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

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

disallowance of expenses.\n109. In view of the above submissions, the Id.AR urged that the findings of the\nId. CIT(A) being well reasoned and based on proper appreciation of facts and\nlaw, deserve to be upheld, and the grounds raised by the Revenue are liable to\nbe dismissed.\n110. We have heard the rival submissions, perused the material available

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 such expenditure, particularly in\nthe absence of any material on record suggesting that the expenditure was not\nincurred for the legitimate business purposes of the assessee.\n97. The Id.CIT(A) further recorded a finding that no incriminating material had\nbeen brought on record by the AO to substantiate the allegation that the mine\ndevelopment expenses were inflated

CRR LEATHERS,CHENNAI vs. ITO, CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.616/Mds/2017 "नधा"रण वष"/Assessment Year:2008-09 M/S. Crr Leathers, The Income Tax Officer, 9/5, Patnool Sardarjung Street, Vs. Non Corporate Ward 4(3), Periamet, Chennai 600 003. Chennai 600 006. [Pan: Aaafc4173G] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri K. Ravi, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 08.06.2017 घोषणा क" तार"ख /Date Of Pronouncement : 21.08.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 5, Chennai Dated 27.10.2016 Relevant To The Assessment Year 2008-09, Wherein, In The Grounds Appeal, Besides Challenging The Confirmation Of Various Additions For Want Of Tds Under Section 195 Of The Income Tax Act, 1961 [“Act” In Short], The Assessee Has Mainly Challenged Confirmation Of Reopening Of Assessment, Which Is Barred By Limitation.

disallowances under sections 40(a)(ia) and 40(A)(2) of the Act during the course of reassessment proceedings under section 147 of the Act beyond the expiry of four years from the end of the assessment year under consideration. While doing so, the Assessing Officer has not brought on record any new tangible materials for reopening of assessment already

SHRI GHEESULAI PRAVEEN,,CHENNAI vs. ITO, NCW - 5(4),, CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Girish Agrawal, Hon’Bleआयकर अपील सं./Ita No.1090/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Smt.Damayanthi Devakinandan- V. The Asst. Commissioner – Harlalka, Of Income Tax, No.6A, Govindan Street, Non-Corporate Circle-10(1), Ayyavoo Colony, Aminjikarai, Chennai-600 034. Chennai-600 029. [Pan: Aabph 2694 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

3) r.w.s.147 of the Act, at total income of Rs.10,29,490/-, which included a disallowance of Rs.7,27,560/- u/s.10(38) of the Act, which was treated as unexplained credit u/s.68 of the Act. Also an addition of Rs.1,091/- was made towards commission @ 0.51% for providing long term capital gains to the assessee. Based on investigation carried

SHRI GHEESULAI PRAVEEN,,CHENNAI vs. ITO, NCW - 5(4),, CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Girish Agrawal, Hon’Bleआयकर अपील सं./Ita No.1090/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Smt.Damayanthi Devakinandan- V. The Asst. Commissioner – Harlalka, Of Income Tax, No.6A, Govindan Street, Non-Corporate Circle-10(1), Ayyavoo Colony, Aminjikarai, Chennai-600 034. Chennai-600 029. [Pan: Aabph 2694 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

3) r.w.s.147 of the Act, at total income of Rs.10,29,490/-, which included a disallowance of Rs.7,27,560/- u/s.10(38) of the Act, which was treated as unexplained credit u/s.68 of the Act. Also an addition of Rs.1,091/- was made towards commission @ 0.51% for providing long term capital gains to the assessee. Based on investigation carried

DAMAYANTHI DEVAKINANDAN,CHENNAI vs. ACIT NON CORPORATE CIRCLE 10(1), CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Girish Agrawal, Hon’Bleआयकर अपील सं./Ita No.1090/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Smt.Damayanthi Devakinandan- V. The Asst. Commissioner – Harlalka, Of Income Tax, No.6A, Govindan Street, Non-Corporate Circle-10(1), Ayyavoo Colony, Aminjikarai, Chennai-600 034. Chennai-600 029. [Pan: Aabph 2694 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

3) r.w.s.147 of the Act, at total income of Rs.10,29,490/-, which included a disallowance of Rs.7,27,560/- u/s.10(38) of the Act, which was treated as unexplained credit u/s.68 of the Act. Also an addition of Rs.1,091/- was made towards commission @ 0.51% for providing long term capital gains to the assessee. Based on investigation carried

SHRI KEVALCHAND MANOHARCHAND,,CHENNAI vs. ITO, NCW-1(3),, CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Girish Agrawal, Hon’Bleआयकर अपील सं./Ita No.1090/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Smt.Damayanthi Devakinandan- V. The Asst. Commissioner – Harlalka, Of Income Tax, No.6A, Govindan Street, Non-Corporate Circle-10(1), Ayyavoo Colony, Aminjikarai, Chennai-600 034. Chennai-600 029. [Pan: Aabph 2694 E] (अपीलाथ"/Appellant) (""यथ"/Respondent)

3) r.w.s.147 of the Act, at total income of Rs.10,29,490/-, which included a disallowance of Rs.7,27,560/- u/s.10(38) of the Act, which was treated as unexplained credit u/s.68 of the Act. Also an addition of Rs.1,091/- was made towards commission @ 0.51% for providing long term capital gains to the assessee. Based on investigation carried

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

142 taxmann.com 274 (Bangalore - Trib.)\n15.1\nFurther, the Hyderabad Bench of the ITAT in the case of S&P Capital\nIQ (India) (P.) Ltd. (supra) and the Bangalore Bench of the ITAT in the case of\nI & B Seeds (P.) Ltd. (supra) held that by way of amendment through Finance\nAct, 2021 clause (b) of Section

MITHU KUMARI RANKA,CHENNAI vs. ITO NON CORPORATE WARD 5(30, CHENNAI

In the result, five appeals vide ITA Nos

Bench: Shri Mahavir Singh, Hon’Ble & Shri Girish Agrawal, Hon’Ble“C” Bench

section 142(3) of the Act failing which may vitiate the assessment itself. We are of the considered view that the Ld. AO has to reconsider the issue afresh after furnishing to the assessee all the material relied upon by him/her while passing the assessment order. Since the matter is restored to the file of Ld. AO for fresh adjudication

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

142(1) of the Act dated 27.08.2013 issued on the assessee to furnish specific details as contained in the notice. After considering the submissions of the assessee and verification of particulars furnished by the assessee, the Assessing Officer has completed the assessment under section 143(3) of the Act by making disallowance

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

142(1) of the Act dated 27.08.2013 issued on the assessee to furnish specific details as contained in the notice. After considering the submissions of the assessee and verification of particulars furnished by the assessee, the Assessing Officer has completed the assessment under section 143(3) of the Act by making disallowance

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, 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

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

142 of the Act, no right to question the jurisdiction of an Assessing Officer would survive. 2.6 In the present case, the assessee has not challenged the assumption of concurrent jurisdiction by the JCIT within the time stipulated in the statute and reproduced hereinabove. The case law filed by the assessee has no application to the facts of the present

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

142 of the Act, no right to question the jurisdiction of an Assessing Officer would survive. 2.6 In the present case, the assessee has not challenged the assumption of concurrent jurisdiction by the JCIT within the time stipulated in the statute and reproduced hereinabove. The case law filed by the assessee has no application to the facts of the present

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

142 of the Act, no right to question the jurisdiction of an Assessing Officer would survive. 2.6 In the present case, the assessee has not challenged the assumption of concurrent jurisdiction by the JCIT within the time stipulated in the statute and reproduced hereinabove. The case law filed by the assessee has no application to the facts of the present