GANESAN KANNAN,THOOTHUKUDI vs. ITI, INTERNATIONAL TAXATION WARD, THOOTHUKUDI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 698/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19

Capital Gain on sale of 1,34,63,935 1,43,14,139 property I & II Total Assessed Income 1,43,66,879 :-6-: ITA. No:698/Chny/2024 Aggrieved by the final assessment order, the assessee is in appeal before us. 5. The learned AR for the assessee submitted that legal grounds are purely issues concerning the limitation prescribed u/s.153

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act fro analyzed the entire statutory framework of Section 153C of the Act from its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance Act, 2017 and its its introduction to the amendment by Finance

ACIT, CHENNAI vs. MYUNGHWA AUTOMOTIVE INDIA PRIVATE LIMITED, KANCHEEPURAM

In the result, the appeal of the Revenue and the cross objections of the assessee are allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

gain related adjustments and the PLI worked out to 0.97% as against the assessee’s working of 10.25%. Hence the TPO made independent search process and selected the final set of comparables as under: Final set of comparables: S.No. Name of the companies PLI (OP/OI) 1 Kalyani Forge Ltd. 5.55% 2 Imperial Auto Industries Ltd. 6.76% 3 Pricol

MASILAMANI NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, appeals filed by the assessee(s) are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain on sale of shares in the hands of the assessee in AY 2014-15. Being aggrieved by the order(s) of the AO, the assessee preferred appeal before the Ld. CIT(A) who dismissed the same. Now the assessee is in appeal before us. 5. We first take up the assessee’s appeal

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपीलसं./Ita Nos.1254, 1255, 1258, 1260/Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 The Dcit, Central Circle-2(2), Chennai. (अपीलार्थी/Appellant) V. M/S. Southern Agrifurane Industries Pvt Ltd., Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (प्रत्यर्थी/Respondent) आयकर अपीलसं./Ita Nos.1233, 1235, 1237, 1238 /Chny/2025 निर्धारणवर्ष/Assessment Years: 2014-15 To 2017-18 M/S. Southern Agrifurane- V. The Dcit, Industries Pvt Ltd Central Circle-2(2), Chennai. Mgm Centre No.1, 9Th Cross Street, Dr. Radhakrishnan Salai, Mylapore, Chennai - 600 004. [Pan: Aagcs 9705 F] (अपीलार्थी/Appellant) Department By Assessee By सुनवाईकीतारीख/Date Of Hearing घोषणाकीतारीख /Date Of Pronouncement (प्रत्यर्थी/Respondent) : Mrs. C. Yamuna, Cit & Mr. Bipin, Cit : Mr. N. Arjun Raj, Advocate : 08.10.2025 : 21.11.2025

Capital/ Reserves/Loan/ Current Liabilities Liabilities (Credit) Immoveable Property/ Loans & Advances/ Shares/ Bank Balance 21. The above view of ours get bolstered from reading of Explanation 2 appended to the fourth proviso, which defines 'asset', for the purpose of fourth proviso to Section 153A, to include i) immovable property, ii) shares and securities iii) loans and advances & iv) Deposit in bank

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

153B of the Act prescribes the time limit for completion of assessment u/s 153A and 153C of the Act. Section 153C of the Act bears the heading "Assessment of income of any other person" which is a special provision in respect of assessment of income of "any other person" (third party) against whom no search u/s. 132 or requisition

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

153B of the Act prescribes the time limit for\ncompletion of assessment u/s 153A and 153C of the Act. Section 153C of\nthe Act bears the heading \"Assessment of income of any other person\"\nwhich is a special provision in respect of assessment of income of \"any\nother person\" (third party) against whom no search u/s. 132 or\nrequisition

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4),, CHENNAI

153B of the Act prescribes the time limit for\ncompletion of assessment u/s 153A and 153C of the Act. Section 153C of\nthe Act bears the heading \"Assessment of income of any other person\"\nwhich is a special provision in respect of assessment of income of \"any\nother person\" (third party) against whom no search u/s. 132 or\nrequisition

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE-1(4), CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

153B of the Act prescribes the time limit for\ncompletion of assessment u/s 153A and 153C of the Act. Section 153C of\nthe Act bears the heading \"Assessment of income of any other person\"\nwhich is a special provision in respect of assessment of income of \"any\nother person\" (third party) against whom no search u/s. 132 or\nrequisition

R.VISWANATHAN,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI

153B of the Act prescribes the time limit for\ncompletion of assessment u/s 153A and 153C of the Act. Section 153C of\nthe Act bears the heading \"Assessment of income of any other person\"\nwhich is a special provision in respect of assessment of income of \"any\nother person\" (third party) against whom no search u/s. 132 or\nrequisition

KSJ INFRASTRUCTURE PRIVATE LIMITED,KOLKATA vs. DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI

Bench: Shri Manjunatha. G, Hon’Ble & Shri Manomohan Das, Hon’Bleआयकर अपील सं./Ita No.: 1110/Chny/2023 िनधा"रण वष" / Assessment Year: 2010-11 M/S. Ksj Infrastructure The Deputy Commissioner Of Pvt. Ltd., V. Income Tax, 2Nd Floor, Grant Lane, Room Central Circle -1(1), No. 218, Kolkata – 700 012. Chennai – 600 0034. [Pan:Aadcc-5913-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. B. Rama Krishnan, Fca & Shri. Shrenik Chordia, Ca ""यथ" क" ओर से/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 10.01.2024 घोषणा क" तारीख/Date Of Pronouncement : 06.03.2024 आदेश /O R D E R

153B(1) of the Income Tax Act. 3. For that the Learned Commissioner of Income Tax (Appeals) ought to have cancelled the assessment u/s 153C of the Act that was made for an Assessment Year beyond the stipulated period of ten assessment years as laid down under the applicable provisions of Section 153A 1153C of the Act by appreciating that

HOTEL SARAVANA BHAVAN,CHENNAI vs. ACIT CENTRAL CIRCLE 1(3), CHENNAI

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

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.474/Chny/2019 ("नधा"रण वष" / Assessment Year: 2014-15) Vs The Acit, M/S. Hotel Saravana Bhavan, C/O. Shri.T.N. Seetharaman, Central Circle 1(3), Advocate, Chennai – 34. #384, (Old No.196), Lloyds Road, Chennai – 600 086. Pan: Aabfh 3049M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri T.N. Seetharaman, Advocate ""यथ" क" ओर से/Respondent By : Shri S. Bharath,Cit सुनवाई क" तार"ख/Date Of Hearing : 26.08.2019 घोषणा क" तार"ख /Date Of Pronouncement : 22.11.2019 आदेश / O R D E R

153B(1)(b) on 30.03.2016, assessing the total income at Rs.19,05,92,896/-. In the assessment order, he initiated penalty proceedings U/s.271AAB on the admission of the additional income of Rs.12.5 crores as a deemed concealment. 2.1 During the penalty proceedings, after considering the assessee’s reply etc., the Assessing Officer held, inter-alia, that since the provision

N.SANTHANAM,CHENNAI vs. ACIT CENTRAL CIRCLE-1(2), CHENNAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकरअपीलसं./I.T.A.No.328/Chny/2020 ("नधा"रणवष" / Assessment Year: 2014-15) Mr. N.Santhanam Vs The Assistant Commissioner Old No.14, New No.12, Income Tax, Seethammal Colony Extension, Central Circle-1(2) 1St Cross Street, Teynampet, Chennai-600 034. Chennai-600 018. Pan: Axups 6533R (अपीलाथ"/Appellant) (""यथ"/Respondent)

153B(1)(b) of the Act on 28.03.2016 and accepted returned income. 4. Subsequently, penalty proceedings u/s.271AAB of the Act was initiated and accordingly, notice u/s.274 r.w.s 271AAB dated 28.03.2016 was issued and served on the assessee. In response, the assessee has filed his written submissions and challenged initiation of penalty proceedings on the ground that 4 admission of undisclosed