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

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

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].

1) of section 251 of the Act provides power of remand to the ld. CIT(A) vide Proviso brought into the Act w.e.f. 01.10.2024. However, sub-section (1A) to section 251 of the Act brought into the Act w.e.f. 01.04.2023, wherein, the Addl./JCIT(A) have given powers under clause (a), (b) & (c), but, however, no such Proviso provided

M/S. TRIVITRON HEALTHCARE PVT. LTD.,CHENNAI vs. PCIT, , CHENNAI-3

In the result, the appeal filed by the assessee is partly\nallowed

capital gains, etc., if it claims the\naccounting of the merger under Purchase method or if it is accounted\nunder pooling of interest method. If a company follows pooling of\ninterest method, obviously there will not be any goodwill at all, which\ncan be termed as intangible assets).\n22. However, for book purpose, especially while issuing shares of the\namalgamated

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

251(1) (a) of the Act, has been omitted with the "power to set aside" or "examining the issue afresh" effect from 01.06.2001 as per Finance Act 2001. 2.2)The Ld CIT(A) failed to note that there was no pucca sale deed conveying the house property in favour of the assessee. 2.3 )The Ld CIT(A) failed to note

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

251(1) (a) of the Act, has been omitted with the "power to set aside" or "examining the issue afresh" effect from 01.06.2001 as per Finance Act 2001. 2.2)The Ld CIT(A) failed to note that there was no pucca sale deed conveying the house property in favour of the assessee. 2.3 )The Ld CIT(A) failed to note

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

251(1) (a) of the Act, has been omitted with the "power to set aside" or "examining the issue afresh" effect from 01.06.2001 as per Finance Act 2001. 2.2)The Ld CIT(A) failed to note that there was no pucca sale deed conveying the house property in favour of the assessee. 2.3 )The Ld CIT(A) failed to note

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

251(1)(a) of the Act. The declaration of law is clear that the power of the Appellate Assistant Commissioner is coterminus with that of the Income Tax Officer, if that be so, there appears to be no reason as to why the appellate authority cannot modify the assessment order on an additional ground even if not raised before

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

251(1)(a) of the Act. The declaration of law is clear that the power of the Appellate Assistant Commissioner is coterminus with that of the Income Tax Officer, if that be so, there appears to be no reason as to why the appellate authority cannot modify the assessment order on an additional ground even if not raised before

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

251(1)(a) of the Act. The declaration of law is clear that the power of the Appellate Assistant Commissioner is coterminus with that of the Income Tax Officer, if that be so, there appears to be no reason as to why the appellate authority cannot modify the assessment order on an additional ground even if not raised before

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

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

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

WHEELS INDIA LTD.,CHENNAI vs. DCIT LARGE TAX PAYER UMIT-1, CHENNAI

In the result, appeals filed by the revenue for assessment years 2013-14 & 2014-15 are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1604 & 1605/Chny/2019 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15

section 35(2AB) as required by DSIR guidelines. The appellant has submitted to the DSIR application along with all Annexures giving the particulars of expenditure incurred in the approved R&D facilities and hence, the appellant's claim of weighted deduction ought to have been allowed. 3.2 The appellant relies on the following decisions: CIT Vs Claris Lifesciences

WHEELS INDIA LTD.,CHENNAI vs. DCIT LARGE TAX PAYER UMIT-1, CHENNAI

In the result, appeals filed by the revenue for assessment years 2013-14 & 2014-15 are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1604 & 1605/Chny/2019 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15

section 35(2AB) as required by DSIR guidelines. The appellant has submitted to the DSIR application along with all Annexures giving the particulars of expenditure incurred in the approved R&D facilities and hence, the appellant's claim of weighted deduction ought to have been allowed. 3.2 The appellant relies on the following decisions: CIT Vs Claris Lifesciences

ACIT LTU 1 CHENNAI, CHENNAI vs. WHEELS INDIA LIMITED, CHENNAI

In the result, appeals filed by the revenue for assessment years 2013-14 & 2014-15 are dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1604 & 1605/Chny/2019 िनधा"रण वष" / Assessment Years: 2013-14 & 2014-15

section 35(2AB) as required by DSIR guidelines. The appellant has submitted to the DSIR application along with all Annexures giving the particulars of expenditure incurred in the approved R&D facilities and hence, the appellant's claim of weighted deduction ought to have been allowed. 3.2 The appellant relies on the following decisions: CIT Vs Claris Lifesciences