GEENA GARMENTS,TIRUPPUR vs. ACIT, CIRCLE-1, TIRUPPUR, TIRUPPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 32(1). Therefore, the aforesaid decision of Hon'ble Supreme Court which held that the expenditure so incurred is not in the capital field, would mean that the 53 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23 expenditure is in the revenue field and therefore, the same, in fact, would support the case of the assessee. 17. Proceeding

ACIT, CIRCLE-1, , TIRUPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING (P) LTD., TIRUPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

Section 32(1). Therefore, the aforesaid decision of Hon'ble Supreme Court which held that the expenditure so incurred is not in the capital field, would mean that the 53 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23 expenditure is in the revenue field and therefore, the same, in fact, would support the case of the assessee. 17. Proceeding

JCI (OSD), CORPORATE CIRCLE -1(1),, CHENNAI vs. M/S. ARCHEAN CHEMICAL INDUSTRIES PVT. LTD.,, CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunatha

condone delay in filing both these appeal filed by the Revenue. ITA No. 1998/Chny/2019 (A.Y.2014-15): 5. The Revenue has raised following grounds of appeal:- “1. The order of the Ld. CIT(A) is contrary to law, facts and circumstances of the case. 2.1 The CIT(A) erred in deleting the addition made u/s 56(2)(viib

DCIT, CC - 1 (1),, CHENNAI vs. M/S. ARCHEAN CHEMICAL INDUSTRIES PVT. LTD.,, CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunatha

condone delay in filing both these appeal filed by the Revenue. ITA No. 1998/Chny/2019 (A.Y.2014-15): 5. The Revenue has raised following grounds of appeal:- “1. The order of the Ld. CIT(A) is contrary to law, facts and circumstances of the case. 2.1 The CIT(A) erred in deleting the addition made u/s 56(2)(viib

STAR HEALTH INVESTMENTS PRIVATE LIMITED,CHENNAI vs. ITO,CORPORATE WARD-6(3), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.357/Chny/2022 िनधा"रण वष"/Assessment Year: 2015-16 Star Health Investments Vs. The Principal Commissioner Of Private Limited (Dissolved), Income Tax-3, Room No. 410, Main No. 10 & 11, 4Th Floor, Chennai Citi Building, Ivth Floor, 121, Mahatma Centre, Dr. Radhakrishnan Salai, Gandhi Road, Nungambakkam, Mylapore, Chennai 600 004, Chennai. Tamil Nadu. [Pan:Aajcs6207K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Venkata Raman, Ca & Shri V. Padmanabhan, Ca ""थ" की ओर से/Respondent By : Shri P. Mohan Reddy, Cit सुनवाई की तारीख/ Date Of Hearing : 09.02.2023 घोषणा की तारीख /Date Of Pronouncement : 15.03.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax, Chennai – 3, Chennai Dated 31.03.2021 Relevant To The Assessment Year 2015-16 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

delay in filing the appeal is condoned and admitted for adjudication. 3. The grounds raised by the assessee are reproduced as under: 1. For that the revision order dated 31.03.2021 passed by the Principal Commissioner of Income Tax – 3, Chennai under section 263 of the Income- tax Act, 1961, is without jurisdiction, barred by limitation and is opposed

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

condoned the said delay in filing Form 10A vide his order dated 30.11.2016 and referred to page 82 of the paper book. He vehemently argued that the Assessing Officer, considering all the details, accepted the returned income and formed an opinion that the assessee was eligible for claiming exemption under section 11 of the Act during scrutiny assessment. He further

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

condoned the said delay in filing Form 10A vide his order dated 30.11.2016 and referred to page 82 of the paper book. He vehemently argued that the Assessing Officer, considering all the details, accepted the returned income and formed an opinion that the assessee was eligible for claiming exemption under section 11 of the Act during scrutiny assessment. He further

THE ERODE CITY MUNICIPAL CORPORATION EMP CO-OP T& C LIMITED,CHENNAI vs. ITO, WARD 1 (1), ERODE

In the result, the appeal in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

condonation of delay Petition u/s 119(2)(b) to treat the return as filed u/s 139(1). The appellant has filed a petition u/s 119(2)(b) dated 26.12.2023 which is still pending before the Central board of Direct Taxes. Concept of Members and Deduction u/s 80P. 5) The CIT(A) ought to have seen that the Appellant

THE ERODE CITY MUNICIPAL CORPORATION EMP CO-OP T& C LIMITED,ERODE vs. ITO, WARD 1(1), ERODE

In the result, the appeal in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.509 & 510/Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-2019 & 2020-2021)

condonation of delay Petition u/s 119(2)(b) to treat the return as filed u/s 139(1). The appellant has filed a petition u/s 119(2)(b) dated 26.12.2023 which is still pending before the Central board of Direct Taxes. Concept of Members and Deduction u/s 80P. 5) The CIT(A) ought to have seen that the Appellant

RAJALAKSHMI VETTRIVEL,NEW DELHI vs. ACIT, CHENNAI

In the result, all the six appeals of the assessee are dismissed

Bench: Shri Chandra Poojari

condonation of delay. In fact, experience shows that on account of an impersonal machinery (no one in charge of the matter is directly hit or hurt by the judgment sought to be subjected to appeal) and the inherited bureaucratic methodology imbued with the note-making, file-pushing, and passing-on-the- buck ethos, delay on its part is less difficult

RAJALAKSHMI VETTRIVEL,NEW DELHI vs. ACIT, CHENNAI

In the result, all the six appeals of the assessee are dismissed

Bench: Shri Chandra Poojari

condonation of delay. In fact, experience shows that on account of an impersonal machinery (no one in charge of the matter is directly hit or hurt by the judgment sought to be subjected to appeal) and the inherited bureaucratic methodology imbued with the note-making, file-pushing, and passing-on-the- buck ethos, delay on its part is less difficult

RAJALAKSHMI VETTRIVEL,NEW DELHI vs. ACIT, CHENNAI

In the result, all the six appeals of the assessee are dismissed

Bench: Shri Chandra Poojari

condonation of delay. In fact, experience shows that on account of an impersonal machinery (no one in charge of the matter is directly hit or hurt by the judgment sought to be subjected to appeal) and the inherited bureaucratic methodology imbued with the note-making, file-pushing, and passing-on-the- buck ethos, delay on its part is less difficult

RAJALAKSHMI VETTRIVEL,NEW DELHI vs. ACIT, CHENNAI

In the result, all the six appeals of the assessee are dismissed

Bench: Shri Chandra Poojari

condonation of delay. In fact, experience shows that on account of an impersonal machinery (no one in charge of the matter is directly hit or hurt by the judgment sought to be subjected to appeal) and the inherited bureaucratic methodology imbued with the note-making, file-pushing, and passing-on-the- buck ethos, delay on its part is less difficult

RAJALAKSHMI VETTRIVEL,NEW DELHI vs. ACIT, CHENNAI

In the result, all the six appeals of the assessee are dismissed

Bench: Shri Chandra Poojari

condonation of delay. In fact, experience shows that on account of an impersonal machinery (no one in charge of the matter is directly hit or hurt by the judgment sought to be subjected to appeal) and the inherited bureaucratic methodology imbued with the note-making, file-pushing, and passing-on-the- buck ethos, delay on its part is less difficult

RAJALAKSHMI VETTRIVEL,NEW DELHI vs. ACIT, CHENNAI

In the result, all the six appeals of the assessee are dismissed

Bench: Shri Chandra Poojari

condonation of delay. In fact, experience shows that on account of an impersonal machinery (no one in charge of the matter is directly hit or hurt by the judgment sought to be subjected to appeal) and the inherited bureaucratic methodology imbued with the note-making, file-pushing, and passing-on-the- buck ethos, delay on its part is less difficult

NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

condone the delay and admit the appeal. 3. The assessee has raised the following grounds of appeal: - ‘’A. For that the order of the Ld. Commissioner of Income-Tax (Appeals)- 16, Chennai ["CIT(A)"] and Assessing Officer ("AO"), is erroneous, bad in law, and was passed ignoring the facts and merits of the case, disregarding the evidences and the case

PREETI MADHOK,,CHENNAI vs. ITO, NCW -2 (5),, CHENNAI

In the result, the appeal filed by the assessee is dismissed as not

Bench: Shri G. Manjunatha, Hon’Ble & Shri Anikesh Banerjeeआयकर अपील सं./Ita No.752/Chny/2020 िनधा"रण वष" /Assessment Year: 2014-15 Mrs.Preeti Madhok, V. The Income Tax Officer, ‘G’ Block, Flat No.1504, Non-Corporate Ward-2(5), Metrozone (Next To Vr Mall), Chennai. No.44, Pillaiyar Koil Street, Anna Nagar, Chennai-600 040. [Pan: Bcopm 7655 J] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 56(2)(vii)(b) are not invocable in the facts and circumstances of the case. 6. For that without prejudice to the above, the Principal Commissioner of Income Tax failed to appreciate that no addition can be made in the hands of the appellant since the entire consideration for the property purchased during the impugned assessment year was paid

SMT. S. SOUNDARAM (INDIVIDUAL),NAMAKKAL vs. ITO, WARD-4,, NAMAKKAL

In the result, the appeal filed by the assessee for the assessment year 2013-14 is allowed and the appeal for the assessment year 2014-

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.685 & 686/Chny/2020 िनधा"रण वष"/Assessment Year: 2013-14 & 2014-15 Smt. S. Soundaram (Indl.), Vs. The Income Tax Officer, No. 9, Kamarajar Nagar, Ward 4, Namakkal. Rasipuram, Namakkal, Tamil Nadu 637 408. [Pan: Ahrps2830C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. S. Lakshmi Venkataraman, Ca ""थ" की ओर से/Respondent By : Dr. S. Palani Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 16.03.2022 घोषणा की तारीख /Date Of Pronouncement : 29.03.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Principal Commissioner Of Income Tax, Salem, Both Dated 20.03.2020 Relevant To The Assessment Years 2013- 14 & 2014-15 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

delay is condoned and admitted the appeal for adjudication. 3. Facts are, in brief, that the Assessing Officer has reopened the assessment under section 147 of the Act on the ground that the assessee has filed her return of income without disclosing purchase of immovable property of ₹.1,18,80,000/-. Accordingly, the Assessing Officer issued notice under section