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 as detailed below:- S.No

RAMDOSS RAMVIJAY KUMAR,,CHENNAI vs. ITO, NCW - 14(5),, CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.: 3096/Chny/2019 िनधा"रण वष" / Assessment Year: 2006-07

section 50C(1) of the Act, the value assessed or assessable by the Stamp Valuation Authority is deemed to be full value of consideration received or accruing :-5-: ITA. No: 3096/Chny/2019 as a result of transfer of capital asset. Since, guideline value of the property is more than the amount of consideration received for transfer of property

TIRUCHENGODE SAKTHI SPINNERS PVT. LTD.,NAMAKKAL vs. ITO, WARD-1,, TIRUCHENGODE

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2417/Chny/2025 िनधा"रण वष"/Assessment Year: 2023-24 Tiruchengode Sakthi Spinners Private Vs. The Income Tax Officer, Limited, 67/3B, Melkallupalayam B.O., Ward 1, Namakkal 637 403. Tiruchengode. [Pan:Aaact7666A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Ms. M. Subashri, Addl. Cit (Virtual) सुनवाई की तारीख/ Date Of Hearing : 02.12.2025 घोषणा की तारीख /Date Of Pronouncement : 02.12.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.06.2025 Passed By The Addl/Jcit(A)-1, Noida, For The Assessment Year 2023-24. 2. Besides Challenging The Order Of The First Appellate Authority On Merits, The Assessee Vide Ground No. 5 Challenged Legal Issue That The First Appellate Authority Has Exceeded The Powers As Contemplated In Section 251(1A) Of The Income Tax Act, 1961 [“Act” In Short].

section 251 of the Act. 5. Be that as it may, on perusal of the para 6.3 of the impugned order, it is noted that the Addl/JCIT(A) observed that the assessee omitted to 3 I.T.A. No.2417/Chny/25 have mentioned the cost of improvement in the relevant schedule and therefore, directed the Assessing Officer to verify the same and to allow

V SATHYAMOORTHY&CO,ERODE vs. DCIT, CENTRAL CIRCLE -2 , COIMBATORE

The appeals stand allowed

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1019/Chny/2024 (िनधा*रण वष* / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.1020/Chny/2024 (िनधा*रण वष* / Assessment Year: 2016-17) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2, Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 18-09-2024 आदेश / O R D E R Per Bench: 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 & 2016-17 Arises Out Of Separate Orders Of Learned First Appellate Authority. Facts As Well As Issues Are Stated To Be Substantially The Same In Both The Years. 1.2 First, We Take Up Assessee’S Appeal For Ay 2015-16 Which Arises Out Of An Order Passed By Learned Commissioner Of Income Tax

Section 251 of the Act there by negating the addition made in relation there to. 9. The CIT (Appeals) - 20, Chennai failed to appreciate that the disputed component was already. forming part of the income credited to the P & L account there by fortifying the plea for such reduction in the return of income filed in response to notice issued

V SATHYAMOORTHY&CO,ERODE vs. DCIT, CENTRAL CIRCLE -2, COIMBATORE

The appeals stand allowed

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकरअपील सं. / Ita No.1019/Chny/2024 (िनधा*रण वष* / Assessment Year: 2015-16) & 2. आयकरअपील सं./ Ita No.1020/Chny/2024 (िनधा*रण वष* / Assessment Year: 2016-17) M/S. V. Sathyamoorthy & Co. Dcit बनाम/ 41, Patel Road, Central Circle-2, Vs. Near Blood Bank, Erode-638 001. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacfv-0222-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar (Advocate)- Ld.Ar " थ" की ओर से/Revenue By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 29-07-2024 घोषणाकीतारीख /Date Of Pronouncement : 18-09-2024 आदेश / O R D E R Per Bench: 1.1 Aforesaid Appeals By Assessee For Assessment Years (Ay) 2015- 16 & 2016-17 Arises Out Of Separate Orders Of Learned First Appellate Authority. Facts As Well As Issues Are Stated To Be Substantially The Same In Both The Years. 1.2 First, We Take Up Assessee’S Appeal For Ay 2015-16 Which Arises Out Of An Order Passed By Learned Commissioner Of Income Tax

Section 251 of the Act there by negating the addition made in relation there to. 9. The CIT (Appeals) - 20, Chennai failed to appreciate that the disputed component was already. forming part of the income credited to the P & L account there by fortifying the plea for such reduction in the return of income filed in response to notice issued

DCIT, CHENNAI vs. ACCEL LIMITED, CHENNAI

In the result, all the appeals filed by the Revenue and the CO filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1910, 2167, 2168 & 2169/Chny/2019 िनधा"रण वष"/Assessment Years: 2007-08, 2012-13, 2013-14 & 2014-15 & C.O. No. 4/Chny/2020 [In Ita No. 2167/Chny/2019 The Deputy Commissioner Of Vs. M/S. Accel Limited, Income Tax, Corporate Circle 1(1), No. 75, Nelson Manickam Road, Chennai 600 034. Aminjikarai, Chennai 600 029. [Pan: Aaaca3042P] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri G. Suresh, Jcit Assessee By : None सुनवाई की तारीख/ Date Of Hearing : 04.07.2024 घोषणा की तारीख /Date Of Pronouncement : 07.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Department Are Directed Against Two Different Orders Both Dated 29.03.2019 Passed By The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai For The Assessment Years 2007-08, 2012-13, 2013-14 & 2014-15. 2. None Appeared On Behalf Of The Assessee Nor Filed Any Application Seeking Adjournment. Thus, The Assessee Called Absent & Treated Exparte.

gain or loss, and by observing that such loss cannot partake the character of business loss, treated the same as long term capital loss and allowed to be carry forward. The ld. CIT(A) remitted the matter to the file of the Assessing Officer for verification on the statement made by the assessee before the ld. CIT(A) 6 I.T.A

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. ACCEL LTD.,, CHENNAI

In the result, all the appeals filed by the Revenue and the CO filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1910, 2167, 2168 & 2169/Chny/2019 िनधा"रण वष"/Assessment Years: 2007-08, 2012-13, 2013-14 & 2014-15 & C.O. No. 4/Chny/2020 [In Ita No. 2167/Chny/2019 The Deputy Commissioner Of Vs. M/S. Accel Limited, Income Tax, Corporate Circle 1(1), No. 75, Nelson Manickam Road, Chennai 600 034. Aminjikarai, Chennai 600 029. [Pan: Aaaca3042P] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri G. Suresh, Jcit Assessee By : None सुनवाई की तारीख/ Date Of Hearing : 04.07.2024 घोषणा की तारीख /Date Of Pronouncement : 07.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Department Are Directed Against Two Different Orders Both Dated 29.03.2019 Passed By The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai For The Assessment Years 2007-08, 2012-13, 2013-14 & 2014-15. 2. None Appeared On Behalf Of The Assessee Nor Filed Any Application Seeking Adjournment. Thus, The Assessee Called Absent & Treated Exparte.

gain or loss, and by observing that such loss cannot partake the character of business loss, treated the same as long term capital loss and allowed to be carry forward. The ld. CIT(A) remitted the matter to the file of the Assessing Officer for verification on the statement made by the assessee before the ld. CIT(A) 6 I.T.A

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. ACCEL LTD.,, CHENNAI

In the result, all the appeals filed by the Revenue and the CO filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1910, 2167, 2168 & 2169/Chny/2019 िनधा"रण वष"/Assessment Years: 2007-08, 2012-13, 2013-14 & 2014-15 & C.O. No. 4/Chny/2020 [In Ita No. 2167/Chny/2019 The Deputy Commissioner Of Vs. M/S. Accel Limited, Income Tax, Corporate Circle 1(1), No. 75, Nelson Manickam Road, Chennai 600 034. Aminjikarai, Chennai 600 029. [Pan: Aaaca3042P] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri G. Suresh, Jcit Assessee By : None सुनवाई की तारीख/ Date Of Hearing : 04.07.2024 घोषणा की तारीख /Date Of Pronouncement : 07.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Department Are Directed Against Two Different Orders Both Dated 29.03.2019 Passed By The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai For The Assessment Years 2007-08, 2012-13, 2013-14 & 2014-15. 2. None Appeared On Behalf Of The Assessee Nor Filed Any Application Seeking Adjournment. Thus, The Assessee Called Absent & Treated Exparte.

gain or loss, and by observing that such loss cannot partake the character of business loss, treated the same as long term capital loss and allowed to be carry forward. The ld. CIT(A) remitted the matter to the file of the Assessing Officer for verification on the statement made by the assessee before the ld. CIT(A) 6 I.T.A

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. ACCEL LTD.,, CHENNAI

In the result, all the appeals filed by the Revenue and the CO filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1910, 2167, 2168 & 2169/Chny/2019 िनधा"रण वष"/Assessment Years: 2007-08, 2012-13, 2013-14 & 2014-15 & C.O. No. 4/Chny/2020 [In Ita No. 2167/Chny/2019 The Deputy Commissioner Of Vs. M/S. Accel Limited, Income Tax, Corporate Circle 1(1), No. 75, Nelson Manickam Road, Chennai 600 034. Aminjikarai, Chennai 600 029. [Pan: Aaaca3042P] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri G. Suresh, Jcit Assessee By : None सुनवाई की तारीख/ Date Of Hearing : 04.07.2024 घोषणा की तारीख /Date Of Pronouncement : 07.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Department Are Directed Against Two Different Orders Both Dated 29.03.2019 Passed By The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai For The Assessment Years 2007-08, 2012-13, 2013-14 & 2014-15. 2. None Appeared On Behalf Of The Assessee Nor Filed Any Application Seeking Adjournment. Thus, The Assessee Called Absent & Treated Exparte.

gain or loss, and by observing that such loss cannot partake the character of business loss, treated the same as long term capital loss and allowed to be carry forward. The ld. CIT(A) remitted the matter to the file of the Assessing Officer for verification on the statement made by the assessee before the ld. CIT(A) 6 I.T.A

JUSTICE N.KANNADASAN,CHENNAI vs. ITO NON CORPORATE WARD 15(3), CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

capital gain declared is accepted as it is. The ld.counsel took us through the assessment and argued that the Revenue has accepted the sale of house property situated at 39/41, Gangai Street, Kalashetra Colony, Besant Nagar, Chennai for a consideration of Rs.3.45 crores to her husband by way of agreement for sale dated 10.12.2011. He argued that once this

JUSTICE N.KANNADASAN,CHENNAI vs. ITO NON CORPORATE WARD 15(3), CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

capital gain declared is accepted as it is. The ld.counsel took us through the assessment and argued that the Revenue has accepted the sale of house property situated at 39/41, Gangai Street, Kalashetra Colony, Besant Nagar, Chennai for a consideration of Rs.3.45 crores to her husband by way of agreement for sale dated 10.12.2011. He argued that once this

ACIT NON CORPORATE CIRCLE 15, CHENNAI vs. JUSTICE N.KANNADASAN, CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

capital gain declared is accepted as it is. The ld.counsel took us through the assessment and argued that the Revenue has accepted the sale of house property situated at 39/41, Gangai Street, Kalashetra Colony, Besant Nagar, Chennai for a consideration of Rs.3.45 crores to her husband by way of agreement for sale dated 10.12.2011. He argued that once this

SANJJAY SAUMYHA,SALEM vs. PRINCIPAL CIT, COIMBATORE

The appeal stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.392/Chny/2024 (िनधा9रणवष9 / Assessment Year: 2013-14) Mrs. Sanjjay Saumyha Pcit बनाम/ 251 A, Omalur Main Road, Swarnapuri, Coimbatore-1. Vs. Salem-636 004. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aeyps-0117-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri T. Banusekar (Advocate)-Ld. Ar " थ"कीओरसे/Respondent By : Dr. R. Mohan Reddy (Cit) - Ld. Dr सुनवाई की तारीख/Date Of Hearing : 15-10-2024 घोषणा की तारीख /Date Of Pronouncement : 05-11-2024 आदेश / O R D E R

251 A, Omalur Main Road, Swarnapuri, Coimbatore-1. Vs. Salem-636 004. "थायीलेखासं./जीआइआरसं./PAN/GIR No. AEYPS-0117-G (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant by : Shri T. Banusekar (Advocate)-Ld. AR " थ"कीओरसे/Respondent by : Dr. R. Mohan Reddy (CIT) - Ld. DR सुनवाई की तारीख/Date of Hearing : 15-10-2024 घोषणा की तारीख /Date of Pronouncement

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

gains’ in the return of income shall not mean that assessee did not make a claim in the loss in the first place. He noted that the assessee has furnished the statement of total income during the assessment proceedings and there mistake crept in, which was subsequently filed in the revised computation of income but not new claim has been

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

gains’ in the return of income shall not mean that assessee did not make a claim in the loss in the first place. He noted that the assessee has furnished the statement of total income during the assessment proceedings and there mistake crept in, which was subsequently filed in the revised computation of income but not new claim has been

ACIT, CC - I (2),, CHENNAI vs. M/S. BALAJI HOTELS & ENTERPRISES LTD.,, CHENNAI

In the result, the appeals filed by the Revenue in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

gains’ in the return of income shall not mean that assessee did not make a claim in the loss in the first place. He noted that the assessee has furnished the statement of total income during the assessment proceedings and there mistake crept in, which was subsequently filed in the revised computation of income but not new claim has been

ASSISSTANT COMMISIONER OF INCOME TAX, CHENNAI vs. ESTRA ENTERPRISES PRIVATE LIMITED, CHENNAI

Capital gain escaping assessment being the\nnotional profit on conversion of Rs.1254,289,672/- would work out to\nRs.42,63,33,059/-.\n11. As we see from the above reasons recorded by the AO for\nreopening assessment that there is no allegation that failure of the\nassessee to disclose fully and truly all material facts necessary for\nthe assessment

PANCHATCHARAM,KANCHEEPURAM vs. ITO, NCW-22(1), TAMBARAM

In the result, appeal filed by the assessee is dismissed

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

Capital Gains (LTCG) at Rs.1,51,28,579/- and assessed the total income of the assessee at Rs.1,61,14,560/- in place of Rs.9,85,980/- shown in the ITR filed by the assessee. On appeal, the Ld.CIT(A) has noted that the AO has passed an ex parte order and therefore, he exercised his powers as per proviso

PERUMAL ANANTHAKUMAR,CHENNAI vs. ITO, NCW-22(1), TAMBARAM

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.831/Chny/2025 Assessment Years: 2015-16 Perumal Ananthakumar, Income Tax Officer, No.144 Gst Road, Chromepet, Non-Corporate Ward-22(1) Chennai-600 044. Chennai [Pan: Aigpa0836Q] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri N.Madhavan, Rtd, Addl.Cit प्रत्यर्थी की ओर से /Revenue By : Ms.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 04.06.2025 घोषणा की तारीख /Date Of Pronouncement : 13.06.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

capital gains by the Ld.AO and its confirmation by the Ld.CIT(A). The Ld.Counsel for the assessee submitted that admittedly it had not filed any return of income for AY-2015-16. Department had initiated 147 / 148 proceedings. The Ld.Counsel further admitted that it could not make due compliance to the statutory notices issued by the Ld.AO. The Ld.AR urged