ITO CORPORATE WARD 2 , COIMBATORE vs. SHRI. T S R KHANNAIYAN, COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

disallowance claimed by the assessee under Section 10(38) of the Income-tax Act, 1961 (in short 'the Act'). According to the Ld. D.R., the Assessing Officer found that the assessee disclosed ₹4,63,21,320/- as long term capital gain, however, the same is short term capital gain. According to the Ld. D.R., the CIT(Appeals) by placing reliance

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

143(3) of the Act. Thus, it is clear that the Assessing Officer was aware that the assessee generated its income out of sale of uniform, books & notebooks and examined the claim under section 11 of the Act. 17. Further, it is also in the knowledge of the Assessing Officer setting apart the accumulated

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed the re- insurance premium under Section 40(a)(i) of the Act. Therefore, the CIT(Appeals) is not justified in restricting the claim of the assessee to 15% without any reason. 33. We have carefully gone through the judgment of Apex Court in the case of Vodafone International Holdings (supra). The provisions of Insurance Act, 1938, more particularly Section

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed the re- insurance premium under Section 40(a)(i) of the Act. Therefore, the CIT(Appeals) is not justified in restricting the claim of the assessee to 15% without any reason. 33. We have carefully gone through the judgment of Apex Court in the case of Vodafone International Holdings (supra). The provisions of Insurance Act, 1938, more particularly Section

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed the re- insurance premium under Section 40(a)(i) of the Act. Therefore, the CIT(Appeals) is not justified in restricting the claim of the assessee to 15% without any reason. 33. We have carefully gone through the judgment of Apex Court in the case of Vodafone International Holdings (supra). The provisions of Insurance Act, 1938, more particularly Section

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed the re- insurance premium under Section 40(a)(i) of the Act. Therefore, the CIT(Appeals) is not justified in restricting the claim of the assessee to 15% without any reason. 33. We have carefully gone through the judgment of Apex Court in the case of Vodafone International Holdings (supra). The provisions of Insurance Act, 1938, more particularly Section

ACIT, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed the re- insurance premium under Section 40(a)(i) of the Act. Therefore, the CIT(Appeals) is not justified in restricting the claim of the assessee to 15% without any reason. 33. We have carefully gone through the judgment of Apex Court in the case of Vodafone International Holdings (supra). The provisions of Insurance Act, 1938, more particularly Section

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order 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 Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

143(3) of the Act. Thus, it is clear that the Assessing Officer was aware that the assessee generated its income out of sale of uniform, books & notebooks and examined the claim under section 11 of the Act. 17. Further, it is also in the knowledge of the Assessing Officer setting apart the accumulated

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

ACIT, CHENNAI vs. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High