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

2) 12. For that the appellant objects to the levy of interest under sections 234B and 234C.” :-3-: ITA. No: 3096/Chny/2019 3. The brief facts of the case are that, the assessee is an individual filed his return of income for the assessment year 2006-07 on 19.10.2006, admitting total income of Rs. 1,84,740/-. The case has been

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

AVANASIYAPPAN ESWARAN,TIRUPPUR vs. ITO,WARD 1(2), TIRUPPUR

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

Bench: Shri George George K & Shri S.R. Raghunatha

2) of the Act was issued on 11.08.2018. The assessee had sold an agricultural land and disclosed capital gains thereon in the return filed for the assessment year 2016-17. The assessee had also claimed deduction u/s.54F from the Long-Term Capital Gains arising from sale of land for the construction of new asset i.e., residential building. The claim

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].

2 I.T.A. No.2417/Chny/25 3. We note that against the intimation order under section 143(1) of the Act, the assessee preferred an appeal before the first appellate authority and the Addl/JCIT(A)-1, Noida remanded the matter to the file of the Jurisdictional Assessing Officer with a direction to take cognisance of the submissions made by the assessee and verify

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

2. The CIT (Appeals) - 20, Chennai erred in confirming the assumption of jurisdiction under Section 153A of the Act and further erred in confirming the search assessment order passed in terms of Section 153A of the Act without assigning proper reasons and justification. 3. The CIT (Appeals) - 20, Chennai failed to appreciate that the search assessment completed by making

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

2. The CIT (Appeals) - 20, Chennai erred in confirming the assumption of jurisdiction under Section 153A of the Act and further erred in confirming the search assessment order passed in terms of Section 153A of the Act without assigning proper reasons and justification. 3. The CIT (Appeals) - 20, Chennai failed to appreciate that the search assessment completed by making

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

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

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

2) Validity of reopening the assessment. The learned assessing officer ought to have verified the veracity of statement made by the appellant accepting LTCG for a specific value before investigation wing in view of the fact that the appellant has not even completed primary education before proceeding to issue notice under section 148, which best can be termed suspicion

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

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

2 years the assessee has not satisfied the primary condition laid down under section 54F. 2.5)The Ld CIT(A) failed to note that, the date of transfer of the property was on 25/06/2011, On the said date, the assessee is owner of flat at Bangalore acquired in March 2011 and another property which was agreed to be sold through

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

2 years the assessee has not satisfied the primary condition laid down under section 54F. 2.5)The Ld CIT(A) failed to note that, the date of transfer of the property was on 25/06/2011, On the said date, the assessee is owner of flat at Bangalore acquired in March 2011 and another property which was agreed to be sold through

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

2 years the assessee has not satisfied the primary condition laid down under section 54F. 2.5)The Ld CIT(A) failed to note that, the date of transfer of the property was on 25/06/2011, On the said date, the assessee is owner of flat at Bangalore acquired in March 2011 and another property which was agreed to be sold through

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

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