EMPEE HOLDINGS LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri George Mathan & Shri Ramit Kochar

capital gains on sale of assets , etc. and hence additions as were made by AO by invoking provisions of Section 2(22)(e) of the 1961 Act were confirmed by learned CIT(A) subject to verification by the AO of actual accumulated profits in the hands of M/s Empee Distilleries Limited, vide appellate order dated 07.03.2014 passed by learned

ARTHI BALIGA,CHENNAI vs. ACIT, NFAC, , DELHI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1559/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Arthi Baliga, Vs. The Principal Commissioner Of No. 15, Flat No. 3-C, Coral Woods Income Tax, Chennai-4, Apartment, Sri Ram Nagar, South Chennai. Street, Alwarpet, Chennai 600 018. [Pan:Bkjpb5416P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ravi Kannan, Advocate & Shri Varun Ranganathan, Advocate ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 05.12.2024 घोषणा की तारीख /Date Of Pronouncement : 28.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax, Chennai-4, Chennai For The Assessment Year 2017-18 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

section 147 r.w.s. 144B of the Act. 5. On verification of the assessment records, the ld. PCIT noted that the Assessing Officer completed the assessment by not making any 4 I.T.A. No.1559/Chny/24 addition in respect of the share of capital gains

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT LTU-II, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 147 of the Act and hence, the reopening is bad in law and (ii) the second issue raised is that the assessee filed complete details before AO during original assessment proceedings and hence, there is change of opinion in reopening of assessment on the same set of facts because no new material is brought on record for reopening

K.R.JAYARAM,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

capital gains computation should have been worked out on this amount. Hence, the AO have a reason to believe that income chargeable to tax has escaped assessment within the ambit of section 147

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

capital gains on sale of shares instead of an amount of Rs. 15 crores which was total consideration as per agreements entered into with Pentamedia Group of concerns. The aforesaid assessment was framed by AO vide assessment order dated 31.12.2008 passed u/s 143(3) read with Section 147

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

capital gains on sale of shares instead of an amount of Rs. 15 crores which was total consideration as per agreements entered into with Pentamedia Group of concerns. The aforesaid assessment was framed by AO vide assessment order dated 31.12.2008 passed u/s 143(3) read with Section 147

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

capital gains on sale of shares instead of an amount of Rs. 15 crores which was total consideration as per agreements entered into with Pentamedia Group of concerns. The aforesaid assessment was framed by AO vide assessment order dated 31.12.2008 passed u/s 143(3) read with Section 147

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

capital gains on sale of shares instead of an amount of Rs. 15 crores which was total consideration as per agreements entered into with Pentamedia Group of concerns. The aforesaid assessment was framed by AO vide assessment order dated 31.12.2008 passed u/s 143(3) read with Section 147

GOKULAKRISHNA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the stay\napplication is dismissed

capital gains tax is leviable. The amount received by the assessee was a consequence of this realignment, not a taxable event.", "result": "Allowed", "sections": [ "250", "147

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

147 of the Act and disallowed the long term capital loss as well. The Ld. AR invited our attention to the order of the Ld. CIT(A) passed u/s 250 of the Act in relation to the reassessment order u/s 147/143(3) of the Act wherein he upheld the correctness of the long term capital loss as well

ACIT, CHENNAI vs. B.V.REDDY ENTERPRISES PVT. LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.3293/Chny/2016 िनधा"रण वष"/Assessment Year: 2008-09 The Assistant Commissioner Of Vs. M/S. B.V. Reddy Enterprises Pvt. Ltd., New No. 21/Old No. 10A, 1St Floor, Income Tax, Corporate Circle 1(2), Umayal Road, Kilpauk, Chennai 600 034. Chennai 600 010. [Pan:Aaccn2252L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri N. Arjunraj, Ca For Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 27.06.2022 घोषणा की तारीख /Date Of Pronouncement 29.07.2022 : आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai, Dated 28.09.2016 Relevant To The Assessment Year 2008-09. 2. Facts Are, In Brief, That The Assessee Filed Its Return Of Income For The Assessment Year 2008-09 On 13.09.2008 Disclosing Total Income Of ₹.1,83,53,540/- After Setting Off Of Carry Forward Loss Of ₹.9,67,40,138/-.

capital gain (non-STT) and STCG (STT). 2.1 Subsequently, the Assessing Officer has reopened the assessment under section 147 of the Act by issuing

THE GATE OF HOPE CHARITABLE TRUST,,CHENNAI vs. ITO(E), WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 147 were invalid. Instead of adding anything to the said reasons, we think it would be ap to the said reasons, we think it would be appropriate if the same are propriate if the same are reproduced: -- "In the case at hand, as is seen from the reasons recorded by the AO, "In the case at hand

THE GATE OF HOPE CHARITABLE TRUST,CHENNAI vs. ITO (EXEMPTIONS) WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 147 were invalid. Instead of adding anything to the said reasons, we think it would be ap to the said reasons, we think it would be appropriate if the same are propriate if the same are reproduced: -- "In the case at hand, as is seen from the reasons recorded by the AO, "In the case at hand

RAM KRISHAN KULWANT RAI,CHENNAI vs. ACIT CENTRAL CIRCLE 2(3), CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita No.1047/Chny/2018 "नधा"रण वष" / Assessment Year : 2009-10

147 of the Act, when there was search operation and proceedings were initiated under Section 153C of the Act. 17. In view of the above discussion, we are unable to uphold the orders of the lower authorities. Accordingly, orders of both the authorities below are set aside and the addition made by the Assessing Officer as capital gain

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. MANIKANDAN, CHENNAI

The appeal of the Revenue is dismissed

147 of the Act. The A.O was of the view\nthat the right to receive profit in a partnership firm is a capital asset u/s. 2(14)\nof the Act and relinquishment of the right of receive the profit is transfer\n- 3 -:\nITA No.2986/Chny/2025\nManikandan\nwithin the definition section 2 (47) of the Act. Accordingly, the A.O treated\nthe

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

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

capital gains arising on the sale of these shares during the Assessment Year under consideration especially in view of the fact that the said sum had passed through the bank account of the Assessee and accordingly the re-assessment order came to be passed in terms of Section 147

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

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

capital gains arising on the sale of these shares during the Assessment Year under consideration especially in view of the fact that the said sum had passed through the bank account of the Assessee and accordingly the re-assessment order came to be passed in terms of Section 147

DCIT, CHENNAI vs. B.V.REDDY ENTERPRISES PVT LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.1914/Chny/2019 िनधा"रण वष"/Assessment Year: 2010-11 The Deputy Commissioner Of Vs. M/S. B.V. Reddy Enterprises Pvt. Ltd., Income Tax, New No. 21/Old No. 10A, First Floor, Corporate Circle 1(2), Umayal Road, Kilpauk, Chennai 600 034. Chennai 600 010. [Pan:Aaccn2252L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Johnson, Addl. Cit ""थ" की ओर से/Respondent By : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 15.09.2022 घोषणा की तारीख /Date Of Pronouncement 04.11.2022 : आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai, Dated 29.03.2019 Relevant To The Assessment Year 2010-11. 2. Facts Are, In Brief, That The Assessee Filed Its Return Of Income For The Assessment Year 2010-11 On 13.10.2010 Admitting Total Income Of ₹.15,50,25,060/-. The Assessing Officer Has Completed The Assessment Under Section 143(3) Of The Income Tax Act, 1961 [“Act” In Short] Dated

capital gain as business income on the basis of the same material available on record. 7.3 Apart from the above, in this case, the assessment was reopened beyond four years from the end of the relevant assessment year under consideration, the provisions of section 147