SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

section 48 of the Act was not considered while erroneously sustaining the exclusion of the garnishee payment to Indian Bank in the computation of Long Term Capital Gains and further ought to have appreciated that the evidence placed on record clearly demonstrated the fact of encumbrance as well as the fact of such payments directly made to M/s Indian Bank

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

section 48 of the Act was not considered while erroneously sustaining the exclusion of the garnishee payment to Indian Bank in the computation of Long Term Capital Gains and further ought to have appreciated that the evidence placed on record clearly demonstrated the fact of encumbrance as well as the fact of such payments directly made to M/s Indian Bank

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

section 48 of the Act was not considered while erroneously sustaining the exclusion of the garnishee payment to Indian Bank in the computation of Long Term Capital Gains and further ought to have appreciated that the evidence placed on record clearly demonstrated the fact of encumbrance as well as the fact of such payments directly made to M/s Indian Bank

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

section 48 of the Act was not considered while erroneously sustaining the exclusion of the garnishee payment to Indian Bank in the computation of Long Term Capital Gains and further ought to have appreciated that the evidence placed on record clearly demonstrated the fact of encumbrance as well as the fact of such payments directly made to M/s Indian Bank

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

section 234B. 3. The brief facts of the case are that the assessee is the Proprietor of M/s. A.K.Exports (hereinafter ‘AKE’), who is engaged in the business of trading of gold jewellery and bullion through his business unit and derives salary from M/s. Lalithaa Jewellery Mart Pvt. Ltd., (hereinafter ‘LJM’). A survey operation u/s.132 of the Income

IDFC FINANCIAL HOLDING COMPANY LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE-2(2), HENNAI

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

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

3), Mumbai Section 234C of the Income-tax Act, 1961 - Interest, chargeable as - Assessment year 199697 - Capital gains accrued to assessee on account of sale of an asset in months of May 1995 and July 1995 - It filed its return for assessment year 1996-97 showing long-term capital gains - Assessee had paid advance tax in instalments after date

PLR TEXTILES LTD.,CHENNAI vs. THE ACIT ,CORPORATE CIRCLE-5(2), CHENNAI

In the result the appeal of the assessee is partly allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकरअपीलसं./Ita No.: 133/Chny/2021 िनधा"रणवष" / Assessment Year: 2005-06 Plr Textiles Ltd., The Acit, 8K, Century Plaza, V. Corporate Circle -5(2), 560-562, Mount Road, Chennai – 641 034. Chennai – 600 018. [Pan: Aaacp-6536-D] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/Appellant By : Mr. R. Vijayaraghavan, Advocate ""थ"कीओरसे/Respondent By : Ms. Anitha, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 06.02.2025 घोषणा की तारीख/Date Of Pronouncement : 27.03.2025 आदेश /O R D E R Per S. R. Raghunatha: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals)-3, Chennai, Vide Ita No.153/Cit(A)-3/2018-19For The Assessment Year 2005-06, Dated 13.03.2020. 2. At The Outset, We Find That There Is A Delay Of 346 Days In Appeal Filed By The Assessee, For Which Petition For Condonation Of Delay Along With Reasons For Delay Has Been Filed. After Considering The Petition Filed By The Assessee, Reason For Delay In Filing The Appeal Was Due To Covid-19 Pandemic & Also Hearing Both The :-2-:

section 234A, 234B and 234C are charged as per law. Demand notice u/s 156 is enclosed. 7. Aggrieved by the order of the AO, the assessee preferred an appeal before the ld. CIT(A) – 3, Chennai. Before the ld.CIT(A), the assessee filed a detailed written submission in respect of delay in passing the order giving effect

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

capital gain the same proportion as the cost of the new asset bears to the net consideration, shall not be charged under section 45: ITA Nos.1535 & 1801/Chny/2024 (AYs 2016-17 & 2015-16) Varadappan Natarajan/ V. Natarajan (Individual) :: 28 :: 69[Provided that nothing contained in this sub-section shall apply where- (a) the assessee (i) owns 70 more than one residential

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

capital gain the same proportion as the cost of the new asset bears to the net consideration, shall not be charged under section 45: ITA Nos.1535 & 1801/Chny/2024 (AYs 2016-17 & 2015-16) Varadappan Natarajan/ V. Natarajan (Individual) :: 28 :: 69[Provided that nothing contained in this sub-section shall apply where- (a) the assessee (i) owns 70 more than one residential

SMART INFORMATION WORLDWIDE INC,CHENNAI vs. ACIT INTERNATIONAL TAXATION 2(2), CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.330/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2016-17) M/S. Smart Information Worldwide Inc. Dcit बनाम/ 49 Sixth Main Road, International Taxation -2(2) Vs. Raja Annamalaipuram, Chennai-600 028. Chennai-6. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-8497-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri V. Ravichandran (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Ar.V.Sreenivasan (Addl.Cit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 06-08-2024

234B when the entire income consisted of capital gains on which tax was deductible at source under section 195. As is evident, the sole that arise for our consideration is addition made by Ld. AO under the head capital gains. 2. The Ld. AR advanced arguments taking support of various documents as placed on record along with various judicial decisions

GOVINDAS PURUSHOTHAMADASS (HUF),CHENNAI vs. ITO NON CORPORATE WARD 3(4), CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 2684/Chny/2018 िनधा"रण वष"/Assessment Year:2011-12 Govindas Purushothamadass (Huf), The Income Tax Officer, No. 3/2, Nowroji Street, Vs. Non Corporate Ward 3(4), Chetpet, Chennai 600 031. 121, Nungambakkam High Road, [Pan:Aabhg4303F] Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 01.08.2022 घोषणा की तारीख /Date Of Pronouncement : 24.08.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 4, Chennai, Dated 10.08.2018 Relevant To The Assessment Year 2011-12. The Assessee Has Raised The Following Grounds: “1.1 The Commissioner Of Income Tax (Appeals) Having Found That The Capital Gains Arising On The Transfer Of Entire Property At Door No.8/17, Shafee Mohammed Street (Now Rutland Gate Second Street) Having Been Offered & Assessed In The A.Y. 2013-14 Went Wrong In Confirming The Action Of The Assessing Officer In Bringing To Tax The Same Capital Gains In This Year. 1.2 The Commissioner Of Income Tax (Appeals) Failed To Note That This Amounts To Double Taxation Of The Same Income Which Is Untenable In Law.

3, 4 & 5 of his order went wrong in giving a totally contrary finding in Para 34 of the Appellate Order. 2.4 The Commissioner of Income Tax (Appeals) having upheld inclusion of the capital gains arising in respect of the three Sale Deeds executed during this year, as a natural corollary ought to have directed the Assessing Officer to exclude

RAMANATHAN ADAIKALAVAN,COIMBATORE, TAMIL NADU vs. THE INCOME TAX OFFICER, NATIONAL FACELESS ASSESSMENT CENTRE, NEW DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.557/Chny/2024 निर्ाारण वर्ा /Assessment Years: 2014-15 Ramanathan Adaikalavan, Deputy Commissioner Of Income Tax, No.80, Ansari Street, Ram Nagar, Non-Corporate Circle-2, Coimbatore-641009. Coimbatore [Pan: Aanpa6846P] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri P.M.Kathir, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Gouthami Manivasagam, Jcit सुिवाई की तारीख/Date Of Hearing : 05.11.2024 घोर्णा की तारीख /Date Of Pronouncement : 06.12.2024 आदेश / O R D E R Per Amitabh Shukla, A.M :

capital gain as envisaged in section 50. 4. Enquiries made by the AO as sequel to information received: NA 5. Findings of the assessing officer :- 5 -: If the facts mentioned in paras 2 and 3 are considered, then there would be an additional demand of Rs. 1,77, 18,004 besides interest u/s 234A and 234B

SMART INFORMATION WORLDWIDE INC,CHENNAI vs. DCIT INTERNATIONAL TAXATION 2(2), CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.329/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2014-15) M/S. Smart Information Worldwide Inc. Dcit बनाम/ 49 Sixth Main Road, International Taxation -2(2) Vs. Raja Annamalaipuram, Chennai-600 028. Chennai-6. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-8497-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri V. Ravichandran (Ca)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 06-08-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

234B when the entire income consisted of capital gains on which tax was deductible at source under section 195. As is evident, the sole that arise for our consideration is addition made by Ld. AO under the head capital gains. 2. The Ld. AR advanced arguments taking support of various documents as placed on record along with various judicial decisions

HYUNDAI MOTOR INDIA LTD.,KANCHEEPURAM vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा(रण वष( /Assessment Year: 2011-12 V. Hyundai Motor India Limited The Deputy Commissioner Of Plot No. H-1, Sipcot Industrial Park Income Tax, Irrungattukottai, 1775, Jawaharlal Nehru Inner Sriperumbudur Taluk, Ring Road, Kancheepuram District, Anna Nagar Western Tamil Nadu-602117 Extension, Chennai-600101 [Pan: Aaach2364M] (अपीलाथ+/Appellant) (,-यथ+/Respondent)

capital gains; or (b) income of the nature referred to in sub-clause (ix) of clause (24) of section 2, and the assessee has paid the whole of the amount of tax payable in respect of income referred to in clause (a) or clause (b), as the case may be, had such income been a part of the total income

R.VASUDEVAN,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 542/Mds/2016 "नधा"रण वष"/Assessment Year:2012-13 Shri R. Vasudevan, The Assistant Commissioner Of Flat No. R-35, Tnhb Complex, T.S. Vs. Income Tax, Krishna Nagar, Mogappair, Central Circle I(1) Chennai 600 050. Chennai. [Pan:Aappv1970J] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri G. Baskar, Advocate & Ms. S. Sriniranjani, Advocate ""यथ" क" ओर से/Respondent By : Shri A.V. Sreekanth, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 05.04.2017 घोषणा क" तार"ख /Date Of Pronouncement : 23.06.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 26.08.2015 Relevant To The Assessment Year 2012-13. The Only Effective Ground Raised In The Appeal Of The Assessee Is That The Ld. Cit(A) Has Erred In Confirming The Denial Of Exemption Under Section 54F Of The Income Tax Act, 1961 [“Act” In Short].

capital gain from sale of land at ₹.16,24,088/-, income from other sources at ₹.4,04,533/- and also declared loss from business of real estate at ₹.1,08,212/-. The return filed by the assessee was selected for scrutiny and notice under section 143(2) of the Act dated 04.09.2014 was served on the assessee. Notice under section

D.KANTABAI ,CHENNAI vs. ACIT NON CORPORATE CIRCLE 1 , CHENNAI

In the result, both the appeals of the assessee are partly allowed

Bench: Shri George Mathan & Shri S.Jayaramanआयकर अपील सं./I.T.A.Nos.1968 & 1969/Chny/2017 "नधा"रण वष" /Assessment Years : 2010-11 & 2012-13 Ms. D. Kantabai Vs. The Assistant Commissioner Of No.13, South Usman Road, Income Tax, T. Nagar Non-Corporate Circle – 1, Chennai – 600 017 Chennai [Pan Aagpk 8590D ] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Mr. Banusekar, Advocate Department By : Mr. A.R.V. Sreenivasan,Jcit सुनवाई क" तार"ख/Date Of Hearing : 05.09.2019 घोषणा क" तार"ख /Date Of Pronouncement : 13.11.2019 आदेश / O R D E R Per S. Jayaraman: The Assessee Filed These Appeals Against The Orders Of The Cit(Appeals)-2, Chennai In Ita Nos.31/Cit(A)-2/2016-17 & 79/Cit(A)-2/2015-16; Dated 30.06.2017 For The Assessment Years 2010-11 & 2012-13, Respectively.

234B. Thereafter, the assessee filed the following additional grounds also: Ground No:4 : For that the Commissioner of Income Tax (Appeals) ought to have appreciated that the year of transfer has not been disputed by the Revenue in the other three co-owners’ case. Ground No.5 : For that the capital gains admitted by the appellant in the assessment years

D.KANTABAI,CHENANI vs. ACIT NON CORPORATE CIRCLE 1 , CHENNAI

In the result, both the appeals of the assessee are partly allowed

Bench: Shri George Mathan & Shri S.Jayaramanआयकर अपील सं./I.T.A.Nos.1968 & 1969/Chny/2017 "नधा"रण वष" /Assessment Years : 2010-11 & 2012-13 Ms. D. Kantabai Vs. The Assistant Commissioner Of No.13, South Usman Road, Income Tax, T. Nagar Non-Corporate Circle – 1, Chennai – 600 017 Chennai [Pan Aagpk 8590D ] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Mr. Banusekar, Advocate Department By : Mr. A.R.V. Sreenivasan,Jcit सुनवाई क" तार"ख/Date Of Hearing : 05.09.2019 घोषणा क" तार"ख /Date Of Pronouncement : 13.11.2019 आदेश / O R D E R Per S. Jayaraman: The Assessee Filed These Appeals Against The Orders Of The Cit(Appeals)-2, Chennai In Ita Nos.31/Cit(A)-2/2016-17 & 79/Cit(A)-2/2015-16; Dated 30.06.2017 For The Assessment Years 2010-11 & 2012-13, Respectively.

234B. Thereafter, the assessee filed the following additional grounds also: Ground No:4 : For that the Commissioner of Income Tax (Appeals) ought to have appreciated that the year of transfer has not been disputed by the Revenue in the other three co-owners’ case. Ground No.5 : For that the capital gains admitted by the appellant in the assessment years

INCOME TAX OFFICER, CHENNAI vs. ROHITKUMAR NEMCHAND PIPARIA, CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1344/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Ito Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1) #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms. Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

Capital Gain on Shares Sales Rs.229,96,19,403/- Less: Purchases Rs.189,63,15,388/- Rs.40,33,04,015/- Income from other sources Rs. 3,80,226/- Rs.40,36,84,241/- Less: Deduction u/s 80C Rs. 70,000/- Assessed Total Income Rs.40,36,14,241/- The above computation is not in dispute. The subject matter of appeal is computation