IL&FS TAMILNADU POWER COMPANY LTD,CHENNAI vs. DCIT CORP CIRCLE 1(1), CHENNAI

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1332/Chny/2024, Assessment Years: 2018-19 आयकर अपील सं./Ita No.1694/Chny/2024, Assessment Years: 2018-19 Il & Fs Tamil Nadu Power Company Deputy Commissioner Of Income Limited, Tax, Old No.21, New No.2, Kpr Tower, Corporate Circle-1(1), 4Th Floor, Greams Road, Chennai S.O, Nungambakkam Chennai-600 006. [Pan: Aabcf1176A] आयकर अपील सं./Ita No.1694/Chny/2024, Assessment Years: 2018-19 Deputy Commissioner Of Income Il & Fs Tamil Nadu Power Company Tax, Limited, Corporate Circle-1(1), Old No.21, New No.2, Kpr Tower, Chennai 4Th Floor, Greams Road, S.O, Nungambakkam Chennai-600 006. [Pan: Aabcf1176A] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri.Ashwin, Ca प्रत्यर्थी की ओर से /Revenue By : Shri Shivanand K Kalakeri, Cit सुनवाई की तारीख/Date Of Hearing : 26.03.2025 घोषणा की तारीख /Date Of Pronouncement : 25.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

capital asset under this section shall, in respect of so much of the sum specified in the contract as is available for discharging the liability aforesaid, be computed with reference to the rate of exchange specified therein.] 7.5.2. Whereas Sec.43AA talks about all other situations of foreign exchange fluctuation and its taxation. This section was inserted by the Finance

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. IL AND FS TAMILNADU POWER COMPANY LIMITED, CHENNAI

In the result, the appeal of the revenue is partly allowed for\nstatistical purposes

capital asset under this section shall, in respect of so much of the sum\nspecified in the contract as is available for discharging the liability aforesaid, be\ncomputed with reference to the rate of exchange specified therein.]\n7. 5. 2. Whereas Sec.43AA talks about all other situations of foreign exchange\nfluctuation and its taxation. This section was inserted

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

section 47(xiv) of the Act.\n64. Per contra, the Ld.DR submitted that there is no dispute with regard to\nthe fact that the assessee transferred his sole proprietorship concern to the\ncompany and that the assessee held 61% shareholding in the said company,\nas duly noted by the AO in the assessment order. It was further submitted that\nthe

ACIT CORPORATE CIRCLE 4(1), CHENNAI vs. MANGAL TIRTH ESTATE LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 1965/Chny/2018 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of M/S. Mangal Tirth Estate Ltd., Income-Tax, V. No. 769, Spencer Plaza, Corporate Circle-4(1), Anna Salai, Chennai – 600 002. Chennai. [Pan: Aaacm-4614-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By : Shri. N.V. Balaji, Advocate सुनवाई क" तारीख/Date Of Hearing : 29.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 31.01.2023

section 50C of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) and adopted deemed consideration for computation of long term capital gains. The relevant findings of the AO are as under: From the above noting the following points emerged : 1. As on 31.03.1999, Out of 1,50,000 sq.ft. the assessee company had handed over

SOCKALINGAM (HUF),MADURAI vs. ACIT, CIRRCLE - 1, MADURAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1849/Chny/2024 िनधा"रणवष" / Assessment Year: 2013-14 Assistant Commissioner Of Sockalingam (Huf), V. Income Tax, Plot No.423, Kk Nagar East, Circle -1, 9Th Street, Madurai – 625 020. Madurai. [Pan: Aaxhs-5962-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. T. Vasudevan, Advocate ""यथ"क"ओरसे/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 06.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.02.2025 आदेश /O R D E R

section 50C from the A.Y.2021-22, so as to enhance the tolerance band from 5% to 10%. Therefore, the said proviso is not applicable in this :-6-: ITA. No:1849/Chny/2024 case." Thus, the Assessment Unit re-computed the capital gains and made the addition of Rs.82,69,145

S.ARJUN,CHENNAI vs. ACIT NON CORPORATE WARD 20(1), CHENNAI

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

145 of the 1961 Act, which read as follows : " 28. Profits and gains of business or profession.—The following income shall be chargeable to Income-tax under the head ' Profits and gains of business or profession' :— (i) the profits and gains of any business or profession which was carried on by the assessee at any time during the previous year

DCIT, CHENNAI vs. ACCEL LIMITED, CHENNAI

In the result, the appeal of the assessee is allowed for 38

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

145, 146 & 147/Mds/2015 "नधा"रण वष" /Assessment year : 2002-03, 2005-06, 2007-08 & 2008-09 M The Deputy Commissioner of Vs. M/s. Accel Limited, Income Tax III floor, Accel House, Company Circle 1(1) 75, Nelson Manickam Road, Chennai. Aminjikarai, Chennai 600 029. [PAN AAACA 3042P ] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee by : Shri. S.T. Prabhu, Director Department by : Shri

ACCEL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed for 38

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

145, 146 & 147/Mds/2015 "नधा"रण वष" /Assessment year : 2002-03, 2005-06, 2007-08 & 2008-09 M The Deputy Commissioner of Vs. M/s. Accel Limited, Income Tax III floor, Accel House, Company Circle 1(1) 75, Nelson Manickam Road, Chennai. Aminjikarai, Chennai 600 029. [PAN AAACA 3042P ] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee by : Shri. S.T. Prabhu, Director Department by : Shri

ACCEL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed for 38

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

145, 146 & 147/Mds/2015 "नधा"रण वष" /Assessment year : 2002-03, 2005-06, 2007-08 & 2008-09 M The Deputy Commissioner of Vs. M/s. Accel Limited, Income Tax III floor, Accel House, Company Circle 1(1) 75, Nelson Manickam Road, Chennai. Aminjikarai, Chennai 600 029. [PAN AAACA 3042P ] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee by : Shri. S.T. Prabhu, Director Department by : Shri

ACIT, CHENNAI vs. MANSI FINANCE CHENNAI LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri Duvvuru R.L. Reddy

section 2(13) but the expression adventure in the nature of trade has not been defined in the Act. It may be pertinent to mention here that a specific (iii) transaction partake the character of business or an adventure in the nature of trade or realization of capital asset or a mere conversion of asset has to be decided depending

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

gains tax. 7. Per Contra, ld.CIT-DR stating that the brand value was created in the books of accounts of the partnership firm as on 30.04.2008 and this firm was converted into a Public Ltd. Co. i.e. the assessee company. He stated that the so called brand value was never existed in the books of the partnership firm V.V.Vanniaperumal & Sons