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

3) of the Act on\n29.12.2019 determining the total income at Rs.122,11,04,812/- after making the\nfollowing additions: -\ni. Unexplained cash credit u/s.68 of the Act on account of increase in capital\namounting to Rs.115,26,13,606/-;\nii. Unexplained investment u/s.69 of Rs.4,30,62,000/-;\niii. Disallowance u/s.14A of Rs.25,152/-.\n15. Aggrieved by the assessment

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

145/- to the Long Term Capital Gains returned by assessee. 8. The CIT(A) NFAC failed to appreciate that sec. 50C value of the demised property was well within the tolerance limit of 10% as per the amended provisions of sec.50C and hence did not call for any adjustment to the returned value for capital gains purposes

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 account with a delay of 31 days. Further, he argued that the impugned order is not justified in denying the deduction under section

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

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

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

145(3) of the Act and that by not doing so, the action of the AO in estimating the profits of the eligible unit was unjustified. 5.7 The Ld. AR further showed the comparative figures of the gross profit and net profit of the eligible unit and other non-eligible units and showed that the profits of Pantnagar were commensurate

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

145(3) of the Act and that by not doing so, the action of the AO in estimating the profits of the eligible unit was unjustified. 5.7 The Ld. AR further showed the comparative figures of the gross profit and net profit of the eligible unit and other non-eligible units and showed that the profits of Pantnagar were commensurate

DY. COMMISSIONER OF INCOME TAX , CHENNAI vs. NAPC PVT. LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

gains of business\nor profession” or “Income from other sources” shall, subject to the\nprovisions of sub-section (2), be computed in accordance with either\ncash or mercantile system of accounting regularly employed by the\nassessee.\n(2) The Central Government may notify in the Official Gazette from\ntime to time 2 [income computation and disclosure standards] to be\nfollowed

M/S. BRITISH AGRO PRODUCTS (INDIA) PVT. LTD.,CHENNAI vs. PCIT-1, CHENNAI

In the result, the appeal of the assessee is allowed

3) Notwithstanding anything contained in sub-section (2), an order in revision\nunder this section may be passed at any time in the case of an order which has\nbeen passed in consequence of, or to give effect to, any finding or direction\ncontained in an order of the Appellate Tribunal, 56 the High Court or the Supreme\nCourt.\nExplanation

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

DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE-1, TIRUPPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING P LTD, TIRUPPUR,TAMILNADU

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

gains from business. The ld. DR drew our attention to para 7 of the impugned order and submits that the ld. CIT(A) held the said incentive received from the Government as a capital receipt by placing reliance on the order of the Tribunal in assessee’s own case in ITA Nos. 47 & 48/Mds/2016 dated