ANIL KUMAR GOEL,CHENNAI vs. ACIT, CHENNAI

In the result, Ground Nos

Bench: Shri George Mathan & Shri A. Mohan Alankamony

249 ITR 306 (SC) re-assessment was based on the opinion of audit party was not permissible and was liable to be quashed. 7. At this point, it was informed to the Ld.AR that as the re-opening had two issues. One in regard to the treatment of the long term capital gains disclosed by the assessee as business income

UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

capital gains which were exempt till AY 2010-11. He submits that the assessee started to claim deduction under section 10(38) of the Act from 5 I.T.A. No.1759/Chny/19 & Ors United India Insurance AY 2005-06 and has been allowed in the assessee’s own case both pre and post amendment of Rule 5(b) of the First Schedule

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot be initiated

UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot be initiated

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot be initiated

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot be initiated

ACIT, CHENNAI vs. M/S. TAJMAHAL AGRO INDUSTRIES PVT LTD., CHENNAI

In the result, the assessee’s appeal for the assessment year 2004-05 & 2006-07 are partly allowed and the appeal for assessment year 2007-08 is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

capital gain and hence we dismiss corresponding grounds of the appeal of the assessee. 5.1 On the claim of deduction u/s 80G, the fact remains that during the assessment proceedings itself, the assessee has produced donation receipts for Rs.18,000/- & Rs.36,000/- paid to Amar Seva Sangam, which was eligible for deduction U/s.80G as per order dated

M/S. TAJMAHAL AGRO INDUSTRIES (P) LTD.,CHENNAI vs. ITO, CHENNAI

In the result, the assessee’s appeal for the assessment year 2004-05 & 2006-07 are partly allowed and the appeal for assessment year 2007-08 is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

capital gain and hence we dismiss corresponding grounds of the appeal of the assessee. 5.1 On the claim of deduction u/s 80G, the fact remains that during the assessment proceedings itself, the assessee has produced donation receipts for Rs.18,000/- & Rs.36,000/- paid to Amar Seva Sangam, which was eligible for deduction U/s.80G as per order dated

M/S. TAJMAHAL AGRO INDUSTRIES (P) LTD.,CHENNAI vs. ITO, CHENNAI

In the result, the assessee’s appeal for the assessment year 2004-05 & 2006-07 are partly allowed and the appeal for assessment year 2007-08 is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

capital gain and hence we dismiss corresponding grounds of the appeal of the assessee. 5.1 On the claim of deduction u/s 80G, the fact remains that during the assessment proceedings itself, the assessee has produced donation receipts for Rs.18,000/- & Rs.36,000/- paid to Amar Seva Sangam, which was eligible for deduction U/s.80G as per order dated

M/S. TAJMAHAL AGRO INDUSTRIES (P) LTD.,CHENNAI vs. ITO, CHENNAI

In the result, the assessee’s appeal for the assessment year 2004-05 & 2006-07 are partly allowed and the appeal for assessment year 2007-08 is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

capital gain and hence we dismiss corresponding grounds of the appeal of the assessee. 5.1 On the claim of deduction u/s 80G, the fact remains that during the assessment proceedings itself, the assessee has produced donation receipts for Rs.18,000/- & Rs.36,000/- paid to Amar Seva Sangam, which was eligible for deduction U/s.80G as per order dated

KEMIA INDUSTRIES LIMITED,CHENNAI vs. ITO, CHENNAI

The appeal stands allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Anikesh Banerjee, Jm

gains were computed and the assessee requested for deduction under Section 54F of the Act, as the sale consideration received was utilized for purchase of a new flat, in which, the name of the assessee's wife was also included as a purchaser. The assessee further stated about the sale of livestock and standing crops. The assessee also stated that

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

249\n(Del. ITAT)\n\n- 19 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\nΟ Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\n\nΟ Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para

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

249\n(Del. ITAT)\n- Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\n• Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para No. 9) of the\ncase law paper book.\n- Routine repair/ maintenance services and remote IT support\nservices

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

249\n(Del. ITAT)\n- Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\n- Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para No. 9) of the\ncase law paper book.\n- Routine repair/ maintenance services and remote IT support\nservices

KANNAN ASHA,CHENNAI vs. ITO, NCW-1(1), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No. 1545/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 V. Kannan Asha, The Ito, Old No.6, New No.15, Ncw-1(1), Veera Perumal Koil Street, Chennai. Mylapore, Chennai-600 004. [Pan: Akrpa 9370 Q] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 45 r.w.s. 48 of the Act. Also, it is noted from page 12 of the impugned sale deed dated 24-08- 2016, that the appellant and the other three persons, viz; Mrs. B. Lakshmi, Mrs. V. Usha and Mr. B. Prakash, being legal heirs of Mr. K. BhoopathiChettiyar, have acquired the impugned properties comprised in Nanjai Survey No.s 58/128

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

249\n(Del. ITAT)\n\n- 19 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\nΟ Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\n\nΟ Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para

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

249\n(Del. ITAT)\nΟ Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\nΟ Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para No. 9) of the\ncase law paper book.\n- Routine repair/ maintenance services and remote IT support\nservices

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

249\n(Del. ITAT)\nO Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\nO Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para No. 9) of the\ncase law paper book.\n- Routine repair/ maintenance services and remote IT support\nservices

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

249\n(Del. ITAT)\nΟ Ernst & Young Private Limited In Re. 323 ITR 184 (AAR)\nΟ Sundaram Asset Management Company Ltd Vs DCIT, LTU\n[2019] 111 taxmann.com 11 (Chennai ITAT) reference in\nthis regard is made to Page No. 396 (Para No. 9) of the\ncase law paper book.\n- Routine repair/ maintenance services and remote IT support\nservices