MOHIT GUPTA,CHENNAI vs. ITO,NON- CORP WARD 17(2), CHENNAI, CHENNAI

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1847/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Shri Mohit Gupta, The Income Tax Officer, T45, Old No.T11, Vs. Non-Corporate Ward 17(2), Vi Avenue, Chennai. Besant Nagar, Chennai – 600 090. Pan: Aoqpg 5419R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 20.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.11.2025

163 had held in the context of Section 54F of the Act that when the entire sale consideration is utilized in construction of a residential house on or before the time limit specified u/s 139(4) of the Act, exemption cannot be denied merely because the amount was not deposited in the capital gains

AVANASIYAPPAN ESWARAN,TIRUPPUR vs. ITO,WARD 1(2), TIRUPPUR

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

Bench: Shri George George K & Shri S.R. Raghunatha

Capital Gains Account Scheme (CGAS) is only a Directory provision and not a Mandatory provision. 4) The Ld. CIT(A) failed to notice that are plethora of case laws, including the decisions of the H’ble Jurisdictional Madras High Court, cited before him, in favour of the assessee’s claim for deduction

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

Capital Gains of Rs.1,32,78,187/- admitted by the assessee has been modified by the AO at an figure of Rs.1,88,57,487/-. 8. In view of the above grounds and other submissions to be made at the time of Appeal hearing, the order U/S 250(6) passed by Commissioner of Income Tax (Appeals) may be cancelled

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

Capital Gains of Rs.1,32,78,187/- admitted by the assessee has been modified by the AO at an figure of Rs.1,88,57,487/-. 8. In view of the above grounds and other submissions to be made at the time of Appeal hearing, the order U/S 250(6) passed by Commissioner of Income Tax (Appeals) may be cancelled

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

163/-\nand direct the AO to delete the addition.\n4.8 Further, the assessee has claimed that Rs.4,00,436/- has been\nintroduced as capital contribution during the year, stating that the\nsame has been given as Gift by her husband Sri.P.Seeman. We note\nthat the assessee has not furnished any cogent evidence for the\nsame. Further, during the assessment proceedings

SMT. JAYANTHI SEEMAN,,CHENNAI vs. ITO, NCW - 1 (2),, CHENNAI

In the result the appeal of the assessee is partly allowed

163/-\nand direct the AO to delete the addition.\n4.8 Further, the assessee has claimed that Rs.4,00,436/- has been\nintroduced as capital contribution during the year, stating that the\nsame has been given as Gift by her husband Sri.P.Seeman. We note\nthat the assessee has not furnished any cogent evidence for the\nsame. Further, during the assessment proceedings

ITO, NON-COPORATE WARD-19(6), CHENNAI vs. SHRI.GOMATHINAYAGAM RATHINASABAPATHY, EKKADUTHANGAL CHENNAI

In the result the appeal of the revenue is dismissed

capital gains account.\nDuring the remand report in response to the mail given by the\nJAO calling for information u/s.133(6), the director of M/s.Omplas\nsystems gave a reply mail confirming the construction, copy of\nwhich is on the record. Regarding the permission and completion\ncertificates, it is explained that as new types of materials were\nused, construction permission

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. We are inclined to first adjudicate the legal issues raised by the assessee, ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 12 :: which if found valid, goes to the root of the matter [since it challenges the jurisdiction exercised by the AO u/s 153C of the Act]. 10. Assailing the action of the lower

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. We are inclined to first adjudicate the legal issues raised by the assessee, ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 12 :: which if found valid, goes to the root of the matter [since it challenges the jurisdiction exercised by the AO u/s 153C of the Act]. 10. Assailing the action of the lower

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. We are inclined to first adjudicate the legal issues raised by the assessee, ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 12 :: which if found valid, goes to the root of the matter [since it challenges the jurisdiction exercised by the AO u/s 153C of the Act]. 10. Assailing the action of the lower

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. We are inclined to first adjudicate the legal issues raised by the assessee, ITA Nos.2270 to 2274/Chny/2024 Arvind Nandagopal (AYs 2014-15 to 2018-19) :: 12 :: which if found valid, goes to the root of the matter [since it challenges the jurisdiction exercised by the AO u/s 153C of the Act]. 10. Assailing the action of the lower

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

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

capital gain.\nWe are inclined to first adjudicate the legal issues raised by the assessee,\nwhich if found valid, goes to the root of the matter [since it challenges the\njurisdiction exercised by the AO u/s 153C of the Act].\n10. Assailing the action of the lower authorities, the Ld. AR Shri. B.\nRamakrishnan C.A submitted that, in order

M/S. CITY UNION BANK LTD.,,KUMBAKONAM vs. PCIT,, MADURAI

In the result, the appeal for A

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

gains from business was a subject matter of consideration by the Assessing Officer during the original assessment proceedings leading to an order dated 12 October 2010. It would therefore, follow that the reopening of the assessment by impugned notice dated 28 March 2013 is merely on the basis of change of opinion of the Assessing Officer from that held earlier

UCAL LIMITED,CHENNAI vs. PCIT, CHENNAI-3,, CHENNAI

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

163 5. 19.09.2021 Reply to Notice under Section 143(2) of the Act 171 dated 29.06.2021 6. - Details of creditors 179 7. - Details of depreciation 180 8. - Detail of default statement 181 9. - Details of donation for scientific research 182 10. 08.12.2021 Notice under Section 142(1) of the Act 282 11. 20.01.2022 Notice under Section

M/S. CITY UNION BANK,KUMBAKONAM vs. PCIT,, MADURAI

In the result, both the appeals for A

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1478 & 1479/Chny/2025 धनिाारण वर्ा / Assessment Year: 2020-21 & 2021-22 M/S. City Union Bank, Pcit No. 148-149, T.S.R Big Street, Vs. Madurai – 1. Kumbakonam – 621 001. Tamil Nadu. [Pan: Aaacc-1287-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. S. Ananthan, Ca & Ms. R. Lalitha, Ca प्रत्यथी की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit. सुनवाई की तारीख/Date Of Hearing : 28.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 09.09.2025

gains from business was a subject matter of consideration by the Assessing Officer during the original assessment proceedings leading to an order dated 12 October 2010. It would therefore, follow that the reopening of the assessment by impugned notice dated 28 March 2013 is merely on the basis of change of opinion of the Assessing Officer from that held earlier

M/S. CITY UNION BANK,KUMBAKONAM vs. PCIT,, MADURAI

In the result, both the appeals for A

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1478 & 1479/Chny/2025 धनिाारण वर्ा / Assessment Year: 2020-21 & 2021-22 M/S. City Union Bank, Pcit No. 148-149, T.S.R Big Street, Vs. Madurai – 1. Kumbakonam – 621 001. Tamil Nadu. [Pan: Aaacc-1287-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. S. Ananthan, Ca & Ms. R. Lalitha, Ca प्रत्यथी की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit. सुनवाई की तारीख/Date Of Hearing : 28.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 09.09.2025

gains from business was a subject matter of consideration by the Assessing Officer during the original assessment proceedings leading to an order dated 12 October 2010. It would therefore, follow that the reopening of the assessment by impugned notice dated 28 March 2013 is merely on the basis of change of opinion of the Assessing Officer from that held earlier

ASSISSTANT COMMISIONER OF INCOME TAX, CHENNAI vs. ESTRA ENTERPRISES PRIVATE LIMITED, CHENNAI

Capital gain escaping assessment being the\nnotional profit on conversion of Rs.1254,289,672/- would work out to\nRs.42,63,33,059/-.\n11. As we see from the above reasons recorded by the AO for\nreopening assessment that there is no allegation that failure of the\nassessee to disclose fully and truly all material facts necessary for\nthe assessment

HYUNDAI TRANSYS INC,REPUBLIC OF KOREA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.338/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Hyundai Transys Inc, Vs. The Deputy Commissioner Of 105, Sindang Income Tax, 1 Ro Seongyeon, International Tax, Myeon, Corporate Circle 1(1) Seosan, Ccn 356851 Chennai. Korea.

capital gains tax would be reconsidered by the Tribunal in case it comes to the conclusion that the notice dated 13/11/2000 is a notice within jurisdiction of the Assessing Officer’’. 11. Therefore, in the light of above settled position of law and respectfully following the Hon’ble Supreme Court and Hon’ble High Courts judgments referred supra , we admit