DEVASAKAYAM AANGILAPPALLI PARIPALANA SABAI,MADURAI vs. ITO, EXEMPTION WARD,, MADURAI

In the result the appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:933/Chny/2025 धनिाजरण वर्ज / Assessment Years: 2018-19 Devasakayam Aangilappalli Income Tax Officer, Paripalana Sabai, Vs. Exemptions Ward, No.11, Devasakayam Matriculation Madurai. Hr.Sec.School, Pasumalai, Madurai – 625 004. [Pan:Aaatd-0964-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent)

Section 139 of the Act would be directory. 7. Reference to the aforesaid decision has no connection whatsoever remotely to the facts of the present case and therefore, in the facts of the present case, the Tribunal has rightly followed the decision of this Court in case of Sarvodaya Charitable Trust v. Income Tax Officer (Exemption) in Special Civil Application

ARUTPERUM JOTHI ARAKKATTALAI,SALEM vs. ITO, EXEMPTION WARD., SALEM

In the result, the appeal of the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI JAGADISH (Accountant Member)

1) of section 139 of the Act, as extended to 31st December, 2021 vide Circular No.9/2021 dated 20-5-2021, is hereby further extended to 28th February, 2022; 6. The due date of furnishing of belated/revised Return of Income for the Assessment Year 2021-22, which is 31st December, 2021 under sub-section (4)/sub-section (5) of section

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

161. Similarly, the discount rate allowed by the assessee is 28% of the brand value and an additional 10% for errors and margins in the estimation has been considered to eliminate the overall risk involved in the estimation. We noted that if these factors had been considered, the actual quantity achieved during AY 2009-10 to 2012-13, there

MADRAS PORT AND DOCK EDUCATIONAL TRUST HIGHER SECONDARY SCHOOL,CHENNAI vs. ITO, EXEMPTION WARD-2,, CHENNAI

In the result both the appeals of the assessee for the A

Bench: Shri George George K & Shri S.R. Raghunathaआयकरअपीलसं./Ita Nos.:937 & 938/Chny/2025 धनि््रणवर्/ Assessment Years: 2021-22 & 2022-23 Chennai Port & Dock Educational Ito, Trust Higher Secondary School Vs. Exemptions Ward-2, (Formerly Known As Madras Port & Chennai – 600 034. Dock Educational Trust Higher Secondary School), Mdlb Housing Colony, Tondiarpet, Chennai – 600 081. [Pan:Aaaam-8192-L] (अपील्थ्/Appellant) (प्थ्/Respondent) अपील्थ्कीओरसे/Appellant By : Shri. Suraj Nahar, C.A. प्थ्कीओरसे/Respondent By : Shri. Kumar Chandan, J.C.I.T. सुनव््कीत्रीख/Date Of Hearing : 17.06.2025 घोरण्कीत्रीख/Date Of Pronouncement : 30.07.2025

Section 139 of the Act would be directory. 7. Reference to the aforesaid decision has no connection whatsoever remotely to the facts of the present case and therefore, in the facts of the present case, the Tribunal has rightly followed the decision of this Court in case of Sarvodaya Charitable Trust v. Income Tax Officer (Exemption) in Special Civil Application

MADRAS PORT AND DOCK EDUCATIONAL TRUST HIGHER SEC. SCHOOL,CHENNAI vs. ITO, EXEMPTIONS WARD-2,, CHENNAI

In the result both the appeals of the assessee for the A

Bench: Shri George George K & Shri S.R. Raghunathaआयकरअपीलसं./Ita Nos.:937 & 938/Chny/2025 धनि््रणवर्/ Assessment Years: 2021-22 & 2022-23 Chennai Port & Dock Educational Ito, Trust Higher Secondary School Vs. Exemptions Ward-2, (Formerly Known As Madras Port & Chennai – 600 034. Dock Educational Trust Higher Secondary School), Mdlb Housing Colony, Tondiarpet, Chennai – 600 081. [Pan:Aaaam-8192-L] (अपील्थ्/Appellant) (प्थ्/Respondent) अपील्थ्कीओरसे/Appellant By : Shri. Suraj Nahar, C.A. प्थ्कीओरसे/Respondent By : Shri. Kumar Chandan, J.C.I.T. सुनव््कीत्रीख/Date Of Hearing : 17.06.2025 घोरण्कीत्रीख/Date Of Pronouncement : 30.07.2025

Section 139 of the Act would be directory. 7. Reference to the aforesaid decision has no connection whatsoever remotely to the facts of the present case and therefore, in the facts of the present case, the Tribunal has rightly followed the decision of this Court in case of Sarvodaya Charitable Trust v. Income Tax Officer (Exemption) in Special Civil Application

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

condone the delay. We required the ld DR to present the case. The ld DR submitted on the issue of ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 33 -: ITA Nos.1417 & 1421/Chny/2016 disallowance of interest on loan under section 14A r w r 8D that the AO has disallowed the interest on loans

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

condone the delay. We required the ld DR to present the case. The ld DR submitted on the issue of ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 33 -: ITA Nos.1417 & 1421/Chny/2016 disallowance of interest on loan under section 14A r w r 8D that the AO has disallowed the interest on loans

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

condone the delay. We required the ld DR to present the case. The ld DR submitted on the issue of ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 33 -: ITA Nos.1417 & 1421/Chny/2016 disallowance of interest on loan under section 14A r w r 8D that the AO has disallowed the interest on loans

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

condone the delay. We required the ld DR to present the case. The ld DR submitted on the issue of ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 33 -: ITA Nos.1417 & 1421/Chny/2016 disallowance of interest on loan under section 14A r w r 8D that the AO has disallowed the interest on loans

THE TRIPLICANE COOP CREDIT SOCIETY LTD.,CHENNAI vs. ITO, WARD-9(1), CHENNAI

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2992&2993/Chny/2025 िनधा"रण वष" /Assessment Year: 2020-21 & 2021-22

161 (SC), while analysing the scope of section The Triplicane Coop Credit Society Ltd. :- 3 -: 80P(4) of the Act, held that the said provision operates as a proviso to section 80P(1) and (2) and excludes only such co-operative banks which, though co- operative societies, possess an RBI licence to carry on banking business. The Hon’ble Supreme

THE TRIPLICANE COOP CREDIT SOCIETY LTD.,CHENNAI vs. ITO, WARD-9(1), CHENNAI

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2992&2993/Chny/2025 निर्धारण वर्ष/Assessment Year: 2020-21 & 2021-22 The Triplicane Cooperative Credit Society Ltd., Old No.35, New No.73, Bharathi Salai, Triplicane, Chennai - 600 005. Pan: Aaaвт 2681E (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Appellant By प्रत्यर्थी की ओर से /Respondent By सुनवाई की तारीख /Date Of Hearing घोषणा की तारीख /Date Of Pronouncement The Income Tax Officer, Vs. Ward-9(1), Chennai. (प्रत्यर्थी/Respondent) Mr. B. Suresh, C.A Ms. R. Anitha, Addl. Cit 12.02.2026 17.02.2026 Per Padmavathy.S, A.M: आदेश / Order These Appeals By The Assessee Are Against The Separate Orders Of The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi, (In Short "Cit(A)") Passed U/S. 250 Of The Income Tax Act, 1961 (In Short "The Act") Both Dated 13.08.2025 For Assessment Year (Ay) 2020-21 & 2021-22. The Common Issue Contended In Both These Appeals Pertain To The Denial Of Deduction U/S.80P(2)(D) For The Interest Received From Chennai Central Cooperative Bank Ltd.

161 (SC), while analysing the scope of section ITA No.2993/Chny/2025 The Triplicane Coop Credit Society Ltd. :- 3 -: 80P(4) of the Act, held that the said provision operates as a proviso to section 80P(1) and (2) and excludes only such co-operative banks which, though co- operative societies, possess an RBI licence to carry on banking business