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

ITO, INTERNATIONAL TAXATION WARD1(2), CHENNAI vs. RAJAMANICKAM ARULSELVAN, CHENNAI

In the result, the appeal filed by the Revenue and the Cross

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./I.T.A. No.479/Chny/2023 िनधा"रण वष"/Assessment Year: 2013-14 & C.O. No. 44/Chny/2023 [In I.T.A. No. 479/Chny/2023] The Income Tax Officer, Vs. Shri Rajamanickam Arulselvan, 65, Defence Officer Colony, 2Nd International Taxation Ward 1(2), Bsnl Building Tower-1, 4Th Floor, Avenue, 6Th Cross Street, Guindy, Greams Road, Thousand Light, Guindy Industrial Estate S.O., Chennai 600 006. Chennai 600 032. [Pan:Aappa2346C] (अपीलाथ"/Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri P. Sajit Kumar, Jcit Assessee By : Shri N.V. Balaji, Advocate सुनवाई की तारीख/ Date Of Hearing : 03.01.2024 घोषणा की तारीख /Date Of Pronouncement : 01.04.2024 आदेश /O R D E R Per Manjunatha, G.: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-16, Chennai, Dated 22.02.2023 Passed In Ita No. 10039/Cit(A)-16/2012-2013 Relevant To The Assessment Year 2013-14. The Revenue Has Raised Following Grounds: 1. That The Order Of The Ld. Cit(A) Is Erroneous On The Facts, The Merits Of The Case & Provisions Of Law As Well & Hence Unsustainable. 2. That The Ld. Cit(A) Erred In Failing To Appreciate That When The Assessee Had Applied For Conversion Of The Vacant Land Into A Plotted

276 Taxman 224 (Madras) has also considered an identical issue and held that when the land was used for agricultural operation and the said land was also situated beyond the specified limit of the 11 I.T.A. No.479/Chny/23 & C.O. No. 44/Chny/23 municipality, then the said land should be treated as an agricultural land as defined under section

ITO (IT), WARD 2(1), CHENNAI, CHENNAI vs. ROHITKUMAR NEMCHAND PIPARIA, CHENNAI

The appeal stands allowed for statistical purposes

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1326/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Income Tax Officer Shri Rohitkumar Nemchand Piparia बनाम International Taxation Ward-2(1), #34 (Old #77), Meddox Street, / Vs. Chennai. Choolai, Chennai-600 112. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Akzpp-0661-M (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Assessee By : Shri T. Banusekar & Ms.Samyuktha Banusekar (Advocates) - Ld. Ars " थ"कीओरसे/Revenue By : Shri Nilay Baran Som (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 07-10-2024 घोषणाकीतारीख /Date Of Pronouncement : 31-12-2024 आदेश / O R D E R

276 Taxman 356) as confirmed by Hon’ble Supreme Court (reported as 286 Taxman 357). The Ld. CIT-DR submitted that the above case law is on similar facts and involve imposition of concealment penalty arising out of failure of the assessee to report capital gains through 'inadvertence'. It has further been submitted that the decision of Hindustan Steels

INCOME TAX OFFICER, INTERNATIONAL TAXATION WARD-1(1), CHENNAI, CHENNAI vs. RAJAMANICKAM GAUTAMAN, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.: 2753/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 The Income Tax Officer, Shri Rajamanickam Gautam, International Taxation Ward-1(1), Vs. No.65, Old No.46, Chennai. Defence Colony, Nandambakkam, Chennai – 600 032. Pan: Apgpg 6055G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Anitha, Addl. Cit ""यथ" क" ओर से/Respondent By : Shri N.V. Krishnan, Advocate सुनवाई क" तारीख/Date Of Hearing : 07.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 19.05.2025

gains when the assessee had introduced the same as his capital contribution in the firm namely Fidelity Agro Farm. On identical facts, the Chennai Bench of the Tribunal in the case of Shri Rajamanickam Arulselvan, supra (assessee’s brother) had held that at the time of transfer, the impugned land remained to be an agricultural land

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

capital gain added in AY 2014-15 was unsustainable, since it was not based on any incriminating material found in the course of search. The Ld. AR relying upon the decisions of the Hon'ble Delhi High Court in the case of CIT vs Kabul Chawla (380 ITR 573), which has since been affirmed by the Hon'ble Supreme Court

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

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

276), to\njustify that the regular books of accounts of M/s Binny Limited can be\ntreated as incriminating material which related / pertained to the\nassessee, to be factually distinguishable. The decided case involved a\nshort question of application of Section 2(22)(e) of the Act in the hands of\nthe shareholder of a closely held company, which had advanced

SARAVANAN PRIYA ,CHENNAI vs. ITO, NCW 15(4), CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Shri Mahavir Singh

276/-. The stamp duty authorities adopted the value of land at Rs.4,32,34,800/- and building value taken at Rs.12,27,000/- aggregating Rs.4,44,61,800/- as against :- 4 -: ITA No.1245 /Chny/2023 fair market value of the property or sale consideration paid by the assessee as per sale deed is Rs.3,75,00,000/-. Assessee objected vide letter

MOHAMED IBRAHIM,CHENNAI vs. ITO INTERNATIONAL TAXATION 1(2), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.794/Chny/2019 िनधा"रण वष"/Assessment Year: 2015-16 Shri Mohamed Ibrahim, Vs. The Income Tax Officer, New No. 22, Old No. 141, (International Taxation), Ward 1(2), 3Rd Floor, Vepery High Road, Chennai. Periamet, Chennai 600 003. [Pan:Allpm9641F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.02.2023 घोषणा की तारीख /Date Of Pronouncement : 15.02.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, Dated 31.01.2019 Relevant To The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is Non-Resident & Filed His Return Of Income For The Assessment Year 2015-16 Admitting Total Income Of ₹.51,93,980/-. The Case Was Selected For Limited Scrutiny Under Cass & Notice Under Section 143(2) Of The Income Tax Act, 1961 [“Act”

capital gain. On verification of the purchase deed dated 07.04.2016, the Assessing Officer has observed that the property consist of ground floor 1323 sq. ft., first floor 1323 sq. ft., second floor 1323 sq. ft., third floor 1323 sq. ft. and 3 I.T.A. No.794/Chny/19 fourth floor 849 + 80 sq. ft. As there was difference in the statement of the sale

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX,, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, , CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

GUNASEKARAN MANNAR,VILLUPURAM vs. ASST. COMMISSIONER OF INCOME TAX, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

gains. A search action under section 132 of the Act was conducted at the residential and business premises of the assessee on 02/03.11.2022. During the course of search, the Respondent examined the billing software "S.S. Retail" used by the assessee and found the difference of ₹.1,00,11,231/- between the Trans_Sales_Mas, treated as 3 I.T.A. Nos.1863

DCIT, CC2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

gains” occurring in sub-section (2) of section 12. Therefore, the scope for allowing a deduction under clause (iii) or (xv) of sub-section (2) of section 10 would be much wider than the one available under sub-section (2) of section 12.” 10.15 The decision rendered by the Hon’ble Supreme Court in the case of Indian Bank Limited

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

gains” occurring in sub-section (2) of section 12. Therefore, the scope for allowing a deduction under clause (iii) or (xv) of sub-section (2) of section 10 would be much wider than the one available under sub-section (2) of section 12.” 10.15 The decision rendered by the Hon’ble Supreme Court in the case of Indian Bank Limited