DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. SATHYABAMA RAMACHANDRAN , ALWARTHIRUNAGAR

The appeal of the revenue is dismissed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

section 45(4) of the Act and the said amount would be chargeable to capital gains. For the above proposition, the ld. DR placed reliance on the judgement of the Hon’ble Supreme Court in the case of CIT v. Mansukh Dyeing and Printing Mills 449 ITR 439 (SC). We have carefully gone through the above judgement

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. RAMASAMY RAJASEHAR, PERAMBALUR

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

197(Kar) [Page 53 para 36 and page 91 para 53] [SLP dismissed by Hon’ble Supreme court dated 21.10.2024], where it was categorically held as follows: “...Further, satisfaction note is required to be recorded under Section 153C of the IT Act for each Assessment Year and in the impugned proceedings, a consolidated satisfaction note has been recorded for different

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

197\n\n8\nParasoft\nCorporation\nUSA\nUSD\n3,456\n1,55,002\n\n9\nTibco Software\nInc\nUSA\nUSD\n3,834\n1,74,961\n\n10\nXenos Group\nInc\nCanada\nUSD\n1,59,300\n74,20,194\n\n11\nZoho Corp\nUSA\nUSD\n2,923\n1,31,798\n\n12\nZoho Corp\nUSA\nUSD

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

197\nComplete Inc\n8\nParasoft\nUSA\nUSD\n3,456\n1,55,002\nCorporation\n9\nTibco Software\nUSA\nUSD\n3,834\n1,74,961\nInc\n10\nXenos Group\nCanada\nUSD\n1,59,300\n74,20,194\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

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

197\n8\nParasoft\nCorporation\nUSA\nUSD\n3,456\n1,55,002\n9\nTibco Software\nInc\nUSA\nUSD\n3,834\n1,74,961\n10\nXenos Group\nInc\nCanada\nUSD\n1,59,300\n74,20,194\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

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

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

197\n| Complete Inc\n| 8 | Parasoft\n| USA\n| USD\n| 3,456\n| 1,55,002\n| Corporation\n| 9 | Tibco Software\n| USA\n| USD\n| 3,834\n| 1,74,961\n| Inc\n| 10 | Xenos Group\n| Canada\n| USD\n| 1,59,300\n| 74,20,194\n| Inc\n| 11 | Zoho Corp

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

197\n8\nParasoft\nCorporation\nUSA\nUSD\n3,456\n1,55,002\n9\nTibco Software\nInc\nUSA\nUSD\n3,834\n1,74,961\n10\nXenos Group\nInc\nCanada\nUSD\n1,59,300\n74,20,194\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

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

197\n8\nParasoft\nCorporation\nUSA\nUSD\n3,456\n1,55,002\n9\nTibco Software\nInc\nUSA\nUSD\n3,834\n1,74,961\n10\nXenos Group\nInc\nCanada\nUSD\n1,59,300\n74,20,194\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

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

197\n8\nParasoft\nCorporation\nUSA\nUSD\n3,456\n1,55,002\n9\nTibco Software\nInc\nUSA\nUSD\n3,834\n1,74,961\n10\nXenos Group\nInc\nCanada\nUSD\n1,59,300\n74,20,194\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

M/S. AMBATTUR DEVELOPERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(1), CHENNAI

In the result the appeal of the assessee is allowed

gains computation under Section 50C.\n13) The combined value of the land and the Hotel building with\nthe facilities is well worth the Rs.365.12 Crores and the total tangible\nassets Rs.470.11 Crores as taken by the Appellant and the value of\nintangible assets at Rs.26 Crores as given by Registered valuers.\nNeither the AO or the CIT(A) have

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular provides that the difference between the bid price of a deep discount bonds and its redemption price which is actually paid the time of maturity, will continue

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular provides that the difference between the bid price of a deep discount bonds and its redemption price which is actually paid the time of maturity, will continue

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular provides that the difference between the bid price of a deep discount bonds and its redemption price which is actually paid the time of maturity, will continue

DCIT , CENTRAL CIRCLE - 3, COIMBATORE vs. SHRI D VIJAY MOHAN, COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

197 1,24,51,234 38,47,432 Total: 1,62,98,666 6. The assessee is noted to have also admitted in her statement recorded u/s 132(4) of the Act that, the notings in this loose sheet pertained to her and her spouse and her entity, M/s Shrimayi Enterprises. It was further explained that, the notings contained

DCIT , CENTRAL CIRCLE - 3, COIMBATORE vs. SMT.VANITHA MOHAN, COIMBATRE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

197 1,24,51,234 38,47,432 Total: 1,62,98,666 6. The assessee is noted to have also admitted in her statement recorded u/s 132(4) of the Act that, the notings in this loose sheet pertained to her and her spouse and her entity, M/s Shrimayi Enterprises. It was further explained that, the notings contained

VANITHA MOHAN,COIMBATORE vs. DCIT CENTRAL CIRCLE-3, COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

197 1,24,51,234 38,47,432 Total: 1,62,98,666 6. The assessee is noted to have also admitted in her statement recorded u/s 132(4) of the Act that, the notings in this loose sheet pertained to her and her spouse and her entity, M/s Shrimayi Enterprises. It was further explained that, the notings contained

VIJAY MOHAN,COIMBAORE vs. DCIT, CENTRAL CIRCLE-(3)(I/C), COIMBATORE

In the result, the appeal by the assessee in ITA No

Bench: Shri Aby T. Varkey & Shri S.R.Raghunathaआयकर अपील सं./ Ita No.267/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14 V. Shri D. Vijay Mohan, The Dcit, No.232, Tea Estates, Central Circle-3, Race Course Road, Coimbatore. Coimbatore-641 018. [Pan: Aatpm 1202 F] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./ Ita No.268/Chny/2022 िनधा"रण वष"/Assessment Year: 2013-14

197 1,24,51,234 38,47,432 Total: 1,62,98,666 6. The assessee is noted to have also admitted in her statement recorded u/s 132(4) of the Act that, the notings in this loose sheet pertained to her and her spouse and her entity, M/s Shrimayi Enterprises. It was further explained that, the notings contained