D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gain computation mechanism fail 4.1 The Commissioner of Income tax (Appeals) erred in confirming the disallowance of agriculture income of Rs.10,000/- under section 56. 4.2 The Commissioner of Income tax (Appeals) estimate of agricultural income is very low. 4.3 The Commissioner of Income tax (Appeals) ought to have appreciated that the agricultural income offered by the Appellant

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gain computation mechanism fail 4.1 The Commissioner of Income tax (Appeals) erred in confirming the disallowance of agriculture income of Rs.10,000/- under section 56. 4.2 The Commissioner of Income tax (Appeals) estimate of agricultural income is very low. 4.3 The Commissioner of Income tax (Appeals) ought to have appreciated that the agricultural income offered by the Appellant

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gain computation mechanism fail 4.1 The Commissioner of Income tax (Appeals) erred in confirming the disallowance of agriculture income of Rs.10,000/- under section 56. 4.2 The Commissioner of Income tax (Appeals) estimate of agricultural income is very low. 4.3 The Commissioner of Income tax (Appeals) ought to have appreciated that the agricultural income offered by the Appellant

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gain computation mechanism fail 4.1 The Commissioner of Income tax (Appeals) erred in confirming the disallowance of agriculture income of Rs.10,000/- under section 56. 4.2 The Commissioner of Income tax (Appeals) estimate of agricultural income is very low. 4.3 The Commissioner of Income tax (Appeals) ought to have appreciated that the agricultural income offered by the Appellant

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gain computation mechanism fail 4.1 The Commissioner of Income tax (Appeals) erred in confirming the disallowance of agriculture income of Rs.10,000/- under section 56. 4.2 The Commissioner of Income tax (Appeals) estimate of agricultural income is very low. 4.3 The Commissioner of Income tax (Appeals) ought to have appreciated that the agricultural income offered by the Appellant

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gain computation mechanism fail 4.1 The Commissioner of Income tax (Appeals) erred in confirming the disallowance of agriculture income of Rs.10,000/- under section 56. 4.2 The Commissioner of Income tax (Appeals) estimate of agricultural income is very low. 4.3 The Commissioner of Income tax (Appeals) ought to have appreciated that the agricultural income offered by the Appellant

GURUPRASAD ANGISETTY,CHENNAI vs. ITO, CHENNAI

In the result, the appeal of the assessee is dismissed

Bench: Shri A.Mohan Alankamony & Shri. G. Pavan Kumar

239/- and the Return of income was processed u/s.143(1) of the Act and subsequently, the case was selected for scrutiny through CASS and notice u/s.143(2) of the Act was issued. The ld. Authorised Representative of assessee appeared from time to time and produced details as called for by the ld. Assessing Officer. The ld. Assessing Officer found that

ITO, CHENNAI vs. TVS SHRIRAM GRWOTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

239 and the Hon’ble Special Bench of the ITAT, Delhi in the case of Pradeep Agencies joint venture reported in (2007) 111 TTJ Delhi 346. 5.3 The Ld. DR made further submissions that the assessee’s investment manager M/s.TVS Capital Ltd., a company incorporated under the Indian Companies Act had published the FAQs and note on taxation of income

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

239 and the Hon’ble Special Bench of the ITAT, Delhi in the case of Pradeep Agencies joint venture reported in (2007) 111 TTJ Delhi 346. 5.3 The Ld. DR made further submissions that the assessee’s investment manager M/s.TVS Capital Ltd., a company incorporated under the Indian Companies Act had published the FAQs and note on taxation of income

ITO, CHENNAI vs. TVS SHRIRAM GROWTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

239 and the Hon’ble Special Bench of the ITAT, Delhi in the case of Pradeep Agencies joint venture reported in (2007) 111 TTJ Delhi 346. 5.3 The Ld. DR made further submissions that the assessee’s investment manager M/s.TVS Capital Ltd., a company incorporated under the Indian Companies Act had published the FAQs and note on taxation of income

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

239 and the Hon’ble Special Bench of the ITAT, Delhi in the case of Pradeep Agencies joint venture reported in (2007) 111 TTJ Delhi 346. 5.3 The Ld. DR made further submissions that the assessee’s investment manager M/s.TVS Capital Ltd., a company incorporated under the Indian Companies Act had published the FAQs and note on taxation of income

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

239 and the Hon’ble Special Bench of the ITAT, Delhi in the case of Pradeep Agencies joint venture reported in (2007) 111 TTJ Delhi 346. 5.3 The Ld. DR made further submissions that the assessee’s investment manager M/s.TVS Capital Ltd., a company incorporated under the Indian Companies Act had published the FAQs and note on taxation of income

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 -

239 (Para No. 22) of the case law paper book • Raymond Limited vs. DCIT [86 ITD 791 (Mum. ITAT)] O CESC Ltd vs. DCIT [87 ITD 653 (Cal. ITAT)] • NQA Quality Systems Register Ltd vs. DCIT 2 SOT 249 (Del. ITAT) O Ernst & Young Private Limited In Re. 323 ITR 184 (AAR) O Sundaram Asset Management Company Ltd Vs DCIT

DCIT, CHENNAI vs. M/S. SIFY TECHNOLOGIES LTD., CHENNAI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

239 ITR 502) has approved in principle the proposition that book entries to have a legal effect and cannot be ignored merely because they are book entries. 31. It was noticed by the AO during assessment proceeding that in the balance sheet as on 31.03.2003 Rs. 45,67,354 was shown as 'unearned income' under the head 'current liabilities

DCIT, CHENNAI vs. M/S. SIFY TECHNOLOGIES LTD., CHENNAI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

239 ITR 502) has approved in principle the proposition that book entries to have a legal effect and cannot be ignored merely because they are book entries. 31. It was noticed by the AO during assessment proceeding that in the balance sheet as on 31.03.2003 Rs. 45,67,354 was shown as 'unearned income' under the head 'current liabilities

DCIT, CHENNAI vs. M/S. SIFY TECHNOLOGIES LTD., CHENNAI

In the result, the appeal of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

239 ITR 502) has approved in principle the proposition that book entries to have a legal effect and cannot be ignored merely because they are book entries. 31. It was noticed by the AO during assessment proceeding that in the balance sheet as on 31.03.2003 Rs. 45,67,354 was shown as 'unearned income' under the head 'current liabilities

G.C.SIVARAJ,COIMBATORE vs. DCIT NON CORPORATE CIRCLE 1, COIMBATORE

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

Bench: Shri G. Manjunatha, Hon’Ble & Shri Anikesh Banerjeeआयकर अपील सं./Ita No.2946/Chny/2017 िनधा"रण वष" /Assessment Year: 2013-14 Mr.G.C.Sivaraj, V. The Dy. Commissioner Of 21, Prem Nivas, Income Tax, Psg Estate Colony, Peelamedu, Non-Corporate Circle-1, Coimbatore-641 004. Coimbatore. [Pan: Bqips 4795 P] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Capital Gain on sale of land and (ii) deduction u/s.54F of actual expenditure incurred on improvement of residential building against the appellant and dismissing the appeal. 3. The Commissioner (Appeals) erred in upholding the assessing officer's action in adopting the FMV as on 01.04.1981 of 9.37 acres of land as Rs.1,04,93,894/- (at :: 2 :: the rate

DCIT LARGE TAX PAYER UNIT 1, CHENNAI vs. M/S SUNDARAM ASSET MANAGEMENT COMPANY LIMITED, CHENNAI

In the result, both the appeals of the assessee(ITA no

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

gains derived from the alienation of any such right, property or information; (b) any industrial, commercial or scientific equipment, other than payments derived by an enterprise from activities described in paragraph 4(b) or 4(c) of Article 8. 4. The term "fees for technical services" as used in this Article means payments of any kind to any person