DEVARAYA PILLAI SUBRAMANIAN,SALEM vs. ITO, WARD-1(1), SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri S.R.Raghunathaआयकर अपील सं./Ita No.: 561/Chny/2025 धनिाजरण वर्ज / Assessment Year:2017-18 Devaraya Pillai Subramanian, Ito 58A, Sathyamoorthy Street, Vs. Ward – 1(1), Salem – 636 001. Salem. Tamil Nadu. [Pan: Aijps-3267-J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate प्रत्यथीकीओरसे/Respondent By : Ms. Sita Krishnamoorthy, Jcit

Capital Gains' for the purposes of the I.T. Act. Consequently, the interest amounts will also get the benefit of Section 10 (37) of the I.T. Act if the land compulsorily acquired is agricultural land. Further, since the interest amounts so received are not the nature of interest as defined under Section 2 :-9-: ITA. No:561/Chny/2025 (28A), the provisions

ACIT CORPORATE CIRCLE-6(2), CHENNAI vs. S V GLOBAL MILL LTD, CHENNAI

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

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकर अपील सं./Ita No.: 2684/Chny/2019 िनधा"रण वष" / Assessment Year: 2016-17 The Acit, M/S. Sv Global Mill Ltd., Corporate Circle 6(2), V. New No.5/1, Old No.3/1, 6Th Cross Street, Cit Colony, Chennai. Mylapore, Chennai – 600 004. Pan: Aaocs2500E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Suresh Periasamy,Jcit ""यथ" क" ओर से/Respondent By : Shri B. Ramakrishnan, Fca सुनवाई क" तार"ख/Date Of Hearing : 30.12.2020 घोषणा क" तार"ख/Date Of Pronouncement : 28.01.2021

56(2)(viii) r.w.s. 145A(b) of Rs.8,59,67,120/- after allowing notional expenditure u/s 57(iv) adjusted proportionately to the tune of estimated expenditure that could have been incurred. 4.3.4. Before the CIT(A), the appellant’s AR has strongly contended against the AO’s aforesaid addition. The AO’s contentions on the AO’s observations are rebutted

CLASSIC LINEN INTERNATIONAL PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, the appeal filed by assessee in iTA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा$रण वष$ /Assessment Year: 2011-12

gains of the undertaking; and (iv) in computing the depreciation allowance under section 32, the written down value of any asset used for the purposes of the business of the undertaking shall be computed as if the assessee had claimed and been actually allowed the deduction in respect of depreciation for each of the relevant assessment year. (7) The provisions

VEERASWAMY JOTHEESWARAN,TIRUVALLUR vs. ITO, WARD-1,, TIRUVALLUR

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

Bench: Shri George George K

Capital Gains' for the purposes of the I.T. Act. Consequently, the interest amounts will also get the benefit of Section 10 (37) of the I.T. Act if the land compulsorily acquired is agricultural land. Further, since the interest amounts so received are not the nature of interest as defined under Section 2 (28A), the provisions of Section 56

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

2\n35,10,69,000\n(B) Upcoming Projects:\n97,43,22,000\n(i) The Royal Castle\n31,24,40,000\nCommercial Land (255/1a1)\n(ii) The Royal Castle\n14,32,74,000\nCommercial Land\n(262/lala)\n(iii) Pazhanthandalam\n6,41,68,000\nProject Site (144/1)\n(iv) Land at\n5,56,88,000\nPazhanthandalam 63/1

N BASKAR,CHENNAI vs. ITO, CORPORATE WARD-3(2), CHENNAI

In the result, the appeal of assessee is dismissed

Bench: Shri Chandra Poojari

capital gains’. 3.1 However, the Income Tax Officer, Corporate Ward 3(2), Chennai vide his re-assessment order dated 23.03.2016 u/s 143(3) r/w section 147 of the Act had brought to tax `38,78,5151- u/s 56(2)(viii

MALINI,THIRUNINDRAVUR vs. ACIT, NCC-22(1), TAMBARAM

In the result the appeal of the assessee is allowed

Bench: Shri Duvvuru Rl Reddyand Shri S.R. Raghunathaआयकरअपीलसं/.Ita No.:2362/Chny/2024 िनधा"रणवष"/Assessment Year:2018-19 Malini, The Assistant Commissioner Of 7, Ganapathy Puram, Near Vs. Income Tax, Ragvendra Nagar, Periyapalayam Non Corporate Circle 22(1), (Tbm), Road, Thiruninravur 602 024, Chennai. Tamil Nadu. [Pan: Ajspm-9167-B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri D. Anand, Advocate ""यथ"क"ओरसे/Respondent By : Ms. Gauthami Manivasagam, Jcit सुनवाईक"तारीख/Date Of Hearing : 24.03.2025 घोषणाक"तारीख/Date Of Pronouncement : 27.03.2025 आदेश/ O R D E R Per Duvvuru Rl Reddy, Vice-: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Dated 25.06.2024 Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Year Is 2018-19. 2. We Find That This Appeal Is Filed With A Delay Of 17 Days. The Assessee Filed A Petition For Condonation Of Delay Explaining Reasons For The Said Delay & Prayed For Condonation Of That Delay. On Perusal Of The Condonation Petition & Upon Hearing The Ld. Ar & Ld. Dr, We Find That The Reasons Explained By The Assessee Are Bonafide & Therefore, The Delay Is Condoned & Admitted The Appeal For Adjudication.

56(2)(viii) r.w.s. 57(iv) and section 145A(b) of the Act. So far as addition made towards unsecured loan is concerned, the ld. CIT(A) gave relief to the assessee, on that the Revenue has not preferred any appeal before the ITAT. 6. On being aggrieved against confirmation of the addition made by the Assessing Officer, the assessee

DCIT CORPORATE CIRCLE 5(1), CHENNAI vs. REPCO HOME FINANCE P LTD., CHENNAI

In the result, the appeal of Revenue in ITA no

Bench: Shri George Mathan & Shri Ramit Kochar

capital and of the general reserves of the specified entity, no allowance under this clause shall be made in respect of such excess. Explanation.- in this clause, (a) "specified entity" means,- (i) a financial corporation specified in section 4A of the Companies Act, 1956 (1 of 1956) ; (ii) a financial corporation which is a public sector company ; (iii) a banking

AMUDHA SUKUMAR,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals filed by the Revenue and the assessee are dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.883/Chny/2016 िनधा"रण वष"/Assessment Year: 2011-12 The Assistant Commissioner Of Vs. Smt. Amudha Sukumar, Income Tax, Non-Corporate Circle 1(1) New No. 15, Old No. 5, Ranjith Formerly Known As Business Circle I, Road, Kotturpuram, Chennai. Chennai 600 085. [Pan:Admpa6612R] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1033/Chny/2016 िनधा"रण वष"/Assessment Year: 2011-12 Smt. Amudha Sukumar, Vs. The Assistant Commissioner Of New No. 15, Old No. 5, Ranjith Road, Income Tax, Non-Corporate Circle Kotturpuram, 1(1) Formerly Known As Business Chennai 600 085.. Circle I, Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Shri P. Sajit Kumar, Jcit Assessee By : Shri Suhrith Parthasarathy, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 04.02.2016 Relevant To The Assessment

2(47) of the Act. In the instant case, the capital asset did not come into existence at all in the first place and therefore, there can be no capital gains that have accrued. When the said income is not chargeable under capital gains, the same is to be chargeable under section 56 of the Act as 'Other Sources

ACIT, CHENNAI vs. AMDUHA SUKUMAR, CHENNAI

In the result, both the appeals filed by the Revenue and the assessee are dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.883/Chny/2016 िनधा"रण वष"/Assessment Year: 2011-12 The Assistant Commissioner Of Vs. Smt. Amudha Sukumar, Income Tax, Non-Corporate Circle 1(1) New No. 15, Old No. 5, Ranjith Formerly Known As Business Circle I, Road, Kotturpuram, Chennai. Chennai 600 085. [Pan:Admpa6612R] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1033/Chny/2016 िनधा"रण वष"/Assessment Year: 2011-12 Smt. Amudha Sukumar, Vs. The Assistant Commissioner Of New No. 15, Old No. 5, Ranjith Road, Income Tax, Non-Corporate Circle Kotturpuram, 1(1) Formerly Known As Business Chennai 600 085.. Circle I, Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Shri P. Sajit Kumar, Jcit Assessee By : Shri Suhrith Parthasarathy, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 04.02.2016 Relevant To The Assessment

2(47) of the Act. In the instant case, the capital asset did not come into existence at all in the first place and therefore, there can be no capital gains that have accrued. When the said income is not chargeable under capital gains, the same is to be chargeable under section 56 of the Act as 'Other Sources

ITO, ERODE vs. S.NARAYANAN, ERODE

In the result, Revenue’s appeal in ITA No

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

56(2)(viii) r.w.s. 145A. 4. We heard the rival contentions, gone through the orders of the lower authorities. The Supreme Court in the case of CIT, Faridabad vs Ganshyam (HUF) 2009, 315 ITR 1 SC after analysing various provisions of :-4-: CO No. 32/Mds/2017 the Land Acquisition Act, 1894 held , inter alia, that Section 23(1A) provides for additional

KESAVAN VANITHAMANI,CHENNAI vs. ITO, NCW-19(4), CHENNAI

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.2451 & 2452/Chny/2025 िनधा$रण वष$ /Assessment Years: 2017-18 & 2018-19

Section 54F of the Act invalid and baseless. 6.. For the aforesaid grounds and for other grounds to be raised at the time of hearing, the order of CIT(A) may be quashed and justice be rendered.” 2. The assessee is an individual and filed the return of income for AY 2018-19 on 28.10.2018 declaring total income

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

gains tax. It is an undisputed position that respondent assessee is an investment company and had invested by purchasing a substantial number of shares and thereby securing right to management. Possibility of sale of shares by private placement etc. cannot be ruled out and is not an improbability. Dividend may or may not be declared. Dividend is declared

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

gains tax. It is an undisputed position that respondent assessee is an investment company and had invested by purchasing a substantial number of shares and thereby securing right to management. Possibility of sale of shares by private placement etc. cannot be ruled out and is not an improbability. Dividend may or may not be declared. Dividend is declared

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

56 ITR 198) and the other in Ellerman Lines Limited v. CIT [(1971) 82 ITR 913] that circulars issued by the CBDT under Section 119 of the Act are binding on all officers and persons employed in the execution of the Act even if they deviate from the provisions of the Act.” 6.6 (vi) The Hon’ble Supreme Court

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

56 ITR 198) and the other in Ellerman Lines Limited v. CIT [(1971) 82 ITR 913] that circulars issued by the CBDT under Section 119 of the Act are binding on all officers and persons employed in the execution of the Act even if they deviate from the provisions of the Act.” 6.6 (vi) The Hon’ble Supreme Court

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

56 ITR 198) and the other in Ellerman Lines Limited v. CIT [(1971) 82 ITR 913] that circulars issued by the CBDT under Section 119 of the Act are binding on all officers and persons employed in the execution of the Act even if they deviate from the provisions of the Act.” 6.6 (vi) The Hon’ble Supreme Court

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

56 ITR 198) and the other in Ellerman Lines Limited v. CIT [(1971) 82 ITR 913] that circulars issued by the CBDT under Section 119 of the Act are binding on all officers and persons employed in the execution of the Act even if they deviate from the provisions of the Act.” 6.6 (vi) The Hon’ble Supreme Court