GOKULAKRISHNA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the stay\napplication is dismissed

42 (1) of the LLP Act, what is transferred\nin this case is the economic rights of the assessee partner and the same is\nan asset under section 2(47) of the Act and the transfer is liable to capital\ngains under section 45(1) of the Act and relied on the following case law:\n1. Sudhakar M. Shetty

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 2(42C) of the Act. We further observe that, the transaction involving the sale of windmill undertaking was carried out with a related concern for which an independent valuation report was obtained and the price agreed between the parties at Rs.93 crores was higher than the value determined by the independent valuer. It is noticed that

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

capital gains and in the case of self-generated good will it is not possible to determine the same. The third reason for holding that the good will generated in a newly commenced business cannot be described as an 'asset' within the terms of section 45 of the Act was that it is impossible to determine its cost of acquisition

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

Section 147 of the Act on 31.03.2004 in assessing the Long Term Capital Gains at Rs.47,79,56,455/-. :-18-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 40. The assessee aggrieved by passing of the aforesaid re-assessment order, had filed an appeal before the ld.CIT(A), wherein before the ld.CIT(A), the assessee had contended

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

Section 147 of the Act on 31.03.2004 in assessing the Long Term Capital Gains at Rs.47,79,56,455/-. :-18-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 40. The assessee aggrieved by passing of the aforesaid re-assessment order, had filed an appeal before the ld.CIT(A), wherein before the ld.CIT(A), the assessee had contended

NATESAN EKAMBARAM,CHENNAI vs. DCIT CENTRAL CIRCLE 1(2), CHENNAI

In the result, the ground of appeal raised by the assessee on this issue stands allowed

Bench: Shri Ss Viswanethra Ravi & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.:2873/Chny/2024 धनिाारणिर्ा / Assessment Year: 2014-15 Natesan Ekambaram, Dcit, 1/115, Bajanai Kovil Vs. Central Circle -1(2), Street, Chennai. Perumbakkam, Medavakkam Post, Chennai – 601 302 [Pan:Ackpe-6757-C] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) अपीलाथीकीओरसे/Appellant By : Mr.K.Vishwa Padmanabhan, Ca. प्रत्यथीकीओरसे/Respondent By : Mr.C.Sivakumar , Addl.Cit.

section 2(47) of the Act. 32. In the instant case, the recitals of the registered sale deed dated 14.10.2013 clearly indicate that the full value of consideration for the transfer of 30.35 cents of land to M/s.Jacaranda Properties Private Limited is Rs.1,00,44,000/- only. In law, the recitals of a registered document carry greater evidentiary value unless

PANKAJ AGARWAL,CHENNAI vs. PCIT , CHENAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 434/Chny/2022 िनधा"रण वष" / Assessment Year: 2012-13

section 68 of the I.T. Act. Further, in the case of Pr.CIT v 15th Prabha Jain dated September 2021 (indiarnkanoon.org/doc/ 697648699/), the Court upheld the addition made u/s.68 in respect of claim of exemption from bogus capital gain u/s.10(38) of the I.T. Act. In this case also, the subject sale for claiming bogus capital gain exemption pertained

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

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

IDFC FINANCIAL HOLDING COMPANY LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE-2(2), HENNAI

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

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

42,31,14,669/- (includes capital gains on sale of investments of Rs.1.40 Crs) and which event arose in the 4th quarter only i.e. M/s. IDFC Financial Holdings Co. Ltd. :: 3 :: 28.03.2019. Accordingly, assessee asserted that it rightly computed and paid advance tax on 31.03.2019 for the capital gains arising on 28.03.2019. However, the intimation u/s.143

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), CHENNAI vs. M. MAHADEVAN, CHENNAI

In the result, the appeals of the Revenue are decided as under:-\nITA Nos\nAssessment\nResult\nYear\nPartly allowed

Section 56 of the Income-tax Act, 1961 read with Rule 11UAA and Rule\n11UA. In this context, the appellant has made his submission that the NAV\nof the shares of OCPL as per the Balance sheet as on 31/07/2018 is Rs.11 as\nper Rule 11UA and the same is considered for purposes of business transfer\narrangement. Further

IL&FS TAMILNADU POWER COMPANY LTD,CHENNAI vs. DCIT CORP CIRCLE 1(1), CHENNAI

In the result, the appeal of the revenue is partly allowed for statistical purposes

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1332/Chny/2024, Assessment Years: 2018-19 आयकर अपील सं./Ita No.1694/Chny/2024, Assessment Years: 2018-19 Il & Fs Tamil Nadu Power Company Deputy Commissioner Of Income Limited, Tax, Old No.21, New No.2, Kpr Tower, Corporate Circle-1(1), 4Th Floor, Greams Road, Chennai S.O, Nungambakkam Chennai-600 006. [Pan: Aabcf1176A] आयकर अपील सं./Ita No.1694/Chny/2024, Assessment Years: 2018-19 Deputy Commissioner Of Income Il & Fs Tamil Nadu Power Company Tax, Limited, Corporate Circle-1(1), Old No.21, New No.2, Kpr Tower, Chennai 4Th Floor, Greams Road, S.O, Nungambakkam Chennai-600 006. [Pan: Aabcf1176A] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri.Ashwin, Ca प्रत्यर्थी की ओर से /Revenue By : Shri Shivanand K Kalakeri, Cit सुनवाई की तारीख/Date Of Hearing : 26.03.2025 घोषणा की तारीख /Date Of Pronouncement : 25.04.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

gain or loss against the actual cost of the capital asset purchased from outside India. For the sake of understanding, Sec.43A is reproduced hereunder … [Special provisions consequential to changes in rate of exchange of currency. 43A. Notwithstanding anything contained in any other provision of this Act, where an assessee has acquired any asset in any previous year from a country

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

gain of\nRs.93,63,20,420/- arising from business succession is exempt from tax\nu/s 47(xiv) of the Act, and hence the provisions of section 68 are inapplicable\nto such amount.\n4. That the Ld.CIT(A) has erred in law and on facts in upholding the action of\nthe Assessing Officer in invoking section 68 of the Act, despite

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. IL AND FS TAMILNADU POWER COMPANY LIMITED, CHENNAI

In the result, the appeal of the revenue is partly allowed for\nstatistical purposes

gain or loss against the\nactual cost of the capital asset purchased from outside India.\nFor the sake of understanding, Sec.43A is reproduced hereunder\n[Special provisions consequential to changes in rate of exchange of\ncurrency.\n43A. Notwithstanding anything contained in any other provision of this Act,\nwhere an assessee has acquired any asset in any previous year from

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

In the result, all the appeals of the assessee are partly allowed and all the appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold