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

94,30,900/- shall be credited to the current account of the\nexisting partners of M/s. CRCL LLP after fulfilment of the \"Conditions\nSubsequent\" as per clause 7 of the Investment Agreement dt.17.11.2016 to the\nsatisfaction of M/s. Elior India Catering LLP.\nf. that the assessee has undertaken with M/s. Elior India Catering LLP\nthat he and his affiliates shall

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. MANIKANDAN, CHENNAI

The appeal of the Revenue is dismissed

7 -:\nITA No.2986/Chny/2025\nManikandan\n\"The Whole concept of partnership is to embark upon a joint\nventure and in as capital money or even property including\nimmovable property. Once that is done, whatever is brought in\nwould cease to be the exclusive property of the person who brought\nit in. It would be the trading asset of the partnership

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

7. Both assessee and Revenue are aggrieved by appellate order dated 27.03.2012 passed by learned CIT(A) who have come in appeal before the tribunal and we shall take up the contentions of the assessee as well Revenue after discussing factual back ground of appeal filed by assessee in ITA No.307/Chny/2010 and ITA No.1016/Chny/2012

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

7. Both assessee and Revenue are aggrieved by appellate order dated 27.03.2012 passed by learned CIT(A) who have come in appeal before the tribunal and we shall take up the contentions of the assessee as well Revenue after discussing factual back ground of appeal filed by assessee in ITA No.307/Chny/2010 and ITA No.1016/Chny/2012

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

7. Both assessee and Revenue are aggrieved by appellate order dated 27.03.2012 passed by learned CIT(A) who have come in appeal before the tribunal and we shall take up the contentions of the assessee as well Revenue after discussing factual back ground of appeal filed by assessee in ITA No.307/Chny/2010 and ITA No.1016/Chny/2012

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

7. Both assessee and Revenue are aggrieved by appellate order dated 27.03.2012 passed by learned CIT(A) who have come in appeal before the tribunal and we shall take up the contentions of the assessee as well Revenue after discussing factual back ground of appeal filed by assessee in ITA No.307/Chny/2010 and ITA No.1016/Chny/2012

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 is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect 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 is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect 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 is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect 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 is chargeable in view of supporting documents showing the subjected lands are agricultural lands, whereby, we deleted the addition of Rs.1,50,00,000/- made by the Assessing Officer. 50 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18 Therefore, we find force in the arguments of the ld. AR about the availability of funds in respect of sale

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

capital gain on sale of\nshares - Rs.2,94,33,160/-\nAs regards the issue of Tax residency of the assessee, during the course\nof assessment proceedings, upon verification of the documents,\nInformation obtained from the FRRO, copies of Visa and Passport etc,\nLd.AO noted that Shri. Mahadevan had stayed / resided in India as per\nbelow mentioned details:-\nSL.\nAsst. Year

ITO, VIRUDHUNAGAR vs. M/S. P.R. VENKETARAMA RAJA (HUF), RAJAPALAYAM

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

Bench: Shri Duvvuru Rl Reddy & Shri D.S.Sunder Singh

94,600 The entire long term capital gains relating to sale consideration on account of sale of properties was claimed as exempt u/s.54F of the Income Tax Act. The AO disallowed the claim of the assessee on two reasons as follows: (i) The receipt of capital gains on sale of properties mentioned above were residential houses and the deduction u/s.54

VINNY SAWHNEY,CHENNAI vs. ITO, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.993/Mds/2015 "नधा"रण वष" / Assessment Year : 2010-11 Shri Vinny Sawhney, The Income Tax Officer, Prop: T.N. Marketing, V. Business Ward Xv(3) / 3B, D Block, Venus Colony, Non-Corporate Ward 3(5), Alwarpet, Chennai - 600 018. Chennai - 600 034. Pan : Aaapv 4423 G (अपीलाथ"/Appellant) (""यथ"/Respondent)

94,840/-. The Ld. D.R. further submitted that the Assessing Officer treated the capital gain as short term capital gain by taking the holding of the land from the date of conversion into 4 I.T.A. No.993/Mds/15 capital asset. According to the Ld. D.R., for the purpose of computation, the period of holding, the date on which the asset became capital

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LTD.,CHENNAI vs. ACIT, LARGE TAXPAYER UNIT-1, CHENNAI

Bench: Shri Mahavir Singh, Hon’Ble & Shrimanjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.269/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. M/S.Cognizant Technology- The Asst. Commissioner- Solutions India Pvt. Ltd., Of Income Tax, 5/535, Okkiam, Thoriapakkam, Large Taxpayer Unit-1, Old Mahabalipuram Road, Chennai. Chennai-600 096. [Pan:Aaacd 3312 M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Ajay Vohra, Sr.Counsel For Shri N.V. Balaji, Adv. ""यथ" क" ओर से /Respondent By : Shri R.Shankaranarayanan, Additional Solicitor – General Of India For Shri A.P.Srinivas, Sr. Standing Counsel : सुनवाईक"तारीख/Date Of Hearing 03.07.2023 घोषणाक"तारीख /Date Of Pronouncement : 13.09.2023

7. The learned CIT(A) has erred in holding that the provisions of section 46A of the Act are applicable only to purchase of own shares undertaken in accordance with section 77A or section 391 read with section 77A of the Companies Act, 1956 and is not applicable to purchase of own shares under section 391 of the Companies

INCOME TAX OFFICER- WARD-1/JAO, NAGERCOIL vs. ARULANANDHAM BER SYRIL ANTOW, NAGERCOIL

In the result the appeal filed by the Revenue is dismissed

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

94,831/- to M/s.Cholamandalam Finance Ltd. ii) Addition of Rs.10,18,03,600/- by treating sale of land situated at Villukuri Village, Kanyakumari District as taxable long-term capital gain, holding that the land was a capital asset under section 2(14) of the Act. 4.1 On appeal the Ld.CIT(A) confirmed the disallowance u/s.40(a)(ia) and deleted

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

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

7. Regarding payment of commissions to those who facilitated in completing the transaction, it is submitted that the payment of commission to brokers for facilitating smooth transaction would fall under the category of “the expenditure incurred wholly and exclusively in connection with such transfer”. However, the expenditure incurred towards payment of commission has been disallowed on the ground that

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

7. Regarding payment of commissions to those who facilitated in completing the transaction, it is submitted that the payment of commission to brokers for facilitating smooth transaction would fall under the category of “the expenditure incurred wholly and exclusively in connection with such transfer”. However, the expenditure incurred towards payment of commission has been disallowed on the ground that

ACIT, CHENNAI vs. B.V.REDDY ENTERPRISES PVT. LTD., CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.3293/Chny/2016 िनधा"रण वष"/Assessment Year: 2008-09 The Assistant Commissioner Of Vs. M/S. B.V. Reddy Enterprises Pvt. Ltd., New No. 21/Old No. 10A, 1St Floor, Income Tax, Corporate Circle 1(2), Umayal Road, Kilpauk, Chennai 600 034. Chennai 600 010. [Pan:Aaccn2252L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri N. Arjunraj, Ca For Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 27.06.2022 घोषणा की तारीख /Date Of Pronouncement 29.07.2022 : आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai, Dated 28.09.2016 Relevant To The Assessment Year 2008-09. 2. Facts Are, In Brief, That The Assessee Filed Its Return Of Income For The Assessment Year 2008-09 On 13.09.2008 Disclosing Total Income Of ₹.1,83,53,540/- After Setting Off Of Carry Forward Loss Of ₹.9,67,40,138/-.

94,66,619 Total purchases Rs.353,98,88,336 Holding of Shares as on 31.03.08 Rs. 51,36,62,151 The ratio of purchase/sales to holding is 1:7 The above ratio clearly proves that the assessee is more of a trader and not an investor. As regards clause 3 being the intent of profit making, out of the total