ITO(EXCEMPTION) TRICHY, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, both ITA No

Bench: Shri Veeravalli Durga Rao, Jm & Shri Girish Agrawalita Nos.1534 & 1535/Chny/2019 Assessment Years: 2009-10 & 2011-12 Income-Tax Officer, Grama Vidiyal Trust, (Exemptions), Trichy Vs. No. 44, Williams Road, Cantonment, Trichy-620001 (Pan: Aaatg2928F) (Appellant) (Respondent) Present For: Appellant By : Shri N. V. Balaji, Advocate Respondent By : Shri Arv. Sreenivasan, Addl. Cit Date Of Hearing : 31.05.2022 Date Of Pronouncement : 24.08.2022 O R D E R Per Girish Agrawal: Both These Appeals By Revenue Are Directed Against The Separate Orders Of Ld. Cit(A)-1, Trichy Vide Ita No. 156/2017-18/Cit(A)-1/Try Dated 04.03.2019 & 163/2017-18/Cit(A)-1/Try Dated 22.02.2019 Against The Separate Orders Of Ld. Ito, Exemptions Ward, Trichy, Passed U/S 143(3) R.W.S. 254 Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Both Dated 30.12.2017 For Ays 2009-10 & 2011-12. 2. First We Take Up Ita No. 1534/Chny/2019 For Ay 2009-10 For Which The Revised Ground Taken By The Revenue Is As Under:

capital gains claimed by the assessee u/s. 11(1A) of the Act more particularly when this Co-ordinate Bench in its earlier order dated 30.06.2016, wherein the impugned matter was set aside to the file of Ld. AO, has categorically held that case of assessee is hit by the proviso to section 2(15) of the Act and the assessee

ITO(EXCEMPTION) TRICHY, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, both ITA No

Bench: Shri Veeravalli Durga Rao, Jm & Shri Girish Agrawalita Nos.1534 & 1535/Chny/2019 Assessment Years: 2009-10 & 2011-12 Income-Tax Officer, Grama Vidiyal Trust, (Exemptions), Trichy Vs. No. 44, Williams Road, Cantonment, Trichy-620001 (Pan: Aaatg2928F) (Appellant) (Respondent) Present For: Appellant By : Shri N. V. Balaji, Advocate Respondent By : Shri Arv. Sreenivasan, Addl. Cit Date Of Hearing : 31.05.2022 Date Of Pronouncement : 24.08.2022 O R D E R Per Girish Agrawal: Both These Appeals By Revenue Are Directed Against The Separate Orders Of Ld. Cit(A)-1, Trichy Vide Ita No. 156/2017-18/Cit(A)-1/Try Dated 04.03.2019 & 163/2017-18/Cit(A)-1/Try Dated 22.02.2019 Against The Separate Orders Of Ld. Ito, Exemptions Ward, Trichy, Passed U/S 143(3) R.W.S. 254 Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Both Dated 30.12.2017 For Ays 2009-10 & 2011-12. 2. First We Take Up Ita No. 1534/Chny/2019 For Ay 2009-10 For Which The Revised Ground Taken By The Revenue Is As Under:

capital gains claimed by the assessee u/s. 11(1A) of the Act more particularly when this Co-ordinate Bench in its earlier order dated 30.06.2016, wherein the impugned matter was set aside to the file of Ld. AO, has categorically held that case of assessee is hit by the proviso to section 2(15) of the Act and the assessee

SUBRAMANYAM BASKARAN,CHENNAI vs. ITO, CHENNAI

In the result, the appeal of the assessee is allowed for 8

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

197/- and assessed total income. Aggrieved by the order, the assessee filed an appeal before Commissioner of Income Tax (Appeals). In the appellate proceedings, the ld. Authorised 4. Representative of assessee argued the grounds and reiterated the facts and the findings of the ld. Assessing Officer. The ld. Assessing Officer erred in restricting the Long term capital gains

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

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

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 -

197 8 Parasoft Corporation USA USD 3,456 1,55,002 9 Tibco Software Inc USA USD 3,834 1,74,961 10 Xenos Group Inc Canada USD 1,59,300 74,20,194 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

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

ACIT, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, appeal of Revenue in 345/2013 is partly allowed for

Bench: Shri Chandra Poojari & Shri G.Pavan Kumar

section of the public and it does not involve any charitable activity. Therefore, looking into the activities carried on by the assessee, we fully agree with the findings of the AO and this view of ours is squarely covered by the decision of the Tribunal in the case of Janalakshmi Social Services (33 SOT 197) (Bang.). The assessee relied

ACIT, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, appeal of Revenue in 345/2013 is partly allowed for

Bench: Shri Chandra Poojari & Shri G.Pavan Kumar

section of the public and it does not involve any charitable activity. Therefore, looking into the activities carried on by the assessee, we fully agree with the findings of the AO and this view of ours is squarely covered by the decision of the Tribunal in the case of Janalakshmi Social Services (33 SOT 197) (Bang.). The assessee relied

ITO, TRICHY vs. GRAMA VIDIYAL TRUST, TRICHY

In the result, appeal of Revenue in 345/2013 is partly allowed for

Bench: Shri Chandra Poojari & Shri G.Pavan Kumar

section of the public and it does not involve any charitable activity. Therefore, looking into the activities carried on by the assessee, we fully agree with the findings of the AO and this view of ours is squarely covered by the decision of the Tribunal in the case of Janalakshmi Social Services (33 SOT 197) (Bang.). The assessee relied

UMA REDDY ,CHENNAI vs. ITO NON CORPORATE WARD 3(5) , CHENNAI

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं/.I.T.A. No. 1870/Chny/2017 "नधा"रण वष"/Assessment Year : 2008-09 Smt. Uma Reddy, The Income Tax Officer, 22, Rutland Gate, 4Th Street, Vs. Non-Corporate Ward -3(5), Thousand Lights, Chennai. Chennai – 600 006. [Pan: Aaapu 7292C] ('(यथ*/Respondent) (अपीलाथ"/Appellant) Assessee By : Shri. S. Sridhar, Advocate : Shri Guru Bashyam, Jcit Revenue By सुनवाईक2तार"ख/Date Of Hearing : 23.01.2018 घोषणाक2तार"ख/Date Of Pronouncement : 20.04.2018

section 50C, adopted the guideline value fixed by the per stamp valuation authority at Rs. 1,07,06,400/- as the sale consideration for the purpose of computation of long term capital gains. Since, the assessee deposited in the capital gains scheme on 26.09.2008, which was beyond the due date , i.e., 31.07.2008, of filing the return, relying on the Kerala

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

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2601/Chny/2024 निर्धारण वर्ष / Assessment Year: 2015-16 M/S. Ambattur Developers Private Limited, (Amalgamated With Ambattur Hotels Private Limited) No. 86/E2, Industrial Estate, Ambattur, Chennai - 600 058. Tamil Nadu. [Pan: Aaeca-7490-D] (अपीलार्थी/Appellant) Income Tax Officer, Vs. Corporate Ward- 1(1), Chennai. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. R. Vijayaraghavan, Advocate : Shri. Bipin, C.N., Cit सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 11.11.2025 आदेश /Order Per S.R.Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A)) For The Assessment Year 2015-16, Vide Order Dated 12.08.2024. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

gains computation under Section 50C. 13) The combined value of the land and the Hotel building with the facilities is well worth the Rs.365.12 Crores and the total tangible assets Rs.470.11 Crores as taken by the Appellant and the value of intangible assets at Rs.26 Crores as given by Registered valuers. Neither the AO or the CIT(A) have

TAMIL NADU CRICKET ASSOCIATION,CHENNAI vs. DDIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1535, 1536 & 1537/Mds/2014 "नधा"रण वष" / Assessment Years : 2008-09 To 2010-11 M/S Tamil Nadu Cricket Association, The Deputy Director Of No.5, M.A.Chidambaram Stadium, V. Income Tax (Exemptions), Victoria Hostel Road, Chennai - 600 034. Chepauk, Chennai - 600 005. Pan : Aaaat 0398 M (अपीलाथ"/Appellant) (""यथ"/Respondent)

197 of the paper-book. The assessee challenged the correctness of the order of the Director of Income Tax (Exemptions) cancelling the registration granted under Section 12AA of the Act, in I.T.A. No.396/Mds/2012. This Tribunal by an order dated 22.02.2013, confirmed the order of the Director of Income Tax (Exemptions). The assessee carried the matter before the High Court

TAMIL NADU CRICKET ASSOCIATION,CHENNAI vs. DDIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1535, 1536 & 1537/Mds/2014 "नधा"रण वष" / Assessment Years : 2008-09 To 2010-11 M/S Tamil Nadu Cricket Association, The Deputy Director Of No.5, M.A.Chidambaram Stadium, V. Income Tax (Exemptions), Victoria Hostel Road, Chennai - 600 034. Chepauk, Chennai - 600 005. Pan : Aaaat 0398 M (अपीलाथ"/Appellant) (""यथ"/Respondent)

197 of the paper-book. The assessee challenged the correctness of the order of the Director of Income Tax (Exemptions) cancelling the registration granted under Section 12AA of the Act, in I.T.A. No.396/Mds/2012. This Tribunal by an order dated 22.02.2013, confirmed the order of the Director of Income Tax (Exemptions). The assessee carried the matter before the High Court

TAMIL NADU CRICKET ASSOCIATION,CHENNAI vs. DDIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1535, 1536 & 1537/Mds/2014 "नधा"रण वष" / Assessment Years : 2008-09 To 2010-11 M/S Tamil Nadu Cricket Association, The Deputy Director Of No.5, M.A.Chidambaram Stadium, V. Income Tax (Exemptions), Victoria Hostel Road, Chennai - 600 034. Chepauk, Chennai - 600 005. Pan : Aaaat 0398 M (अपीलाथ"/Appellant) (""यथ"/Respondent)

197 of the paper-book. The assessee challenged the correctness of the order of the Director of Income Tax (Exemptions) cancelling the registration granted under Section 12AA of the Act, in I.T.A. No.396/Mds/2012. This Tribunal by an order dated 22.02.2013, confirmed the order of the Director of Income Tax (Exemptions). The assessee carried the matter before the High Court

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