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

b) of the Act read with Notification issued by the Central 43 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Government, fortified by the decisions of the Hon’ble High Court of Madras. 77. Therefore, in pursuance of the provisions under section 2 of the Act read with notification above, the subjected lands are situated beyond

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

b) of the Act read with Notification issued by the Central 43 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Government, fortified by the decisions of the Hon’ble High Court of Madras. 77. Therefore, in pursuance of the provisions under section 2 of the Act read with notification above, the subjected lands are situated beyond

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

b) of the Act read with Notification issued by the Central 43 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Government, fortified by the decisions of the Hon’ble High Court of Madras. 77. Therefore, in pursuance of the provisions under section 2 of the Act read with notification above, the subjected lands are situated beyond

SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SPL SHELTERS PRIVATE LIMITED, CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRIPROP PROPERTIES PRIVATE LIMITED, BANGALORE

Bench: Shri George George K & Ms Padmavathy S, Am

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case

SHRIPROP PROPERTIES PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Accordingly.\n15. In result, appeal of both the assessees in ITA No. 1172 & 1173/Chny/2025\nare allowed and the appeal of the revenue in ITA No

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS.\nThe assessee and the revenue are in appeal against the order of the CIT(A).\n5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is\nretrospective in nature and therefore should be applied in assessee's case

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

B.\nRamakrishnan C.A submitted that, in order to validly usurp jurisdiction\nu/s 153C of the Act, it was incumbent upon the AO to first identify the\nrelevant material, that was found and seized from the premises of the\nsearched person, which `related to' or 'pertained to' the assessee and had\na bearing on the determination of his total income

INDIA JAPAN LIGHTING PRIVATE LIMITED,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 4, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1427/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 V. M/S. India Japan Lighting Pvt. Ltd., The Pcit-4, No.1, Tiruvallur High Road, Chennai. Puduchatram B.O., Thirumazhisai, Tiruvallur-600 124. [Pan: Aaaci 2673 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

40A(2)(b) Refer Annexure - 6 7. Reason for decline in G.P Ratio and N.P. Ratio We would like to bring attention to your good office, due to Covid-19 Pandemic the company sales were badly affected during 1st quarter of 2020-2021 and gradually started increasing from 3rd quarter onwards. During pandemic there was big disruption in Supply Chain

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular provides that the difference between the bid price of a deep discount bonds and its redemption price which is actually paid the time of maturity, will continue

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular provides that the difference between the bid price of a deep discount bonds and its redemption price which is actually paid the time of maturity, will continue

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular provides that the difference between the bid price of a deep discount bonds and its redemption price which is actually paid the time of maturity, will continue

ACIT CORPORATE CIRCLE 3(2), CHENNAI vs. VISWAKARMA REAL ESTATES & CONSTRUCTIONS P. LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri Aby T. Varkery, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 2034/Chny/2018 धनिाारण वर्ा / Assessment Year: 2015-16 Assistant Commissioner Of M/S. Viswakarma Real Estates & Income Tax, V. Constructions P. Ltd., Corporate Circle -3(2), Alwarpet Street, Alwarpet, Chennai – 600 034. Chennai – 600 018. [Pan: Aabcv-5770-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) : Shri. P. Sajit Kumar, Jcit अपीलाथी की ओर से/Appellant By : Shri. J. Prabhakar, Fca प्रत्यथी की ओर से/Respondent By सुनवाई की तारीख/Date Of Hearing : 23.03.2023 घोर्णा की तारीख/Date Of Pronouncement : 05.04.2023

Section 92F 6. For these grounds, and for such other grounds that may be adduced at the time of hearing, it is prayed that the order of assessment be cancelled. 3. The brief facts of the case are that, the assessee is in the business of property development, filed its return of income for the assessment year

BANNARIAMMAN EDUCATIONAL TRUST,COIMBATORE vs. ACIT CENTRAL CIRCLE 3(2), CHENNAI

2. Are you in a sound state of mind to give a sworn statement ? \n\nAns: Yes Sir, I am in a sound state of mind and physically alert and fit to give \na swo statement.\n\nQ.No. 3. Do you know the consequences of giving false statement under oath? \n\nAns: Yes Sir. I have been made aware

D.RAMGOPAL,COIMBATORE vs. DCIT, CENTRAL CIRCLE-1(1), COIMBATORE

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

Bench: Shri Mahavir Singhand Shri Manjunatha.G

capital gain in his hand. The AO after going through the facts of the case noted that the assessee is unable to prove the payment made for removal of encroachments, unable to prove payments made for house clearing expenses and also could not produce Shri P.R. Balakrishnan to whom he claimed to have made payment of Rs.2 crore. Therefore