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

TDS effected by the respective companies on the accrual of dividend would clearly establish the intention of the assessee. 12. The Assessing Officer in the process had further held that the adjustment of the dividend income against the interest payable by the companies in which :-6-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 the Assessee had interest

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

TDS effected by the respective companies on the accrual of dividend would clearly establish the intention of the assessee. 12. The Assessing Officer in the process had further held that the adjustment of the dividend income against the interest payable by the companies in which :-6-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 the Assessee had interest

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.

TDS u/s.194IA as required for transfer of land as Capital asset and the land is immediately developed as residential project by this company. c) The assessee has claimed this land as agricultural land without furnishing any proof such as the land was put to use for agricultural purposes and proof of agricultural activity carried out in her land

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

TDS". If one reads the observation of the Supreme Court, the words "such sum" clearly indicate that the observation refers to a case of composite payment where the payer has a doubt regarding the inclusion of an amount in such payment which is exigible to tax in India. In our view, the above observations of this Court in Transmission Corpn

RAMASAMI PALANISAMY,TIRUPUR vs. ITO, WARD-2(1), ERODE

In the result, appeal filed by the assessee is allowed

capital gains to tax in his hands and\naccordingly passed the assessment order u/s.143(3) of the Act dated\n30.12.2018, by observing as under:\n12. ..........The entire sale consideration has been received by him\nand his wife from the Trust and the TDS

SIVASUNDAR SELVAKUMARI,CHENNAI vs. ITO, NCW-1(6), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

TDS and not offering capital gain income in return of income. The assessee filed her response on 24.01.2022 wherein she again

M/S. RMZ INFINITY (CHENNAI) PVT. LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.511/Chny/2025 Assessment Years: 2009-10 M/S.Rmz Infinity(Chennai) Pvt. Ltd, The Principal Commissioner Of No.110, Mount Poonamallee Road, Income Tax-4, Porur, Porur S.O, Circle-1, Ltu, Kanchipuram Dist, Chennai Tamil Nadu-600 116. [Pan: Aaacd2287R]

capital gains has been calculated while omitting to consider cost of acquisition of Rs.2,55,70,923/-. ii) TDS claim

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

TDS on interest paid of Rs.8,94,831/- 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

INCOME TAX OFFICER, CHENNAI vs. ROHITKUMAR NEMCHAND PIPARIA, CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Aby T. Varkey, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.1344/Chny/2023 (िनधा*रण वष* / Assessment Year: 2008-09) Ito 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

TDS, the same constituted final tax liability of the assessee. The same is erroneous presumption. It could be noted that the case was specifically reopened to bring to tax capital gains

S RAJASEKARAN,CHENNAI vs. DCIT, NCC-7(1), CHENNAI

In the result, the appeal of the assessee is partly allowed for statistical purposes, in the manner indicated above

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

TDS on payment of Rs.1,42,82,956/- on account of rent. Subsequently, on perusal of P&L account & audit report of the assessee, the AO found that the assessee has debited expenses of Rs.69,21,472/- on account of GST-interest & late fee. The AO made an addition of Rs.8,83,21,384/- as long term capital gain

NARENDRA MAHENDRA KOTHARI,CHENNAI vs. ITO NON CORPORATE WARD 5(2), CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.1006/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 V. Shri Narendra Mahendra- The Income Tax Officer, Kothari, Non-Corporate Ward-5(2), No.76, Osian Heights, Chennai. Basin Bridge Road, Mint, Chennai-600 079. [Pan: Amopk 2535 Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Shri D. Anand, Advocate : ""यथ" क" ओर से /Respondent By Shri Arv Sreenivasan, Addl.Cit : सुनवाईक"तारीख/Date Of Hearing 05.02.2024 घोषणाक"तारीख /Date Of : 14.02.2024 Pronouncement

Capital Gain’, the question of allowing deduction u/s.54F of the Act, does not arise, and thus, in our considered view, there is no error in the reasons given by the AO and the Ld.CIT(A) to reject deduction claimed u/s.54/54F of the Act. Thus, we are inclined to uphold the findings of the Ld.CIT(A) and reject the ground taken

MOHIT GUPTA,CHENNAI vs. ITO,NON- CORP WARD 17(2), CHENNAI, CHENNAI

In the result, the appeal filed by the assessee is partly- allowed for statistical purposes

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1847/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Shri Mohit Gupta, The Income Tax Officer, T45, Old No.T11, Vs. Non-Corporate Ward 17(2), Vi Avenue, Chennai. Besant Nagar, Chennai – 600 090. Pan: Aoqpg 5419R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई क" तारीख/Date Of Hearing : 20.11.2025 घोषणा क" तारीख/Date Of Pronouncement : 25.11.2025

capital gain is liable to be taxed in the relevant assessment year, assessee is entitled for exemption u/s.54 of the Act, since new asset has been purchased within the stipulated time. 8. As regards, alternative plea of assessee is concerned, we note that the original asset was sold vide registered sale deed dated 23.03.2016 vide Doc.No.735/2016 of SRO, Adyar

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

TDS on consideration paid to non-resident shareholders, M/s.Cognizant Technology Solutions Corporation, USA, M/s.MarketRx Inc. USA, and M/s.CSS Investments LLC, Delaware, USA, because, treaty benefit is not available to non-resident shareholders of USA. The assessee did not withheld tax on consideration paid to M/s.Cognizant (Mauritius) Ltd., Mauritius, because, capital gain

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

capital gains on transfer of shares. As a recipient of income, it was the obligation of the assessee to disclose actual taxable income and claim the TDS

DCIT NON CORPORATE CIRCLE 1, CHENNAI vs. MUTHU DANIEL RAJAN, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital gains’ and thus, we are inclined to uphold the findings of the Ld.CIT(A) and reject the ground taken by the Revenue. 9. In the result, appeals filed by the assessee in ITA No.1675/Chny/2019 for the AY 2013-14 is allowed & appeal filed by the Revenue in ITA No.1727/Chny/2019 is dismissed. ITA No.1632/Chny/2019

MUTHU DANIEL RAJAN,CHENNAI vs. CIT CORPORATE CIRCLE 1, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital gains’ and thus, we are inclined to uphold the findings of the Ld.CIT(A) and reject the ground taken by the Revenue. 9. In the result, appeals filed by the assessee in ITA No.1675/Chny/2019 for the AY 2013-14 is allowed & appeal filed by the Revenue in ITA No.1727/Chny/2019 is dismissed. ITA No.1632/Chny/2019

DCIT NON CORPORATE CIRCLE 1, CHENNAI vs. MUTHU DANIEL RAJAN, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital gains’ and thus, we are inclined to uphold the findings of the Ld.CIT(A) and reject the ground taken by the Revenue. 9. In the result, appeals filed by the assessee in ITA No.1675/Chny/2019 for the AY 2013-14 is allowed & appeal filed by the Revenue in ITA No.1727/Chny/2019 is dismissed. ITA No.1632/Chny/2019

MUTHUSAMY SHANMUGAM,CHENNAI vs. ITO, INTERNATIONAL TAXATION WARD-2(2), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./Ita No.362/Chny/2023 िनधा(रण वष( /Assessment Year: 2013-14 Muthusamy Shanmugam, The Income Tax Officer, C/O.Ramesh & Ramachandran, Cas Vs. Ward-2(2), New No.39, Old No.29/3, Chennai. Viswanathapuram Main Road, Kodambakkam, Chennai – 600 024. [Pan: Dghps-7897-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Shri V. Nandakumar, Cit सुनवाई क" तारीख/Date Of Hearing : 21.09.2023 घोषणा क" तारीख /Date Of Pronouncement : 30.11.2023 आदेश / O R D E R

TDS amounting to Rs.8,40,34,976/- and refund of Rs. 3,54,77,480/-. Tax :- 5 -: was computed as per section 115E i.e. Tax on investment income and LTCG. 4. The ld. AO, thereafter, issued show-cause notice dated 26-03- 2022 to the assessee as under: “Reason: Bogus long term capital gains

BHAGWANDAS H.JUMANI ,CHENNAI vs. ITO NON CORPORATE WARD 10(1), CHENNAI

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

Bench: Shri Mahavir Singh, Vice- & Shri Arun Khodpiaआयकर अपीलसं./I.T.A.Nos.2701, 774 & 2253/Chny/2018 (िनधा"रणवष" / Assessment Years: 2003-04, 2004-05 & 2005-06) Vs The Income Tax Officer, Mr. Bhagwandas H.Jumani Flat 2B, 2Nd Floor, Tatvam, Non-Corporate Ward-10(1) 118, A.K.Samy Nagar, 9Th Street, Chennai-600 034. Kilpauk, Chennai-600 010. Pan : Ablpj 0980A (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital gain or income from trading of shares. Hence, this issue is remitted back to the file of the Assessing Officer. 29. The next issue in this appeal of the assessee is as regards to shares of HDFC and investments made in the same was considered in the present assessment year amounting to Rs.2,35,500/. The learned counsel