V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

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

4. The brief facts of the case insofar the cross appeals for the block period under consideration in IT(SS)A No.153 & 162/Mds/2003 are as follows: The assessee is a Managing Director of M/s.Pentafour Products Limited, receiving income under the head “Salary”, dividend income as well as the sitting fees during the block period. The Income Tax Department had conducted

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

sections 36(1)(vii) rws 36(2) of the Income Tax Act”. 9.3 Further, it is submitted that no such information was ever asked for in the course of appellate proceedings. He submitted that the claim of bad debts needs to be allowed in view of the following judgments: (i) CIT vs. Ahmedabad Electricity Company Limited

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

sections 36(1)(vii) rws 36(2) of the Income Tax Act”. 9.3 Further, it is submitted that no such information was ever asked for in the course of appellate proceedings. He submitted that the claim of bad debts needs to be allowed in view of the following judgments: (i) CIT vs. Ahmedabad Electricity Company Limited

M.KIRAN KUMAR,CHENNAI vs. ACIT CENTRAL CIRCLE-1(4), CHENNAI

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

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

172 at Para 17 held; “17. Section 2(22)(e) of the Act is designed to strike balance, i.e., advance or loan to a shareholder and that the word 44 I.T.A. No.3374/CHNY/2019 shareholder can mean only a registered shareholder. A beneficial owner of shares whose name does not appear in the Register of shareholders of the Company cannot be stated

K.K.SRINIVASAN,SALEM vs. ITO, SALEM

In the result, appeal of the assessee is allowed

Bench: Shri Abraham P. George]

Capital Gain Scheme should have been made prior to due date under section 139(1) is untenable (259 CTR 388 P&H) - Copy enclosed. (b) Investment under section 54 B can be made within the period prescribed by Section 139(4) - 172

SESHANK MAHADEV,CHENNAI vs. DEPUTY DIRECTOR OF INCOME TAX, CPC BENGALURU

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

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2274/Chny/2025 िनधा"रण वष"/Assessment Year: 2024-25 Seshank Mahadev, Vs. The Income Tax Officer, Ak 27, Tas Enclave, E2, Golden King Corporate Ward 3(1), Villa Apartments, Anna Nagar, Chennai. Chennai 600 040. [Pan:Olwps5532Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Varadharajan, F/O Of Assessee ""थ" की ओर से/Respondent By : Shri C.P. Solomon, Jcit सुनवाई की तारीख/ Date Of Hearing : 22.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 02.06.2025 Passed By The Addl./Jcit(A), Indore For The Assessment Year 2024-25. 2. At The Outset, We Note That The Cpc Denied The Rebate Claimed By The Assessee Under Section 87A Of The Income Tax Act, 1961 [“Act” In Short] Vide Intimation Order Under Section 143(1) Of The Act Dated 12.11.2024. Against The Intimation Order, The Assessee Preferred An 2

172/- and it was contended that when it is below ₹.1,00,000/-, the rebate under section 87A of the Act is allowable. 4 I.T.A. No.2274/Chny/25 We find the same is acceptable and admittedly, the income under long term capital gains

DCIT CENTRAL CIRCLE 2(20, CHENNAI vs. RAMA NARAYANAN (LATE), L/H SHRINARAYANAN RAMASWAMY, CHENNAI

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.3080/Chny/2018 िनधा"रण वष" /Assessment Year: 2012-13 The Dy. Commissioner – V. Mr.Rama Narayanan (Late) Of Income Tax, L/H Mr.Narayanan- Central Circle-2(2), Ramasamy, Chennai. No.14/19, Saraswathi Street, Mahalingapuram, Chennai-600 034. [Pan: Achpr 5912 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

4 :: Crs. has been treated as income from other sources and added back to total income. The relevant findings of the AO are as under: 7. The reply of the assessee was verified and in this case the facts of the case were as under. The assessee has filed the Original ROI on 13.03.2013. As per this ROI the assessee

DCIT, NCC - 2 (1),, CHENNAI vs. SHRI SAILENDRA KUMAR KETHINENI,, CHENNAI

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

Bench: Shri Inturi Rama Rao & Shri Duvvuru R.L. Reddyआयकर अपील सं./I.T.A. No. 2263/Chny/2019 िनधा"रण वष"/Assessment Year: 2012-13 & C.O. No. 104/Chny/2019 [In I.T.A. No. 2263/Chny/2019] The Deputy Commissioner Of Shri Sailendra Kumar Kethineni, Income Tax Vs. No. 61, Greenways Road, R.A. Puram, Non Corporate Circle 2(1), Chennai 600 028. Chennai 600 034. [Pan:Aafpk8983P] (अपीलाथ" /Appellant) (Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By : Shri Abani Kanta Nayak, Cit ""थ" की ओर से/Respondent By : Shri M. Karunakaran, Advocate सुनवाई की तारीख/ Date Of Hearing : 18.02.2020 घोषणा की तारीख /Date Of Pronouncement : 24.02.2020 आदेश /O R D E R Per Duvvuru Rl Reddy: The Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 10.04.2019 Relevant To The Assessment Year 2012-13. The Effective Grounds Raised By The Revenue Are That The Ld. Cit(A) Has Erred In Deleting The Addition Made In Respect Of Employees Contribution Towards Pf/Esi & Treating The Sale Of Land In Sholinganallur As Capital Asset On The Basis Of Book Entry Without Appreciating That Book Entries Are Not Determinative Of Income Of Assessee.

4 I.T.A. No. 2263/Chny/19 & C.O. No. 104/Chny/19 of ₹.12,89,52,958/- in the return of income. In the course of assessment proceedings, the Assessing Officer found that the profit on sale of another property viz., Anandavalli Nagar property, was admitted as business income, whereas, the profit on sale of land at Sholinganallur was shown under Capital Gains. When

ACIT, TRICHY vs. SHRI R.VISWANATHAN, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

4 Ms. Rajalakshmi 5,00,000/- 5 Shri. Dinesh 6,91,532/- Total 26,91,532/- Vide Notice u/s 142(1) dated 30-01-2012, the assessee was requested to give the details of all the above loans along with ledger extracts of I.T.A.Nos.2036 & 2037, 2039 :- 75 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. the above persons appearing

SRI PONNAIYAH RAMAJAYATHAMMAL EDUCTIONAL & CHARITABLE TRUST,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

4 Ms. Rajalakshmi 5,00,000/- 5 Shri. Dinesh 6,91,532/- Total 26,91,532/- Vide Notice u/s 142(1) dated 30-01-2012, the assessee was requested to give the details of all the above loans along with ledger extracts of I.T.A.Nos.2036 & 2037, 2039 :- 75 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. the above persons appearing

ACIT, TRICHY vs. P.MURUGESAN, THANJAVUR

Bench: Shri Chandra Poojari & Shri V. Durga Rao

4 Ms. Rajalakshmi 5,00,000/- 5 Shri. Dinesh 6,91,532/- Total 26,91,532/- Vide Notice u/s 142(1) dated 30-01-2012, the assessee was requested to give the details of all the above loans along with ledger extracts of I.T.A.Nos.2036 & 2037, 2039 :- 75 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. the above persons appearing

ACIT, TRICHY vs. SHRI P.JANAKAR, DINDIGUL

Bench: Shri Chandra Poojari & Shri V. Durga Rao

4 Ms. Rajalakshmi 5,00,000/- 5 Shri. Dinesh 6,91,532/- Total 26,91,532/- Vide Notice u/s 142(1) dated 30-01-2012, the assessee was requested to give the details of all the above loans along with ledger extracts of I.T.A.Nos.2036 & 2037, 2039 :- 75 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. the above persons appearing

P.MURUGESAN,CHENNAI vs. ACIT, TRICHY

Bench: Shri Chandra Poojari & Shri V. Durga Rao

4 Ms. Rajalakshmi 5,00,000/- 5 Shri. Dinesh 6,91,532/- Total 26,91,532/- Vide Notice u/s 142(1) dated 30-01-2012, the assessee was requested to give the details of all the above loans along with ledger extracts of I.T.A.Nos.2036 & 2037, 2039 :- 75 -: to 2045/Mds/2013, 1884 to 1890/ 2013, 462/2011 & 649/2011. the above persons appearing

S.PRAVEEN KUMAR,CHENNAI vs. ITO WARD 1 (TIRUVALLUR), KANCHEEPURAM

In the result, the appeal of the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.1905/Chny/2018 "नधा"रण वष" /Assessment Year : 2011-2012. Shri. S. Praveen Kumar, Vs. The Income Tax Officer, No.33/3, Ground Floor, Ward I, (Tiruvallur), Veerappan Street, Kancheepuram. Sowcarpet, Chennai 600 001. [Pan Aaipp 9343H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital gains with necessary evidences. There was no addition whatsoever made for the reason cited in the notice issued under Section 148 of the Act. In our opinion, once the alleged escaped of income, is found not to be any escapement at all, then an addition made for items other than on which the reopening was attempted would not stand

DCIT CORPORATE CIRCLE 1(2), CHENNAI vs. CHENNAI METRO RAIL LIMITED, CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2180 & 2181/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Chennai Metro Rail Limited, Income Tax, Administrative Building, Chennai Metro Corporate Circle 1(2), Rail Depot, P.H. Road, Opp. To Daniel Chennai 600 034. Thomas School, Koyambedu, Chennai 600 107. [Pan: Aadcc2233K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By : Shri G. Baskar, Advocate सुनवाई की तारीख/ Date Of Hearing : 10.05.2022 घोषणा की तारीख /Date Of Pronouncement : 24.06.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 4, Chennai Dated 14.05.2018 Relevant To The Assessment Years 2013-14 & 2014-15. Since Common Ground Involved, Both The Appeals Were Heard & Being Disposed Of By This Common Order For The Sake Of Convenience. The Only Common Ground Raised In Both The Appeals Relates To Deletion Of Addition Made Towards Interest Income.

capital gain" otherwise Section 56 comes into rescue. As per Section 56 (1) Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head "Income from other sources", if it is not chargeable to income-tax under any of the heads specified in section

DCIT CORPORATE CIRCLE 1(2), CHENNAI vs. CHENNAI METRO RAIL LIMITED, CHENNAI

In the result, both the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2180 & 2181/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Chennai Metro Rail Limited, Income Tax, Administrative Building, Chennai Metro Corporate Circle 1(2), Rail Depot, P.H. Road, Opp. To Daniel Chennai 600 034. Thomas School, Koyambedu, Chennai 600 107. [Pan: Aadcc2233K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By : Shri G. Baskar, Advocate सुनवाई की तारीख/ Date Of Hearing : 10.05.2022 घोषणा की तारीख /Date Of Pronouncement : 24.06.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 4, Chennai Dated 14.05.2018 Relevant To The Assessment Years 2013-14 & 2014-15. Since Common Ground Involved, Both The Appeals Were Heard & Being Disposed Of By This Common Order For The Sake Of Convenience. The Only Common Ground Raised In Both The Appeals Relates To Deletion Of Addition Made Towards Interest Income.

capital gain" otherwise Section 56 comes into rescue. As per Section 56 (1) Income of every kind which is not to be excluded from the total income under this Act shall be chargeable to income-tax under the head "Income from other sources", if it is not chargeable to income-tax under any of the heads specified in section

M/S MADRAS RACE CLUB,CHENNAI vs. DCIT, CENRAL CIRCLE-1(2), CHENNAI

In the result the appeal of the assessee stands allowed

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.688/Chny/2024 िनधा"रण वष"/Assessment Year:2007-2008 M/S.Madras Race Club, The Deputy Commissioner Of Race Course Road, Vs. Income Tax, Guindy Industrial Estate S.O., Central Circle 1(2) Guindy, Chennai Chennai 600 032. Pan: Aaacm 7640R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. R. Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nandakumar, Irs, Cit.

capital gains on sale of this property for the AY 2019-20. The Ld.CIT(A) has recognised this fact in Para 6.9.9 of his order. There cannot be two sales of the same property between the same parties. It is the sale deed executed on 13.04.2018 which is the proper sale of the property and not under the lease deed

JAKHAU SALT COMPANY P LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.367/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. M/S. Jakhau Salt Co. P. Ltd., The Dy. Commissioner – No.2, North Crescent Road, Of Income Tax, T. Nagar, Chennai-600 017. Corporate Circle-1(1), Chennai. [Pan:Aaacw 0867 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr.S.Sridhar, Adv. ""यथ" क" ओर से /Respondent By : Mr.S. Senthil Kumaran, Cit : सुनवाईक"तारीख/Date Of Hearing 09.01.2023 : घोषणाक"तारीख /Date Of Pronouncement 24.02.2023

gains’ from the business or profession. This view is supported by the decision of the Hon’ble Bombay High Court in the case of CIT v. Colgate Palmolive (India) Ltd.(supra), where it has been clearly held that when investment in subsidiary company is for the purpose of its business and the loss on sale of shares