J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

ACIT CORPORATE CIRCLE 1, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

J.K.FENNER (INDIA) LIMITED,MADURAI vs. ACIT CORPORATE CIRCLE 1, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. ACIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

depreciation as available with the assessee far exceeded the year-end investment of Rs.5397.85 Lacs and therefore, it not be said that the borrowed funds were utilized for the purpose of business. Further, major portion of investment was made in earlier years and only a part of investment was made in one scrip during the year. Also, as per settled

M/S. BAY FORGE PVT. LTD.,CHENNAI vs. ACIT, CO, CIRCLE-1(3), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunatha

Section 115JB of the Act as under: Year Depreciation Business Business Adjustment Remarks cumulative Ending Loss Loss without business loss Depreciation as per books 31.03.1997 (2,848,288) (1,78,66,281) (15,017,993) (1,78,66,281) (2,848,288) (1,78,66,281) (15,017,993) 31.03.1998 (14,872,413) (28,351,317) 5,912,166 Prior

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

Depreciation Rs. 1,18,895/- - 3. Interest expenses Rs. 8,93,642/- Rs. 12,99,120/- Net professional income (-)Rs. 3,59,150/- Add: Disallowance of interest unrelated to Rs. 8,93,642/- profession Income assessed u/s 143(3) r.w.s 153A Rs. 5,35,492/- Tuition income as undisclosed income u/s 68 Rs. 10,65,970/- Gift received as undisclosed

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

Depreciation Rs. 1,18,895/- - 3. Interest expenses Rs. 8,93,642/- Rs. 12,99,120/- Net professional income (-)Rs. 3,59,150/- Add: Disallowance of interest unrelated to Rs. 8,93,642/- profession Income assessed u/s 143(3) r.w.s 153A Rs. 5,35,492/- Tuition income as undisclosed income u/s 68 Rs. 10,65,970/- Gift received as undisclosed

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

220, 230 (P & H), where from the facts it ITA Nos.2578 to 2580/chny/2017 :- 32 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells was clear that the assessee had claimed depreciation in the return at the rate of 50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

220, 230 (P & H), where from the facts it ITA Nos.2578 to 2580/chny/2017 :- 32 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells was clear that the assessee had claimed depreciation in the return at the rate of 50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

220, 230 (P & H), where from the facts it ITA Nos.2578 to 2580/chny/2017 :- 32 -: C.O.Nos.47to 49/Chny/2018 M/s.Deloittee Haskins & Sells was clear that the assessee had claimed depreciation in the return at the rate of 50 per cent and he had nowhere disputed the fact that the admissible rate of depreciation to him was 40 per cent., such fact alone

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

220 (Para No. 8) of the case\nlaw paper book\n• Deputy/Joint Commissioner of Income-tax (OSD) vs\nAspire Systems India (P.) Ltd [2023] 157 taxmann.com\n699 (Chennai ITAT) reference in this regard is made to\nPage No. 381 (Para No. 12) of the case law paper book\n• Titan Industries v ITO (11 SOT 206 Bang.)\n• Lufthansa Cargo