K.R.JAYARAM,CHENNAI vs. ACIT, COIMBATORE

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

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

depreciation allowance or that there has been underassessment or assessment at a lower rate or for applying other provisions of Explanation 2 to section 147 , it must be on material and it should have nexus for holding such opinion contrary to what has been expressed earlier. Even after the amendment of section 147 mere change of opinion does not confer

ASSISTANT COMMISSIONER OF INCOME TAX, PUDUCHERRY vs. VELAYUDAME PONNAMBALAME RAMALINGAME, PUDUCHERRY

In the result, the appeal filed by the Revenue is partly allowed and the C

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2515/Chny/2024 & C.O No.77/Chny/2024 िनधा<रण वष< /Assessment Year: 2018-19 The Asst. Commissioner Of Velayudame Ponnambalame Income Tax, Vs. Ramalingame, Circle-1, 72-74, Perumal Koil Street, Puducherry. Puducherry – 605001. [Pan: Aaipr 7831G]

section 50C of the Act consideration received is deemed to be the full value of consideration. ITA No.2515/Chny/2024 & C.O No.77/Chny/2024 :- 7 -: Accordingly, the addition confirmed by the Ld CIT(A) of Rs.13,24,353/- is deleted. 5. Ground No.3 is against deletion of addition of Rs.1,46,91,098/- made by the A.O on account of undisclosed sales

D.K.HEATERS,CHENNAI vs. DCIT, NON CORPORATE CIRCLE -1, CHENNAI

In the result, the assessee’s appeal is treated as partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.2285/Chny/2017 (िनधा"रण वष" / Assessment Year: 2010-11) M/S. D.K. Heaters, Vs The Deputy Commissioner Of New No.41, Old No.20, Income Tax, 3Rd Trust Cross Street, Non-Corporate Circle – I, Chennai – 34. Mandavali, Chennai – 28. Pan: Aacfd 6086B (अपीलाथ"/Appellant) (""थ"/Respondent)

2. M/s. D.K. Heaters, the assessee, a Firm is engaged in the business of treatment of steel. By a tripartite agreement between the assessee, Tamilnadu Housing Board and Tamilnadu Small Industries Development Corporation dated 22.07.1980 certain partition of land, valued at Rs.39,848/- and building valued at Rs.61,300/-, in total for Rs.1,01,148/- was leased to the assessee

ACIT CORPORATE CIRCLE 4(1), CHENNAI vs. MANGAL TIRTH ESTATE LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 1965/Chny/2018 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of M/S. Mangal Tirth Estate Ltd., Income-Tax, V. No. 769, Spencer Plaza, Corporate Circle-4(1), Anna Salai, Chennai – 600 002. Chennai. [Pan: Aaacm-4614-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By : Shri. N.V. Balaji, Advocate सुनवाई क" तारीख/Date Of Hearing : 29.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 31.01.2023

section 50C of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) and adopted deemed consideration for computation of long term capital gains. The relevant findings of the AO are as under: From the above noting the following points emerged : 1. As on 31.03.1999, Out of 1,50,000 sq.ft. the assessee company had handed over

PENUPETRUNI CHINNA RAO,CHENNAI vs. ITO, INTERNATIONAL TAXATION, WARD-1(1), CHENNAI

In the result, the appeal stand partly allowed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.401/Chny/2022 (िनधा*रण वष* / Assessment Year: 2016-17) Mr. Penupatruni Chinna Rao Ito बनाम 8, Pughs Road, Sundaram Salai, International Taxation, / Vs. R.A. Puram, Chennai-600 028. Ward-1(1), Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aecpc-1481-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. N.V. Lakshmi (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Shri D. Hema Bhupal (Jcit)- Ld. Sr. Dr सुनवाईकीतारीख/Date Of Final Hearing : 04-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 25-04-2024 आदेश / O R D E R

50C(1) of the Act which has been held to have retrospective operation for the purpose of guideline value, the agreement of sale which took place in the previous year relevant to the AY 2013-14, only should have been considered as the date of transfer. H. The learned CIT(A) erred in endorsing the view of the AO that

N.MOHAMMED YAKUB,CHENNAI vs. ITO, CHENNAI

In the result, the appeal of the assessee stands dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No. 852/Mds/2016 "नधा"रण वष" /Assessment Year : 2007-08

depreciable business asset, therefore, the profit on sale of the land has to be assessed as ‘business profit’. Referring to the order of the CIT (A), the learned department representative submitted that Section 41(5) of the Income Tax Act refers to profit and gain arising from transfer of capital asset. Since capital asset was transferred, the CIT (A) found

V.N.CHANDRASEKARAN,VELLORE vs. ITO, VELLORE

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

section 50C. 3.2 During the appeal, Ld.CIT(A) directed the AO to refer the valuation of property to the valuation cell u/s50C(2) of Income tax act. The A.O referred the valuation of property to the valuation cell and the D.V.O submitted the valuation report valuing the property at Rs.18,95,544/- (Land at Rs.15,83,576/- and building