENNAI vs. ITO, NCW-1(6), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

section 144B of the Income Tax Act, 1961 for the Assessment Year 2016-17 dated 16.03.2022. 2. The assessee raised the following grounds of appeal: 1. The CIT(A) erred in upholding the addition of Rs.19,86,16,459/- as Long Term Capital Gain

LOGANATHAN DHANDAPANI,CHENNAI vs. ACIT, NCC-3(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

THANARAJ SUMATHI,MAYILADUTHURAI vs. ITO, WARD-1,, KUMBAKONAM

In the result, appeal filed by the assessee is allowed

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2031/Chny/2025 यनिाारणवर्ा / Assessment Year:2019-20 Thanaraj Sumathi, Income Tax Officer, No.3/25, North Street, Vs. Ward-1 Moovalur, Kumbakonam. Mayiladuthurai – 609806. Tamil Nadu. [Pan:Knyps-1061-J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate. प्रत्यर्थीकीओरसे/Respondent By : Ms. R. Anitha, Cit. सुनवाईकीतारीख/Date Of Hearing : 13.10.2025 घोर्णाकीतारीख/Date Of Pronouncement : 14.10.2025

Section 144B of the Act with reference to making assessment or reassessment of total income or loss of assessee. Therefore, according to Ld AR, since the impugned notice u/s 148 dated 31.03.2022 has been issued by JAO and not by the NFAC, there is per-se contravention of the provisions of the Act, thus violating the principles of Rule

M/S. R.K. INVESTMENTS,CHENNAI vs. DCIT, NCC-3(1),, CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1159/Chny/2024 (िनधा*रणवष* / Assessment Year: 2014-15) M/S. R.K. Investments Dcit Ground Floor, Block-Iv, Non-Corporate Circle-3(1) बनाम/ No.184-187,Temple Steps, Chennai. Vs. Anna Salai Little Mount, Chennai-600 015. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaafr-3413-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan (Advocate)-Ld.Ar " थ"कीओरसे/Respondent By : Shri R. Clement Ramesh Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 31-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 12-08-2024 आदेश / O R D E R

144B of the Act on 28- 03-2022. The grounds taken by the assessee are as under: - 1. The Order of Principal Commissioner of lncome tax is contrary to law facts and circumstances of the case. 2. The PCIT erred in assuming jurisdiction in as much as the very issue whether the land transferred was agricultural land subject matter

S RAJASEKARAN,CHENNAI vs. DCIT, NCC-7(1), CHENNAI

In the result, the appeal of the assessee is partly allowed for statistical purposes, in the manner indicated above

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

144B of the Act dated 24.03.2025. 4. Aggrieved by the Order, the assessee prefers an appeal before the Ld.CIT(A), for deleting the additions made by the Assessing Officer. 5. The ld.CIT(A) has confirmed the addition of Interest capitalized claimed as cost out of long term capital gains to the tune of Rs.7,67,07,745/- along with amounts

LATE ABDULLAH ABDULMAJEED, REP. BY L/H,PUDUKKOTTAI vs. ITO, WARD-1,, PUDUKKOTTAI

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

Capital Gains' as provided under section 48 and this is the only\nmanner of understanding the words, 'income chargeable to tax under\nsection 149(1)(b) of I.T. Act.\n19. The contention of the Revenue that under section 149 what is required\nto be taken note of, is the 'income that has escaped assessment' being\nthe entirety of sale consideration

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

In the result, all the three appeals of the assessee stand allowed

Bench: Shri George George K & Shri S.R. Raghunatha

Gains of Business or Profession”, “Income from Other Sources”, :-3-: ITA. Nos:1859, 1860 & 1865/Chny/2025 including interest income. The assessee maintains regular books of account which are duly audited u/s.44AB of the Act, and the same have consistently accepted the trading results, including the Gross Profit (“GP”) in all prior years by the revenue. 4. A search and seizure action

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX , CHENNAI

In the result, all the three appeals of the assessee stand allowed

Gains of Business or Profession”, “Income from Other Sources”,\nincluding interest income. The assessee maintains regular books of account\nwhich are duly audited u/s.44AB of the Act, and the same have consistently\naccepted the trading results, including the Gross Profit (“GP”) in all prior years\nby the revenue.\n4. A search and seizure action u/s.132 of the Act was conducted

K V TEX FIRM,CHENNAI vs. ASST. COMMISSIONER OF INCOME TAX , CHENNAI

In the result, all the three appeals of the assessee stand allowed

Gains of Business or Profession”, “Income from Other Sources\",\nincluding interest income. The assessee maintains regular books of account\nwhich are duly audited u/s.44AB of the Act, and the same have consistently\naccepted the trading results, including the Gross Profit (“GP”) in all prior years\nby the revenue.\n4. A search and seizure action u/s.132 of the Act was conducted

VAIDYANATHAN KALAIVANI,CHENNAI vs. PCIT, CHENNAI

Appeal of the assessee stands dismissed

gains of business or profession\".\nFurther, section 56 of the Income-tax Act has also been amended to\nprovide that any compensation received or receivable by any person,\nwhether in the nature of revenue or capital, in connection with the\ntermination or the modification of the terms and conditions of any contract\nrelating to his employment shall be taxable under

MIHO KIKUCHI,THIRUVANNAMALAI vs. PCIT, CHENNAI

In the result, the appeal filed by the assessee is dismissed subject to above direction and modification in the order

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.: 1318/Chny/2024 िनधा"रण वष"/Assessment Year: 2015-16 Smt. Miho Kikuchi, The Principal Commissioner No.25, Chengam Road, Vs. Of Income Tax-8, Fourth Street, Chennai. Thiruvannamalai – 606 601. Pan: Bdepm 5316B (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Quadir Hoseyn, Advocate & Dr. L. Natarajan, Ca ""यथ" क" ओर से/Respondent By : Shri Nilay, Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 24.07.2024 घोषणा क" तारीख/Date Of Pronouncement : 26.07.2024 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Revision Order Passed By The Principal Commissioner Of Income Tax, Chennai -8 In Order No.Itba/Rev/F/Rev5/2023-24/1063189420 (1) Dated 22.03.2024. The Assessment Was Framed By The Addl./Joint/Deputy/Asst. Commissioner Of Income Tax/Income Tax Officer, National Faceless Assessment Centre, Delhi For The Assessment Year 2015-16 U/S.147 R.W.S 144B Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Vide Order Dated 27.03.2022. 2. The Only Issue In This Appeal Of Assessee Is Against The Revision Order Passed By Pcit U/S.263 Of The Act Revising The Assessment Framed By Ao Of National Faceless Assessment Centre Vide Order Dated 27.03.2022 U/S.147 R.W.S 144B Of The Act. For This Assessee Has Raised Various Grounds Which Are Factual, Argumentative & Exhaustive & Hence, Need Not Be Reproduced.

144B of the Act. For this assessee has raised various grounds which are factual, argumentative and exhaustive and hence, need not be reproduced. 3. The brief facts are that the assessee is an individual and Japanese nationality by birth and is a resident of India for the relevant assessment year 2015-16 relevant to financial year 2014- 15. The assessee

BADRI NARAYANAN,CHENNAI vs. ITO, NCW-2(1),, COIMBATORE

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

Bench: Shri George George Kand Shri Jagadishआयकर अपील सं./Ita No.: 1959/Chny/2024 िनधा"रण वष"/Assessment Year: 2016-17 Shri Badri Narayanan, The Income Tax Officer, A2, Aishwaryam Apartment, Vs. Non-Corporate Ward -2(1), Tansi Nagar, Coimbatore. Velachery, Chennai – 600 042. Pan: Afmpb 8640N (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. N.V. Krishnan, Advocate ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 11.12.2024 घोषणा क" तारीख/Date Of Pronouncement : 12.12.2024

section 250 of the Income Tax Act, 1961 (hereinafter called ‘the Act’). The relevant Assessment Year is 2016-17. 2. The assessee had filed four grounds. The assessee has also filed a petition dated 04.11.2024 for admission of additional grounds challenging the reopening of assessment. The ld.AR during the course of hearing did not press ground Nos.1

MONOTECH SYSTEMS LTD.,CHENNAI vs. DCIT, CORP. CIRCLE-4(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

144B of the Income-tax Act, 1961(hereinafter :-2-: ITA. No.:1021/Chny/2025 referred to as “the Act”) dated 30.03.2022, as well as the denial of the claim of bad debts written off in the P & L Account of the year amounting to Rs.4,34,44,057/- which was added to the to the total income of the impugned year

SANJJAY SAUMYHA,SALEM vs. PRINCIPAL CIT, COIMBATORE

The appeal stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.392/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2013-14) Mrs. Sanjjay Saumyha Pcit बनाम/ 251 A, Omalur Main Road, Swarnapuri, Coimbatore-1. Vs. Salem-636 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aeyps-0117-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri T. Banusekar (Advocate)-Ld. Ar " थ"कीओरसे/Respondent By : Dr. R. Mohan Reddy (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 15-10-2024 घोषणा की तारीख /Date Of Pronouncement : 05-11-2024 आदेश / O R D E R

section 14 7 r.w.s 144B, the Assessing Officer had mentioned that the Assessee had complied and replied to the notices on 31/08/2021 in Page no. 4 of the assessment order. 2. The Ld. AR advanced arguments and submitted that the case was reopened specifically to examine the issue as raised in the revisionary order. The Ld. AR stated that

INDIAN OVERSEAS BANK,CHENNAI vs. ACIT, NFAC, , DELHI

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

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1569/Chny/2024 िनधा"रण वष" / Assessment Year: 2019-20 Indian Overseas Bank, The Principal Commissioner Of 763, Anna Salai, V. Income Tax, Anna Road, Chennai -4, Chennai – 600 002. Chennai -600 034. [Pan: Aaaci-1223-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. C. Naresh, Ca : Shri. Nilay Baran Som, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 25.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 18.12.2024 आदेश /O R D E R Per S. R. Raghunatha:

gain shown on sales made to ARCs and whether the contribution made to PF/Superannuation fund was in contravention to Rule 87 of the Income Tax Rules. Therefore, the assessment order passed under section u/s 143(3) r.w.s. 144B dated 30.09.2021 by the Assessing Officer for the assessment year 2019-20 is considered to be erroneous and prejudicial to the interests

TIRUCHANGODU RAMASAMY KHANNAIYANN SARASUWATHI,COIMBATORE vs. DCIT, CENTRAL CIRCLE-1,, COIMBATORE

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

capital gains based on the stamp duty valuation. This deprived the assessee of the statutory right to contest the valuation before an independent authority. The violation of section 50C(2), being a procedural safeguard founded on principles of natural justice, renders the assessment unsustainable. ………. 28. In view of the above discussion, we hold that: i. The assessment order dated

QILIN SUPPORTERS,TIRUPUR vs. ITO, WARD-2(4), TIRUPUR

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1275/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Qilin Supporters Vs. The Income Tax Officer, 11, Kasturibai Street, Udumalpet, Ward 2(4), Tiruppur 642 126. Tirupur. [Pan: Aaafq2944D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. M. Subashri, Addl. Cit (Virtual) सुनवाई की तारीख/ Date Of Hearing : 20.11.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 07.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. The Ld. Ar Shri S. Sridhar, Advocate Drew Our Attention To The Additional Ground Raised Vide Letter Dated 22.09.2025 & Submits That The Issue Of Questioning The Reopening As Legal Ground Can Be Raised At Any 2

capital asset being land or building or both is less than the value adopted/assessed by any authority of the State Government is assessable under income from “Profits and Gains from business or profession”. Therefore, the argument of the ld. DR is not acceptable in contending that there is no difference between the provisions under section 50C and 43CA

M/S. CITY UNION BANK LTD.,,KUMBAKONAM vs. PCIT,, MADURAI

In the result, the appeal for A

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

144B of the Act on 19.04.2021. Therefore, the ld.ARs stated that the order is neither erroneous nor prejudicial to the interest of revenue. Further, the ld.ARs drew our attention to the page 17 of the impugned order, wherein the Ld.PCIT has recorded the details of the query raised and the response submitted by the assessee. 8. The Ld.ARs drew