ACIT, CHENNAI vs. TEJENDRA KUMAR GOLECHA, CHENNAI

In the result, the Revenue’s appeal is partly allowed

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddy

194 + 2,88,445] Rs. 21,40,639/- The Long Term Capital Gain from sale of Building at Hospet (Karnataka) Rs. 18,52,195/- Sale consideration from sale of land at Khichan (Rajasthan) Rs. 6,79,120/- ------------------ Rs. 25,31,314/- ------------------ The above amount had been utilized for purchased the new residential property at Muthukadu

ASSISSTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. ANIL REDDY YEDUGURY SANDHINTI, CHENNAI

In the result, appeal filed by the Revenue is dismissed and Cross-

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

Section 45 as the income of the previous year. If the amount of capital gain is equal to or less than the cost of new residential house, including land on which the residential house is constructed, capital gain not be charged". 6.3 Furthermore, the Hon'ble Kerala High Court in the B. Premanandh vs. CIT (2022) 144 taxman.com 194

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

194,480 73,348,325 Return on Capital 21% 13% 38% Weight 3 2 1 (More weights for Latest Year) Weighted Average Return 21% Less Tax @ 35% (7%) Post Tax Return on Capital 14% Add : Risk Premium @ 100% 14% Net Discount Rate 28% 8.4 The assessee submitted that 10% error in Estimation has to be considered. The Risk has been

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

section (1) of sec. 139 discovers any omission or any wrong statement therein, he may furnish a revised return at any time before the expiry of one year from the end of the relevant assessment year or before the completion of assessment whichever is earlier. In this case, the revised return was filed on 24.12.2003, i.e. well beyond one year

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

section (1) of sec. 139 discovers any omission or any wrong statement therein, he may furnish a revised return at any time before the expiry of one year from the end of the relevant assessment year or before the completion of assessment whichever is earlier. In this case, the revised return was filed on 24.12.2003, i.e. well beyond one year

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

capital gain is provided in section 48 of the Act. According to this section, the only deductions which are allowable are - (1) the cost of acquisition of the asset, (2) the cost of any improvement thereto and (3) expenditure incurred wholly and exclusively in connection with the transfer of the asset. The cost of acquisition, in our opinion, means

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

capital gain is provided in section 48 of the Act. According to this section, the only deductions which are allowable are - (1) the cost of acquisition of the asset, (2) the cost of any improvement thereto and (3) expenditure incurred wholly and exclusively in connection with the transfer of the asset. The cost of acquisition, in our opinion, means

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

capital gain is provided in section 48 of the Act. According to this section, the only deductions which are allowable are - (1) the cost of acquisition of the asset, (2) the cost of any improvement thereto and (3) expenditure incurred wholly and exclusively in connection with the transfer of the asset. The cost of acquisition, in our opinion, means

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

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

194\n\n11\nZoho Corp\nUSA\nUSD\n2,923\n1,31,798\n\n12\nZoho Corp\nUSA\nUSD\n8,320\n3,76,480\n\nTotal of payments (with 'make available'\nclause) (A)\n2,62,162\n1,20,46,349\n\nPayments made towards Software AMC - countries without 'make available'\nclause\n\n1\nSAP AG\nGermany\nEUR

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

194\nInc\n11\nZoho Corp\nUSA\nUSD\n2,923\n1,31,798\n12\nZoho Corp\nUSA\nUSD\n8,320\n3,76,480\nTotal of payments (with 'make available'\n2,62,162\n1,20,46,349\nclause) (A)\nPayments made towards Software AMC - countries without 'make available'\nclause\n1\nSAP AG\nGermany\nEUR\n60,000\n35,77,464\nTotal of payments