LATE S. YOGARATHINAM, REP. BY L/H Y. SHANMUGA DURAI,CHENNAI vs. ACIT, CIRCLE-1(2), CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.:626/Chny/2024 िनधा"रण वष"/Assessment Year:2010-11 Shri Y. Shanmuga Durai, L/H Of Acit Late S.Yogarathinam Vs. Circle -1(2) Old No.24, No.14, Chennai. 17/24, Ramanathan Street, T.Nagar, Chennai-600 017. Pan: Aakpy-9845-P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Mr. N. Arjun Raj, Advocate ""यथ"क"ओरसे/Respondent By : Mr. Ar.V. Sreenivasan, Cit सुनवाई क" तारीख/Date Of Hearing : 06.03.2025 घोषणा क" तारीख/Date Of Pronouncement : 17.03.2025

section 47 shall apply to the following transfers:- (i) Any distribution capital assets on the total or partial partition of HUF; (ii) ….. (iii) any transfer of the capital asset under a gift or Will or irrevocable trust (iv) …..” vi) There were no monetary consideration either received or paid in these transactions between the brothers warranting to invoke the rigors

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

In the result, the appeal of the assessee is allowed

sections 14A and 68 of the Act. By making an addition u/s.69 of the Act, the AO has clearly exceeded the jurisdiction vested in him and travelled beyond the scope of limited scrutiny. 96. For this reason, we are unable to subscribe to the reasoning adopted by the Ld.CIT(A) that since the asset was included in the gain arising

PENTA MEDIA GRAPHICS LTD.,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1402/Chny/2015 िनधा"रण वष"/Assessment Year: 2000-01 M/S. Penta Media Graphics Ltd., The Deputy Commissioner Of ‘Taurus’, No. 25, First Main Road, Vs. Income Tax, Media Circle I, Room No. 311, 3Rd Floor, New Block, United India Colony, Kodambakkam, Chennai 600 024. 121, Mahatma Gandhi Road, Nungambakkam, Chennai 600 034. [Pan: Aaacp1647B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Baskar, Advocate & : Smt. Sree Valli Lakshmi, Advocate ""थ" की ओर से/Respondent By None [Dept. Letter Submission] : सुनवाई की तारीख/ Date Of Hearing 12.04.2023 : घोषणा की तारीख /Date Of Pronouncement : 10.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai Dated 30.03.2015 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

164,92,63,742/- by making the additions assessing the capital gains on goodwill at ₹.126,67,00,000/ as against the original capital gain in goodwill assessed at ₹.31,74,40,000/-. 4. Aggrieved against the original order, the assessee has filed an appeal before the CIT(A) vide ITA No. 156/07-08 and also against the order under section

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

164 of the Act. m. Once the shares are determinate, the income is to be taxed of that respective sharer or the beneficiaries in the hands of beneficiary and not in the hands of the trustee. Section 115U provides special benefits to certain SEBI registered entities (Trust & Company) which does not fall under the purview of Section

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

164 of the Act. m. Once the shares are determinate, the income is to be taxed of that respective sharer or the beneficiaries in the hands of beneficiary and not in the hands of the trustee. Section 115U provides special benefits to certain SEBI registered entities (Trust & Company) which does not fall under the purview of Section

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

164 of the Act. m. Once the shares are determinate, the income is to be taxed of that respective sharer or the beneficiaries in the hands of beneficiary and not in the hands of the trustee. Section 115U provides special benefits to certain SEBI registered entities (Trust & Company) which does not fall under the purview of Section

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

164 of the Act. m. Once the shares are determinate, the income is to be taxed of that respective sharer or the beneficiaries in the hands of beneficiary and not in the hands of the trustee. Section 115U provides special benefits to certain SEBI registered entities (Trust & Company) which does not fall under the purview of Section

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

164 of the Act. m. Once the shares are determinate, the income is to be taxed of that respective sharer or the beneficiaries in the hands of beneficiary and not in the hands of the trustee. Section 115U provides special benefits to certain SEBI registered entities (Trust & Company) which does not fall under the purview of Section

LALITHA KUMARI PRAKASH CHAND,CHENNAI vs. ACIT NON CORP. WARD 10(1), CHENNAI

In the result, appeal filed by the assessee is treated as

Bench: Shri V. Durga Rao & Shri G. Manjunatha

164/-.” 3. Brief facts of the case are that the assessee is an individual filed her return of income for the assessment year 2015-16 on 31.08.2015 declaring total income of Rs.98,67,300/-. The case was selected for limited scrutiny assessment under CASS and accordingly, notice u/s.143(2) of the Income Tax Act, 1961, dated 21.09.2016 was issued. During

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital gains at ` 3,68,30,254/- iii) Disallowance of bad debts of rs 14,21,618/- 3. The ld. AR submitted that the assessee is a public limited company with objects, inter alia, of manufacturing yarn. The Assessee filed the return of income on 30/03/2011 for the Assessment year 2009-10, admitting a total income

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital gains at ` 3,68,30,254/- iii) Disallowance of bad debts of rs 14,21,618/- 3. The ld. AR submitted that the assessee is a public limited company with objects, inter alia, of manufacturing yarn. The Assessee filed the return of income on 30/03/2011 for the Assessment year 2009-10, admitting a total income

SARRANGAN ASHOK,CHENNAI vs. ITO NON CORPORATE WARD 15(1), CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri Inturi Rama Raoआयकर अपील सं./I.T.A.No.544/Chny/2019 ("नधा"रण वष" / Assessment Year: 2015-16) Vs The Income Tax Officer, Shri Sarrangan Ashok, H37/12, Gita Apartments, Non Corporate Ward – 15(1),. Kumanan Street, Kalashektra Chennai. Colony, Besant Nagar, Chennai – 600 090. Pan: Aafpa6211N (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 45(3) of the Act was introduced in order to overcome the decision of the Hon’ble Supreme Court in the case of Karthikeya V Sarabhai, reported in 94 Taxman 164 which held that there is no liability to capital gains

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 gain. Ground No.8 is related to interest u/s 234A/B/C. Ground No.9 is related to penalty levied. Accordingly, the ground of appeal is disposed of in the subsequent paragraphs. 6.2 During appeal proceedings, the appellant has filed written submission. Relevant portion of submission is reproduced below: 3. The following case laws are relied upon where in it has been held

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 gain. Ground No.8 is related to interest u/s 234A/B/C. Ground No.9 is related to penalty levied. Accordingly, the ground of appeal is disposed of in the subsequent paragraphs. 6.2 During appeal proceedings, the appellant has filed written submission. Relevant portion of submission is reproduced below: 3. The following case laws are relied upon where in it has been held

D DHANAMMAL,CHENNAI vs. ITO, NON CORPORATE WARD 22(1), CHENNAI

In the result, all the appeals for assessment year 2008-09,

Bench: Shri George Mathan & Shri A.Mohan Alankamony"नधा"रण वष" /Assessment Year :2009-10

Section 2(14) of the Act and consequently cannot be considered as capital asset within a meaning of sec.2(14) of the Act and no capital gains was liable to be levied in respect of the compulsory acquisition of the said land by Government of Tamilnadu. 3. In reply, the ld.D.R vehemently supported the order of the Ld.CIT

DURAIRAJ BABU,CHENNAI vs. ITO, NON CORPORATE WARD 22(1), CHENNAI

In the result, all the appeals for assessment year 2008-09,

Bench: Shri George Mathan & Shri A.Mohan Alankamony"नधा"रण वष" /Assessment Year :2009-10

Section 2(14) of the Act and consequently cannot be considered as capital asset within a meaning of sec.2(14) of the Act and no capital gains was liable to be levied in respect of the compulsory acquisition of the said land by Government of Tamilnadu. 3. In reply, the ld.D.R vehemently supported the order of the Ld.CIT

D NANDAKUMAR,CHENNAI vs. ITO WARD 1(3), CHENNAI

In the result, all the appeals for assessment year 2008-09,

Bench: Shri George Mathan & Shri A.Mohan Alankamony"नधा"रण वष" /Assessment Year :2009-10

Section 2(14) of the Act and consequently cannot be considered as capital asset within a meaning of sec.2(14) of the Act and no capital gains was liable to be levied in respect of the compulsory acquisition of the said land by Government of Tamilnadu. 3. In reply, the ld.D.R vehemently supported the order of the Ld.CIT

ITO, TAMBARAM vs. GEETHA VENUGOPAL, CHENNAI

Bench: Shri Chandra Poojari & Shri V. Durga Raoआयकर अपील सं./ I.T.A. No.636/Mds/2013 ("नधा"रण वष" / Assessment Year : 2009-2010)

164/(3)/87/ITA- I, dated 06.01.1994, as amended by notification No.11186 dated 28th I.T.A.No.636/Mds/2013. :- 6 -: December, 1999 provided that agricultural land situated in area lying within the distance not exceeding 8 km from the local limits of municipality, it covered by amended definition ‘’Capital Assets”. The Central Government in exercise of such powers as issued before notification as amended

M V SUBRAMANIAN FAMILY TRUST,CHENNAI vs. ITO, NCW-1(1), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1087/Chny/2025 िनधा"रण वष"/Assessment Year:2021-22 M/S. M V Subramanian Family The Income Tax Officer, Trust, Non-Corporate Ward 1(1), 10, Valliammai Achi Road, Vs. Chennai. Kotturpuram, Chennai – 600 085. Pan: Aaetm 9151C (""यथ"/Respondent) (अपीलाथ"/Appellant) अपीलाथ" क" ओर से/Appellant By : Shri Ashwin, Ca ""यथ" क" ओर से/Respondent By : Ms. Anitha, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 24.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.08.2025

gains as well as from other sources. The trust submitted its income tax return for the pertinent assessment year on 18.11.2021, reporting an income of Rs.82,21,860/-. An intimation under section 143(1) of the Income Tax Act (hereinafter referred to as the ‘Act’) was issued on 13.10.2022, which applied a surcharge of 37% on dividend income rather than