ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

142(1) notices. Furthermore, the final assessment order did not discuss the applicability of Sections 115QA, 56(2)(vii)(a), or the proportionate disallowance

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

142(1) of the Act and verification of relevant books of accounts and other details, in our opinion, reopening of assessment for denying the exemption is a mere change of opinion and it is not justified. Thus, the reassessment order dated 21.03.2022 under section 147 r.w.s. 144B of the Act made by the Assessing Officer and confirmed

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

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

disallow exemption under section\n11 of the Act to assume jurisdiction to reopen the assessment. He argued\nthat in the case of Songwoon Speciality Chemicals India (P.) Ltd. v. DCIT\n[2024] 169 taxmann.com 184 (Gujarat), when the claim was accepted in\nthe original assessment proceedings and the Assessing Officer could not\nhave reopened assessment on the same facts which

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

2(b) along with 8 are relating to disallowance under section 14A of the Act r.w. Rule 8D. 26 I.T.A. No.1759/Chny/19 & Ors United India Insurance 43. Vide para 3 of the impugned order, the ld. PCIT is of the opinion that for the AY 2016-17, the Assessing Officer made disallowance under section 14A r.w.s. Rule 8D, but, however

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

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

2(b) along with 8 are relating to disallowance under\nsection 14A of the Act r.w. Rule 8D.\n43.\nVide para 3 of the impugned order, the Id. PCIT is of the opinion\nthat for the AY 2016-17, the Assessing Officer made disallowance under\nsection 14A r.w.s. Rule 8D, but, however, no disallowance made for AY\n2017-18. However

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

2(b) along with 8 are relating to disallowance under\nsection 14A of the Act r.w. Rule 8D.\n43.\nVide para 3 of the impugned order, the Id. PCIT is of the opinion\nthat for the AY 2016-17, the Assessing Officer made disallowance under\nsection 14A r.w.s. Rule 8D, but, however, no disallowance made for AY\n2017-18. However

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

2(b) along with 8 are relating to disallowance under\nsection 14A of the Act r.w. Rule 8D.\n43. Vide para 3 of the impugned order, the Id. PCIT is of the opinion\nthat for the AY 2016-17, the Assessing Officer made disallowance under\nsection 14A r.w.s. Rule 8D, but, however, no disallowance made for AY\n2017-18. However

MRS.JOTHI NARAYANAN ,CHENNAI vs. ACIT , CHENNAI

In the result, the appeals filed by the assessees in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 to 153. The rest of additions are additions/ disallowances from salary, interest on borrowed capital added and disallowed, deemed rental income from Thillai Ganga Nagar property and additional deemed rental income from Ponniamman Koil Street property and disallowance of deduction u/s.24(a) of the Act and addition u/s.56(2)(vii)(c) of the Act. When these facts were confronted

MR. THANUSHKODI NARAYANAN,CHENNAI vs. ADDL. CIT CENTRAL CIRCLE 3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA

Bench: Shri Mahavir Singh & Shri Manjunatha.G

142 to 153. The rest of additions are additions/ disallowances from salary, interest on borrowed capital added and disallowed, deemed rental income from Thillai Ganga Nagar property and additional deemed rental income from Ponniamman Koil Street property and disallowance of deduction u/s.24(a) of the Act and addition u/s.56(2)(vii)(c) of the Act. When these facts were confronted

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

2) & 142(1) were issued asking the assessee to furnish further details in respect of deduction claimed u/s.80-IA with supporting documents. During the course of assessment proceedings, the AO being not satisfied with the reply or explanation furnished by the assessee disallowed the entire claim of the assessee made certain additions. 4. Aggrieved, the assessee preferred an appeal before

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

2) & 142(1) were issued asking\nthe assessee to furnish further details in respect of deduction claimed\nu/s.80-IA with supporting documents. During the course of assessment\nproceedings, the AO being not satisfied with the reply or explanation\nfurnished by the assessee disallowed the entire claim of the assessee\nmade certain additions.\n4. Aggrieved, the assessee preferred an appeal before

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

2) & 142(1) were issued asking\nthe assessee to furnish further details in respect of deduction claimed\nu/s.80-IA with supporting documents. During the course of assessment\nproceedings, the AO being not satisfied with the reply or explanation\nfurnished by the assessee disallowed the entire claim of the assessee\nmade certain additions.\n4. Aggrieved, the assessee preferred an appeal before

KARADI PATH EDUCATION COMPANY PRIVATE LIMITED,CHENNAI vs. COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

section 56(2)(viib) disallowance to extent of premium by the Learned\nAssessing Officer.\nIn addition to above jurisdictional Chennai Tribunal decision, the Appellant also\nwishes to rely on following decisions for this ground:\nIn DCTT v. Rankin Infrastructure (P.) Ltd. - [2022] 142

YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

2. Thereafter, in the assessment order passed under section 143(3) read with section 263 of the Act, the Learned AO only disputed the quantum of deduction and the eligibility to claim deduction under section 10AA of the Act was accepted by the AO. A copy of the said order is enclosed as Annexure 3. iii) Further, during the course

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

In the result, the appeal in ITA No

142(1)", "32", "43(1)", "47", "170", "AS-14", "56(2)(viib)", "40(a)(i)", "195" ], "issues": "1. Whether goodwill arising from amalgamation is eligible for depreciation? 2. Applicability of Section 56(2)(viib) to shares issued to non-residents.3. Disallowance

SARAVANAN ARUMUGAM,CHENNAI vs. ITO, CHENNAI

In the result, the appeal of the assessee is allowed for statistical\npurposes

2 of the Wealth-tax Act, 1957 (27 of 1957).]\n1. Subs\n2[143. Assessment.—3[(1) Where a return has been made under section 139, or\nin response to a notice under sub-section (1) of section 142, such return shall be\nprocessed in the following manner, namely:— (a) the total income or loss shall be\ncomputed after making

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

disallowed a sum of Rs. 14,00,000/- transferred on\n11.02.2019 which pertains to EB deposit. On examination of the other\ntransactions it can be seen that these transactions were made with\nDeepa Machinery and other payments relating to the appellant's\nproprietary concern. These remittances were made through a re-\nfinance availed from Sri Ram Transport Finance, a finance