ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

56(1) on the reason that that the share premium of Rs.240 was huge and inflated. In other words, the AO has concluded that the fair value of the share was only Rs.10 without any valuation by him and that he has come to the conclusion that the share premium of Rs.240 was excessive. The issue of shares has been

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

56(1) on the reason\nthat that the share premium of Rs.240 was huge and\ninflated. In other words, the AO has concluded that the fair\nvalue of the share was only Rs.10 without any valuation by\nhim and that he has come to the conclusion that the share\npremium of Rs.240 was excessive. The issue of shares has\nbeen

GATEWAY OFFICE PARKS PRIOVATE LIMITEDI,CHENNAI vs. ACIT, CORPORATE CICLE-6(1), CHENNAI

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

section 56 shall be\nthe value, on the valuation date, of such unquoted equity shares as determined in\nthe following manner under clause (a) or clause (b), at the option of the assessee,\nnamely:-\n(a) The fair market value of unquoted equity shares =| (A-L)(PE)| x (PV)\nwhere,\nPage - 5 - of 14\nITA No.617/Chny/2024\nA=book value

ADP INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), CHENNAI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

depreciation on goodwill, which was confirmed by the CIT(A). Thus, we set aside the order of the CIT(A) and the addition made by the Assessing Officer stands deleted for all the assessment years under consideration. ITA Nos.2670 to 2672 & 2698/Chny/2024 18. The next ground raised by the assessee in ground Nos. 3.1 to 3.6 for the assessment year

ADP INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

depreciation on goodwill, which was confirmed by the CIT(A). Thus, we set aside the order of the CIT(A) and the addition made by the Assessing Officer stands deleted for all the assessment years under consideration. ITA Nos.2670 to 2672 & 2698/Chny/2024 18. The next ground raised by the assessee in ground Nos. 3.1 to 3.6 for the assessment year

ADP INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, NATIONAL FACELESS ASSESSMENT CENTRE

In the result, the appeal in ITA No

depreciation, and the 5th proviso to Section 32(1) does not restrict this claim. The addition made under Section 56

ADP INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeal in ITA No

depreciation was set aside.", "result": "Allowed", "sections": [ "250", "143(1)", "143(2)", "142(1)", "32", "43(1)", "47", "170", "40(a)(i)", "195", "56

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

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

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

INDIA METAL ONE STEEL PLATE PROCESSING PRIVATE LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal is dismissed

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं/.I.T.A. No. 3497/Chny/2016 "नधा"रण वष"/Assessment Year : 2012-13 M/S. India Metal One Steel Plate The Deputy Commissioner Of Income Processing Pvt. Ltd., Vs. Tax, Prestige Palladium Bayan, Corporate Circle – 2(2), 6Th Floor, Door No. 129 To 140 121, Mahatma Gandhi Road, Greams Road, Chennai – 600 006. Nungambakkam, Chennai – 600 034. [Pan: Aacci 5959F] (अपीलाथ"/Appellant) (%&यथ'/Respondent)

depreciation and amortisation expenses and Rs. 23,688,280/- towards other expenses and thus arrived the profit before tax at Rs. 6,460,372/-. The relevant portion of the order of the Ld. CIT(A) is extracted as under: “6. The matter is considered. In the case of M/s. Indian Oil Panipat Power Consortium Ltd (supra), primarily relied upon

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

M/S SHRIRAM PROPERTIES LIMITED,CHENNAI vs. PCIT-CENTRAL1, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 431/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

section 56(2)(viib) of the Act. This fact has been explained to the :-43-: ITA. No: 431/Chny/2022 PCIT, however, he has misunderstood the facts merely for the reason that there is increase in security premium account when compare to year ending 31.03.2016. But, fact remains that said entry is only a disclosure requirement in compliance with IND-AS standards

CHANDRASEKARAN VALARMATHI,TOWN HOUSE, COIMBATORE vs. INCOME TAX OFFICER, COIMBATORE

The appeals stand allowed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

section 271(1)(c) of the Act whereas there is no furnishing of inaccurate particulars.” As is evident, the sole issue that arises for our consideration is addition made by Ld. AO by invoking the provisions of Sec. 56(2)(vii). 2. The Registry has noted a delay of 6 days in ITA No.652/Chny/2022, the condonation of which has been