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

MURUGAN DORAISAMY,CHENNAI vs. ITO, INTERNATIONAL TAXATION WARD-1(2), CHENNAI

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.367/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Murugan Doraisamy, Vs. The Income Tax Officer, 16, 17 & 18, Appasamy Towers, International Taxation Ward 1(2), Sir Thiyagaraya Road, Pondy Bazaar, Chennai. T. Nagar, Chennai 600 017. [Pan:Awkpm2217P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri P. Ranga Ramanujam, Ca ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 29.04.2025 घोषणा की तारीख /Date Of Pronouncement : 14.05.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Dated 28.01.2025 Passed Under Section 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2022-23. 2. The Assessee Raised 10 Grounds Of Appeal, Amongst Which, The Only Short Point Raised For Consideration Whether The Assessing Officer Is 2

145 taxmann.com 314 (Delhi – Trib.) and argued that the Tribunal held the assessee is entitled to get deduction under section 54F of the Act even though net consideration was deposited in capital gain

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

VENKATRAMAN JAYASHREE PRIYADHARSHINI,CHENNAI vs. ACIT, NCC-3,, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.64/Chny/2025 िनधा"रण वष"/Assessment Year: 2015-16 Venkatraman Jayashree Vs. The Assistant Commissioner Of Priyadharshini, No. 8/5, Income Tax, Rajaji 1St Street, Lake Area, Non Corporate Circle 3(1), Nungambakkam, Chennai 600 034. Chennai. [Pan:Adapj3317L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Ms. R. Anita, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 05.06.2025 घोषणा की तारीख /Date Of Pronouncement : 18.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 26.03.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2015-16. 2. The Assessee Raised 5 Grounds Of Appeal Amongst Which, The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Giving Relief To The Extent Of ₹.88,85,000/- Under Section 54 Of The Income Tax Act, 1961 [“Act” In Short]

section 54F of the Act. 5. The ld. DR Ms. R. Anita, Addl. CIT drew our attention the written submissions filed on behalf of the respondent-Revenue and argued that the assessee got relief to the extent allowed by the ld. CIT(A) basing on the evidence produced on record. The ld. DR opposed the submissions

A.JESU RAJENDRAN,CHENNAI vs. ITO BUSINESS WARD XIII(2), CHENNAI

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1634/Chny/2019 िनधा"रण वष" / Assessment Year: 2007-08

145, and its importance over the issue of determination of income under Chapter VI- D 4. The Learned Assessing Officer has grossly erred in considering an land, forming part of. the business stock of the appellant, as a capital asset in the .hands of the appellant on irrelevant and arbitrary grounds; and had invoked the provisions of Section

M/S. KSA POWERINFRA PVT. LTD.,,CHENNAI vs. ACIT, CORPORATE CIRCLE - 4 (2),, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.550/Chny/2020 िनधा"रण वष"/Assessment Year: 2017-18 Ksa Powerinfra Private Limited, Vs. The Assistant Commissioner Of No. 480, First Floor, Khivraj Income Tax Complex-1, Anna Salai, Nandanam, Corporate Circle 4(2), Chennai 600 035. Chennai. [Pan:Aaccg9905B] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Miss. Amirtha, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 27.03.2023 घोषणा की तारीख /Date Of Pronouncement : 31.03.2023 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) 8, Chennai Dated 21.02.2020 Relevant To The Assessment Year 2017-18. 2. Brief Facts Of The Case Are The Assessee Company Filed Its Return Of Income For The Assessment Year 2017-18 On 31.01.2018 Admitting An Income Of ₹.5,95,78,320/-. The Case Was Selected For Scrutiny Under Cass & Notice Under Section 143(2) Of The Income Tax Act, 1961 [“Act”

145: Provided that profits and gains arising from a contract for providing services,— (i) with duration of not more than ninety days shall be determined on the basis of project completion method; (ii) involving indeterminate number of acts over a specific period of time shall be determined on the basis of straight line method. (2) For the purposes of percentage

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

capital R&D expenditure of Rs. 100,21,22,016/- u/s 35(1)(iv) of the Act, and resultantly delete disallowance to the extent of Rs.70,14,85,411/- (Rs.100,21,22,016/- minus Rs.30,06,36,605/-). This ground therefore stands partly allowed. 5. Ground Nos.7 to 15 of the assessee’s appeal and Ground No.3 of the Revenue

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

capital R&D expenditure of Rs. 100,21,22,016/- u/s 35(1)(iv) of the Act, and resultantly delete disallowance to the extent of Rs.70,14,85,411/- (Rs.100,21,22,016/- minus Rs.30,06,36,605/-). This ground therefore stands partly allowed. 5. Ground Nos.7 to 15 of the assessee’s appeal and Ground No.3 of the Revenue

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