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

capital\ngain on sale of mutual funds were offered to tax as income from\nCapital Gains in the year in which they were sold. We do not find any\ninfirmity in the decision of the Id.CIT(A) to intervene with the above\norder of Ld.CIT(A) and accordingly, this issue raised in the Grounds\nof appeal based on chart mentioned

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

capital\ngain on sale of mutual funds were offered to tax as income from\nCapital Gains in the year in which they were sold. We do not find any\ninfirmity in the decision of the Id.CIT(A) to intervene with the above\norder of Ld.CIT(A) and accordingly, this issue raised in the Grounds\nof appeal based on chart mentioned

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

capital\ngain on sale of mutual funds were offered to tax as income from\nCapital Gains in the year in which they were sold. We do not find any\ninfirmity in the decision of the Id.CIT(A) to intervene with the above\norder of Ld.CIT(A) and accordingly, this issue raised in the Grounds\nof appeal based on chart mentioned

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

capital\ngain on sale of mutual funds were offered to tax as income from\nCapital Gains in the year in which they were sold. We do not find any\ninfirmity in the decision of the Id.CIT(A) to intervene with the above\norder of Ld.CIT(A) and accordingly, this issue raised in the Grounds\nof appeal based on chart mentioned

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

capital\ngain on sale of mutual funds were offered to tax as income from\nCapital Gains in the year in which they were sold. We do not find any\ninfirmity in the decision of the Id.CIT(A) to intervene with the above\norder of Ld.CIT(A) and accordingly, this issue raised in the Grounds\nof appeal based on chart mentioned

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

capital\ngain on sale of mutual funds were offered to tax as income from\nCapital Gains in the year in which they were sold. We do not find any\ninfirmity in the decision of the Id.CIT(A) to intervene with the above\norder of Ld.CIT(A) and accordingly, this issue raised in the Grounds\nof appeal based on chart mentioned

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 account or on revenue account irrespective of whether it results in more tax or not. Consequently, the transaction entered by the assessee would fall in the nature of revenue receipt. We are therefore of the considered view that there is no case for any interference to the order of the Ld.CIT(A) at this stage. Accordingly, all the grounds

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

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

14A of the Act read with Rule 8D shall be made where there is no exempt income earned during the year. 7. We have heard both the parties and perused the records. We note that it is now a settled principle that the disallowance u/s.14A of the Act shall not be made where there is no exempt income earned during

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

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

14A of the Act read with Rule 8D shall be made where there is no exempt income earned during the year. 7. We have heard both the parties and perused the records. We note that it is now a settled principle that the disallowance u/s.14A of the Act shall not be made where there is no exempt income earned during

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 account or on revenue account\nirrespective of whether it results in more tax or not. Consequently, the\ntransaction entered by the assessee would fall in the nature of revenue\nreceipt. We are therefore of the considered view that there is no case\nfor any interference to the order of the Ld.CIT(A) at this stage.\nAccordingly, all the grounds

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

sections 14A and 68\nof the Act. By making an addition u/s.69 of the Act, the AO has clearly exceeded\nthe jurisdiction vested in him and travelled beyond the scope of limited scrutiny.\n96. For this reason, we are unable to subscribe to the reasoning adopted by\nthe Ld.CIT(A) that since the asset was included in the gain arising

FL SMIDTH PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.3423/Chny/2019 िनधा"रण वष"/Assessment Year: 2012-13 M/S. Flsmidth Private Limited, The Assistant Commissioner Of No.34, Egatoor, Kelambakkam, Vs. Income Tax, Rajiv Gandhi Salai, Company Circle – 2 (1), Chennai – 603 103. Chennai – 600 034. [Pan: Aaacf4997N] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri S.P. Chidambaram, Advocate : ""थ" की ओर से/Respondent By Shri M. Rajan, Cit : सुनवाई की तारीख/ Date Of Hearing 01.03.2023 : घोषणा की तारीख /Date Of Pronouncement : 08.03.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-5, Chennai Dated 11.10.2019, Relevant To The Assessment Year 2012–13. The Grounds Raised By The Assessee Are As Under: “1. The Order Of The Commissioner Of Income Tax (Appeals) ['Cit (A)’] Is Contrary To Law, Facts & Circumstances Of The Case. 2. Disallowance Under Section 14A Of The Act Read With Rule 8D 2.1. On Facts & Circumstances Of The Case & In Law, The Learned Cit(A) Erred In Confirming The Action Of The Ao In Making Disallowance Of Rs. 75,94,632 Under Section 14A Read With Rule 8D.

section 14A is unwarranted. 2.5. Without prejudice to the above grounds, the CIT(A) erred in including investments not yielding dividend income while computing the disallowance under Rule 8D. 2.6. The CIT(A) ought to have appreciated that investments in wholly owned subsidiaries have not yielded any dividend income and these subsidiaries have since merged with the Company and hence

UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

capital gains arising therefrom are exempt under specific provisions of section 10(38) of the Act. The Tribunal further placing reliance on the decision of Hon’ble High Court of Bombay in the case of New India assurance company Limited reported in 254 taxman 238 [Bombay] and letter dated 21.02.2006 issued by the CBDT to IRDA, further, taking into account

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

gain and when the assessee has converted the property into stock-in-trade and accordingly up to conversion of the property, the Assessing Officer has to treat it as capital asset and after conversion of the property, it has to be treated as business asset. In this case, neither the assessee nor the Assessing Officer properly computed the property

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

gain and when the assessee has converted the property into stock-in-trade and accordingly up to conversion of the property, the Assessing Officer has to treat it as capital asset and after conversion of the property, it has to be treated as business asset. In this case, neither the assessee nor the Assessing Officer properly computed the property

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

gain and when the assessee has converted the property into stock-in-trade and accordingly up to conversion of the property, the Assessing Officer has to treat it as capital asset and after conversion of the property, it has to be treated as business asset. In this case, neither the assessee nor the Assessing Officer properly computed the property

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

gain and when the assessee has converted the property into stock-in-trade and accordingly up to conversion of the property, the Assessing Officer has to treat it as capital asset and after conversion of the property, it has to be treated as business asset. In this case, neither the assessee nor the Assessing Officer properly computed the property

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

gain and when the assessee has converted the property into stock-in-trade and accordingly up to conversion of the property, the Assessing Officer has to treat it as capital asset and after conversion of the property, it has to be treated as business asset. In this case, neither the assessee nor the Assessing Officer properly computed the property