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

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. The appellant being innovative in approach constructed an energy efficient greenhouse in line with the various renewable energy initiatives undertaken by the Government of India, which cannot become a hurdle in accepting the construction of a house for allowing the benefit of54F deduction. Therefore, the AO is hereby directed to allow the 54F deduction and delete

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

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

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. R. Raghunatha, Hon'Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Cognizant Technology Solutions Vs The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai - 600 096. (प्रत्यर्थी/Respondent) Pan: Aaacd 3312M (अपीलार्थी/Appellant) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) The Asst. Commissioner Of Vs Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai - 600 096. Pan: Aaacd 3312M (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निधारिती की ओर से/Assessee By राजस्व की ओर से /Revenue By : Shri N.V. Balaji, Advocate : Shri R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 11.03.2025 घोषणा की तारीख/Date Of Pronouncement : 16.05.2025 - 2 -

194 11 Zoho Corp USA USD 2,923 1,31,798 12 Zoho Corp USA USD 8,320 3,76,480 Total of payments (with 'make available' clause) (A) 2,62,162 1,20,46,349 Payments made towards Software AMC - countries without 'make available' clause 1 SAP AG Germany EUR 60,000 35,77,464 Total of payments (without

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

DILIP KAPUR,PONDICHERRY vs. ACIT, NFAC, CIRCLE 1 , PONDICHERRY

In the result the appeal of the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 984/Chny/2024 िनधा"रणवष" / Assessment Year: 2014-15 Dilip Kapur The Assistant Commissioner Of 7, Saint Martin Street, Income Tax, Pondicherry (Ut), Circle -1, Pondicherry – 605 001. Pondicherry – 605 003. [Pan: Adspd-4530-H ] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Vikram Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 22.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 06.11.2024

194 CTR 241) where in the HC's have upheld penalty where returned loss is reduced under Explanation 4(b) to S.271(1)(c) which reads as follows: :-7-: ITA. No: 984/Chny/2024 "Section 271(1)(c) Explanation 4(b) where in any case the amount of income in respect of which particulars have been concealed or inaccurate particulars have been

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), CHENNAI, CHENNAI vs. MOHAMED MUYEENUDDIN PAZHOOR KOCHU MOHAMED, KANCHIPURAM

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

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 923/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 The Deputy Commissioner Of Shri Mohamed Muyeenuddin Income Tax, Vs. Pazhoor Kochu Mohamed, Central Circle 1(2), E1, 2Nd Main Road, Chennai. Juhu Beach, Sholinganallur S.O., Uthandi, Kanchipuram – 600 119. Pan: Aaipm 4366P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Shiva Srinivas, Cit ""यथ" क" ओर से/Respondent By : Shri Darshan Bothra, Ca सुनवाई क" तारीख/Date Of Hearing : 21.10.2025 घोषणा क" तारीख/Date Of Pronouncement : 22.10.2025

section 194 IA on the full sale consideration, was claimed by assessee in his Return of Income filed for assessment year 2018-19. 6. For these grounds and any other ground including amendment of grounds that may be raised during the course of the appeal proceedings, the order of learned CIT(Appeals) may be set aside and that