B.SUNDARARAJAN,CHENNAI vs. DCIT, NON CORPORATE CIRCLE, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and appeal of the assessee is allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 431/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 The Assistant Commissioner Of Vs. Shri B. Sundararajan, Income Tax, No. 34, Umapathy Street, Non Corporate Circle 18(1), West Mambalam, Chennai 600 033. Chennai 600 034. [Pan:Aasps3969C] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 95/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 Shri B. Sundararajan, The Deputy Commissioner Of No. 34, Umapathy Street, Vs. Income Tax, West Mambalam, Chennai 600 033. Non Corporate Circle 18(1), Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Mrs. V.S. Sreelekha, Cit Assessee By Shri N. Arjunraj, Ca For : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2017 Relevant To The Assessment Year 2008-09. 2

160/- and claimed deduction under section 54F of the Act for both the properties. The Assessing Officer observed by combined reading of sub-section (1) and sub- section (2) of section 54F of the Act that the assessee is eligible for claiming deduction under section 54F of the Act only for one property. Since the assessee purchased two properties

ITO NON CORP WARD 14 (4), CHENNAI vs. SMT. B VATHSALA, CHENNAI

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

Bench: Shri Ramit Kochar & Shri Duvvuru R.L. Reddyआयकर अपील सं./I.T.A. No. 1112/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 The Income Tax Officer, Smt. B. Vathsala, Non-Corporate Ward-14(4), Vs. No.34/30, Umapathy Street, Chennai. West Mambalam, Chennai – 600 033. [Pan: Actpb 9534H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Srinivasa Rao Vana, Jcit ""थ" की ओर से/Respondent By : Shri N. Arjun Raj, C.A For Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 19.11.2019 घोषणा की तारीख /Date Of Pronouncement : 27.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-14, Chennai Dated 15.12.2017 Relevant To The Assessment Year 2008-09. The Only Effective Ground In This Appeal Raised By The Revenue Is That The Ld. Cit(A) Has Erred In Directing The Assessing Officer To Allow The Assessee’S Claim Of Deduction Under Section 54F Of The Income Tax Act, 1961 (In Short “The Act”).

160/- and claimed deduction under section 54F of the Act for both the properties. The 4 I.T.A. No.1112/Chny/18 Assessing Officer observed by combined reading of sub-section (1) and sub- section (2) of section 54F of the Act that the assessee is eligible for claiming deduction under section 54F of the Act only for one property. Since the assessee purchased

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), CHENNAI vs. M. MAHADEVAN, CHENNAI

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1824/Chny/2024, Assessment Years: 2013-14 आयकर अपील सं./Ita No.1825/Chny/2024, Assessment Years: 2014-15 आयकर अपील सं./Ita No.1826/Chny/2024, Assessment Years: 2019-20 Deputy Commissioner Of Income Tax, Central Circle-1(3), Chennai. M.Mahadevan, No.24, Park Avenue Street, Shenoy Nagar, Chennai-600 030. [Pan: Aajpm5888R] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By (प्रत्यर्थी/Respondent) : Shri G.Gireesh, C.A प्रत्यर्थी की ओर से /Revenue By : Ms.C.Vatchala, Cit सुनवाई की तारीख/Date Of Hearing : 08.04.2025 घोषणा की तारीख /Date Of Pronouncement : 30.05.2025 आदेश / Order Per Amitabh Shukla, A.M : The Below Mentioned Appeals Have Been Filed By The Appellant Revenue For Ay-2013-14, Ay-2014-15 & 2019-20 Contesting The Order Of Ld. First Appellate Authority Indicated Column-E, Herein Below:- S. No. A Appeal Nos. B Ays C Appellant D Cit(A) Order Details E Respondent F 1

capital gain on sale of shares - Rs.2,94,33,160/- As regards the issue of Tax residency of the assessee, during the course of assessment proceedings, upon verification of the documents, Information obtained from the FRRO, copies of Visa and Passport etc, Ld.AO noted that Shri. Mahadevan had stayed / resided in India as per below mentioned details:- SL. Asst. Year

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

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

160 will not get affected because of introduction of Section 115U which is applicable only for specific category of assessees. Once one of the beneficiaries has offered the income from trust to tax and is also assessed to tax, the tax authorities cannot assess the Appellant. Thus, once the beneficiaries are identifiable as a class and their share are determinable

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

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

160 will not get affected because of introduction of Section 115U which is applicable only for specific category of assessees. Once one of the beneficiaries has offered the income from trust to tax and is also assessed to tax, the tax authorities cannot assess the Appellant. Thus, once the beneficiaries are identifiable as a class and their share are determinable

ITO, CHENNAI vs. TVS SHRIRAM GRWOTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

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

160 will not get affected because of introduction of Section 115U which is applicable only for specific category of assessees. Once one of the beneficiaries has offered the income from trust to tax and is also assessed to tax, the tax authorities cannot assess the Appellant. Thus, once the beneficiaries are identifiable as a class and their share are determinable

ITO, CHENNAI vs. TVS SHRIRAM GROWTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

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

160 will not get affected because of introduction of Section 115U which is applicable only for specific category of assessees. Once one of the beneficiaries has offered the income from trust to tax and is also assessed to tax, the tax authorities cannot assess the Appellant. Thus, once the beneficiaries are identifiable as a class and their share are determinable

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

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

160 will not get affected because of introduction of Section 115U which is applicable only for specific category of assessees. Once one of the beneficiaries has offered the income from trust to tax and is also assessed to tax, the tax authorities cannot assess the Appellant. Thus, once the beneficiaries are identifiable as a class and their share are determinable

DCIT, CHENNAI vs. CHARUMATHY SESHADRI, CHENNAI

In the result, the Revenue’s appeal is treated as partly allowed for

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

160 (b) Compensation for the building 1,71,360 (c) Solatium 1,03,878 ------------- 7,96,398 ------------- In the income-tax return field for the assessment year 1964-65, the assessee declared her share of capital gain arising on the transfer of the land and building by way of compulsory acquisition, claimed that she constructed a building for her residential

INCOME TAX OFFICER, CHENNAI vs. ROHITKUMAR NEMCHAND PIPARIA, CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1344/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Ito Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1) #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms. Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

160/- on account of interest levied u/s 234B of the Act. 2. The Ld.CIT(A) has relied on the principle of law as laid down by the Hon'ble Supreme Court in the case of Director of Income-tax, New Delhi Vs. Mitsubishi Corporation dated 17.09.2021 in Civil Appeal Nos. 1256 & 1262 of 2016 and others and held that

RAMANATHAN ADAIKALAVAN,COIMBATORE, TAMIL NADU vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.557/Chny/2024 निर्ाारण वर्ा /Assessment Years: 2014-15 Ramanathan Adaikalavan, Deputy Commissioner Of Income Tax, No.80, Ansari Street, Ram Nagar, Non-Corporate Circle-2, Coimbatore-641009. Coimbatore [Pan: Aanpa6846P] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri P.M.Kathir, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुिवाई की तारीख/Date Of Hearing : 05.11.2024 घोर्णा की तारीख /Date Of Pronouncement : 06.12.2024 आदेश / O R D E R Per Amitabh Shukla, A.M :

section 147 / 148 are bad in law. The Ld. Counsel had contended that reassessment of any proceedings on the basis of change of opinion is not permissible in law. It has been submitted that as per extant statutory provisions covering the subject, reassessment u/s 148 is only permissible if either some new facts have come to the notice

GOLDEN ERA PLANTATIONS INDIA PRIVATE LIMITED,COIMBATORE vs. DCIT,CIRCLE 1, OOTY

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 838/Chny/2020 िनधा"रण वष" / Assessment Year: 2013-14

160/-. The guideline value fixed for the purpose of payment of stamp duty as per sale deed was at Rs. 73,81,185/-. The AO has considered registered document between the parties and computed short term capital gains by taking into account deemed consideration as per provisions of :-7-: ITA. No:838 /Chny/2020 section

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. M. MAHADEVAN, CHENNAI

In the result, the appeals of the Revenue are decided as under:-

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1824/Chny/2024, Assessment Years: 2013-14 आयकर अपील सं./Ita No.1825/Chny/2024, Assessment Years: 2014-15 आयकर अपील सं./Ita No.1826/Chny/2024, Assessment Years: 2019-20

gain which the assessee had acquired for selling shares at highly undervalued price. The Ld. AO therefore after reducing the reported cost of acquisition of OCPL shares amounting to Rs.2,60,11,810/-, made the impugned addition of Rs.2,94,33,160/-. We have however noted that the hypothesis propounded by the Ld.AO is flawed and not supported

DEPUTY COMMISSIONER OF INOCME TAX, CENTRAL CIRCLE - 1(3), CHENNAI vs. M. MAHADEVAN , CHENNAI

In the result, the appeals of the Revenue are decided as under:-

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1824/Chny/2024, Assessment Years: 2013-14 आयकर अपील सं./Ita No.1825/Chny/2024, Assessment Years: 2014-15 आयकर अपील सं./Ita No.1826/Chny/2024, Assessment Years: 2019-20

gain which the assessee had acquired for selling shares at highly undervalued price. The Ld. AO therefore after reducing the reported cost of acquisition of OCPL shares amounting to Rs.2,60,11,810/-, made the impugned addition of Rs.2,94,33,160/-. We have however noted that the hypothesis propounded by the Ld.AO is flawed and not supported

DCIT, CHENNAI vs. CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED, CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Capital Gains claimed by the assessee "2,04,45,542/-. 8.3 We have considered the facts and submissions made by the ld. Authorised Representative and Departmental Representative, were similar issue was adjudicated by us for the assessment year 2006-07 in ITA No.1181/Mds/2014 at para 5.18, we partly allow the ground of the assessee. 8.4. The last ground raised

CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Capital Gains claimed by the assessee "2,04,45,542/-. 8.3 We have considered the facts and submissions made by the ld. Authorised Representative and Departmental Representative, were similar issue was adjudicated by us for the assessment year 2006-07 in ITA No.1181/Mds/2014 at para 5.18, we partly allow the ground of the assessee. 8.4. The last ground raised

A VIJAYAKUMARI,PATTUKKOTTAI vs. ITO, NCW-1, , THANJAVUR

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

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 3435/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 Mrs. A. Vijayakumari, The Income Tax Officer, No. 25, Pillaiyar Koil St., Pattukottai, Vs. Ward 1, Thanjavur District. Thanjavur. [Pan:Aacpv3947K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T.T. Durairaj Kandiar, Ca ""थ" की ओर से/Respondent By : Shri Clement Ramesh Kumar, Addl.Cit सुनवाई की तारीख/ Date Of Hearing : 17.07.2019 घोषणा की तारीख /Date Of Pronouncement : 26.07.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Trichy, Dated 27.11.2018 Relevant To The Assessment Year 2014-15. In The Grounds Of Appeal, The Assessee Has Challenged The Order Of The Ld. Cit(A) On Confirmation Of Both Income From Long Term Capital Gains & Short Term Capital Gains.

capital gain workings at ₹.42,68,880/- instead of ₹.44,69,000/-, a notice under section 148 of the Income Tax Act, 1961 [“Act” in short] was issued. In response, the assessee filed a reply dated 16.06.2017 requesting to treat the return filed by her on 23.02.2016 as the one filed in response to notice under section

KIRTHISIMHAN WIJEYANAYAKE,COIMBATORE vs. ACIT NON CORPORATE CIRCLE 2, COIMBATORE

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

160, Thiruvenkatasamy Road, Non-Corporate Circle -2, Vs. R.S. Puram, Coimbatore – 641 002. Coimbatore. "थायीलेखासं./जीआइआरसं./PAN/GIR No. AEWPA-8469-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant by : Shri R. Sivaraman (Advocate) – Ld. AR ""थ"कीओरसे/Respondent by : Shri P. Sajit Kumar (JCIT) – Ld. DR सुनवाईकीतारीख/ : 07-09-2022 Date of Hearing घोषणाकीतारीख / : 06-12-2022 Date of Pronouncement