SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

capital gain in the hands of the assessee by giving indexed cost by holding that the lands were not an agricultural land. The ld. CIT(A) further gone to hold that there were no agricultural activities shown by the assessee and confirmed the order of the Assessing Officer. 23. Before us, the ld. AR placed on record agreement of sale

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

capital gain in the hands of the assessee by giving indexed cost by holding that the lands were not an agricultural land. The ld. CIT(A) further gone to hold that there were no agricultural activities shown by the assessee and confirmed the order of the Assessing Officer. 23. Before us, the ld. AR placed on record agreement of sale

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

capital gain in the hands of the assessee by giving indexed cost by holding that the lands were not an agricultural land. The ld. CIT(A) further gone to hold that there were no agricultural activities shown by the assessee and confirmed the order of the Assessing Officer. 23. Before us, the ld. AR placed on record agreement of sale

ST. JOSEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCOT. CENTRAL CIRCLE-1(3), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

capitation fees, failed to disclose them, and did not meet the conditions for a reduced penalty under Section 271AAB(1A)(a). • The 60% penalty under Section 271AAB(IA)(b) is appropriate. Invalidating the notice on a technicality would defeat the legislative intent to deter tax evasion in search cases. e. Holistic Interpretation of the Notice • The notice should be interpreted

ST.JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

In the result, all the appeals filed by the assessees are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

capitation fees, failed to disclose them, and did not meet the conditions for a reduced penalty under Section 271AAB(1A)(a). • The 60% penalty under Section 271AAB(IA)(b) is appropriate. Invalidating the notice on a technicality would defeat the legislative intent to deter tax evasion in search cases. e. Holistic Interpretation of the Notice • The notice should be interpreted

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

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

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ST. JOSHEPHS INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

capitation fees,\nfailed to disclose them, and did not meet the conditions for a reduced\npenalty under Section 271AAB(1A)(a).\n• The 60% penalty under Section 271AAB(IA)(b) is appropriate.\nInvalidating the notice on a technicality would defeat the legislative\nintent to deter tax evasion in search cases.\ne. Holistic Interpretation of the Notice\n• The notice should

ST. JOSEPHS EDUCATIONAL TRUST,CHENNAI vs. DCIT, CENTRAL CIRCLE-193), CHENNAI

capitation fees,\nfailed to disclose them, and did not meet the conditions for a reduced\npenalty under Section 271AAB(1A)(a).\n•\nThe 60% penalty under Section 271AAB(IA)(b) is appropriate.\nInvalidating the notice on a technicality would defeat the legislative\nintent to deter tax evasion in search cases.\ne. Holistic Interpretation of the Notice\n•\nThe notice should

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, TRICHY, TRICHY vs. RAMASAMY RAJASEHAR, PERAMBALUR

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

274-C, Thuraiyur Road, Trichy. Perambalur, Trichy – 621 212. [PAN: AOOPR-5362-Q] (अपीलाथ(/Appellant) ()*यथ(/Respondent/ Cross Objector ) Assessee by : Shri. D. Anand, Advocate Department by : Mr. Shiva Srinivas, C.I.T. सुनवाई क+ तार"ख/Date of Hearing : 29.10.2025 घोषणा क+ तार"ख/Date of Pronouncement : 20.11.2025 आदेश /O R D E R PER S. R. RAGHUNATHA, AM: The present

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 274(1) provides for reasonable opportunity to be given to the assessee so that he can meet the charge. Therefore, from the above, it is very clear that the satisfaction arrived at by the AO before charging the assessee on particular limb of u/s.271(1)(c) of the Act, the AO must clearly record his satisfaction and such satisfaction

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 274(1) provides for reasonable opportunity to be given to the assessee so that he can meet the charge. Therefore, from the above, it is very clear that the satisfaction arrived at by the AO before charging the assessee on particular limb of u/s.271(1)(c) of the Act, the AO must clearly record his satisfaction and such satisfaction

M/S. R R INDUSTRIES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, appeals filed by the assessee are allowed

274 read with Section\n271(1)(c) of the Income Tax Act, 1961 (for short 'the Act'), to be bad in law as\nit did not specify which limb of Section 271(1)(c) of the Act, the penalty\nproceedings had been initiated i.e., whether for concealment of particulars of\nincome or furnishing of inaccurate particulars of income. The Tribunal