T.RAJENDRAN,CHENNAI vs. ACIT NON CORPORATE CIRCLE 20, 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.: 2032/Chny/2019 िनधा"रण वष" / Assessment Year: 2012-13

10. Thus, on a reading of the first proviso to section 40A(3) read with Rule 6DD(j) as reproduced hereinabove, it is very much clear that no disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

3)(ii) of the Act, so as to attract disallowance of the deduction u/s 80IA(4)(iv) of the Act. 21. In this regard, the ld.CIT(A) drew strong support from the judgment of the Hon’ble Madras High Courtin the case of CIT v. Heartland KG Information Ltd [2013] 39 taxmann.com 132 (Madras), wherein the Hon’ble High Court

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

disallowance of the deduction claimed u/s.80IA(4)(iv) is\nattracted on the ground of violation of the condition specified in section\n801A(3)(ii) when the 'running business' of the 'wind mill undertaking' is\ntransferred to the assessee by the previous owner and that the stipulation in\nthe said condition that the 'undertaking' is not formed by the transfer

UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

disallowance under section 14A r.w. Rule 8D is not applicable to insurance companies due to the special provisions of section 44 of the Act. Similarly, in the case of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025] 174 taxmann.com 603 (Madras), the Hon’ble High Court of Madras was pleased to hold that the provisions of section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

disallowance of the deduction claimed u/s.80IA(4)(iv) is\nattracted on the ground of violation of the condition specified in section\n801A(3)(ii) when the 'running business' of the 'wind mill undertaking' is\ntransferred to the assessee by the previous owner and that the stipulation in\nthe said condition that the 'undertaking' is not formed by the transfer

UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

DCIT, OOTY vs. N.PURUSHOTHAMAN, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

disallowance u/s 40A(3) partly by holding that the provisions of that section would apply even to agricultural land. b)The Honourable Commissioner of Income tax (Appeals) failed to appreciate the fact that, the agricultural land could be converted as business assed only upon getting approval of the concerned authorities, thereby the provisions of section 40A(3) would

N.PURUSHOTHAMAN,COIMBATORE vs. DCIT, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

disallowance u/s 40A(3) partly by holding that the provisions of that section would apply even to agricultural land. b)The Honourable Commissioner of Income tax (Appeals) failed to appreciate the fact that, the agricultural land could be converted as business assed only upon getting approval of the concerned authorities, thereby the provisions of section 40A(3) would

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

Section under\n| | | | order of | assessment | which\n| | | | CIT(A) | order | assessment order\n| | | | | | was passed\n| 1 | 1872/Chny/2025 | 2013-14 | 07.04.2025 | 05.05.2021 | 153A r.w.s 143(3)\n| 2 | 1873/Chny/2025 | 2014-15 | 07.04.2025 | 05.05.2021 | 153A r.w.s 143(3)\n| 3 | 1875/Chny/2025 | 2015-16 | 09.04.2025 | 06.05.2021 | 153A r.w.s 143(3)\n| 4 | 1877/Chny/2025 | 2016-17 | 09.04.2025 | 06.05.2021 | 153A r.w.s 143(3

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

disallow a portion of the said expenditure merely on\nthe premise that the vouchers were unsigned or self-prepared.\n117. In our considered view, such a disallowance made solely on the basis of\nthe absence of recipient signatures cannot be sustained in law. The absence of\nsignatures or thumb impressions on labour vouchers, by itself, cannot lead to a\npresumption

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. AADHITYA FINCORP PVT LTD, CHENNAI

The appeal of the revenue is dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

3) while making the disallowance of 10% of total expenditure being Rs.3,05,972/- despite the fact that the assessee has not produced any evidences before the AO during the assessment and such rejection of books would also affect any genuine entries in the books. 2.5 The Ld. CIT(A) erred in holding that the provisions of section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

disallow a portion of the said expenditure merely on\nthe premise that the vouchers were unsigned or self-prepared.\n117. In our considered view, such a disallowance made solely on the basis of\nthe absence of recipient signatures cannot be sustained in law. The absence of\nsignatures or thumb impressions on labour vouchers, by itself, cannot lead to a\npresumption

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

disallow a portion of the said expenditure merely on\nthe premise that the vouchers were unsigned or self-prepared.\n117. In our considered view, such a disallowance made solely on the basis of\nthe absence of recipient signatures cannot be sustained in law. The absence of\nsignatures or thumb impressions on labour vouchers, by itself, cannot lead to a\npresumption

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

disallowance of Rs.8,62,05,510/- is misconceived as\nthe said sum consists of two distinct components: (i) a sum of Rs.1,40,00,000/-\nrepresenting provision for mine development expenditure, duly recorded as on\n31st March; and (ii) a sum of Rs.7,22,05,510/- which is merely a transfer entry\ninvolving reclassification of expenditure originally booked under

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

section 40A(3) of the Act. The CIT(A) directed the AO to disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

section 40A(3) of the Act. The CIT(A) directed the AO to disallow cash payment of Rs.10,17,517/- u/s.40A(3) of the Act by observing in paras 7.3.9 & 7.3.10 as under:- 7.3.9 IT is undisputed that cash payment to the extent of Rs 10