YCH LOGISTICS (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallowance u/s.10AA of the Act. The Hon’ble High Court has categorically held that these two issues are to be adjudicated afresh and in such circumstances now appeal can be said to be pending qua these two issues or the additional ground now raised before us qua assumption of jurisdiction by the AO for framing of final assessment order, (which

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MRF LIMITED, CHENNAI

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

255 ITR 395 (Madras HC) - Navin Fluorine International Ltd [2019] 178 ITD 201 (Mumbai); - Gujarat Aluminium Extrusions (P.) Ltd [2003] 184 CTR 297 [Guj HC] 12.7.4 In view of the above facts, the Ld.AR stated that the AO having finalized by himself disallowances of R&D expenditure which are without any basis and grossly against the provisions

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MRF LIMITED, CHENNAI

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

255 ITR 395 (Madras HC) - Navin Fluorine International Ltd [2019] 178 ITD 201 (Mumbai); - Gujarat Aluminium Extrusions (P.) Ltd [2003] 184 CTR 297 [Guj HC] 12.7.4 In view of the above facts, the Ld.AR stated that the AO having finalized by himself disallowances of R&D expenditure which are without any basis and grossly against the provisions

M/S. SAINT GOBAIN GLASS INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddy

4 disallowed while computing the profit and loss of the assessee under normal provisions of the Act as well as under section 115JB of the Act. This issue is double fold and they are discussed and adjudicated as follows:- Disallowance under section 14A of the Act r.w.r.8D of the Rules under normal computation of profit & loss:- 4.2 Since this issue

MANGAL & MANGAL,TRICHY vs. ACIT, TRICHY

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.: 2207/Chny/2019 िनधा"रण वष" / Assessment Year: 2013-14

disallowed by the AO, the penalty shall be-three times the amount of tax Sought to be evaded, in the case of amounts disclosed during the course of search, the penalty amount is only ten percent of the undisclosed income. Parliament has, therefore, given a different treatment to the latter category. At the same time, if an assessee were

AVALON TECHNOLOGIES (P) LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2009-10 in ITA No

Bench: Shri Mahavir Singhand Dr. M.L. Meena

sections 32, 40(a)(ia), 40A(3) , 43B, etc. of the Act and other specific disallowances, related to the business activity against which the Chapter VI-A deduction has been claimed, result inenhancement of the profits of the eligible business, and that deduction under Chapter VI- A is admissible on the profits so enhanced by the disallowance. 4. Accordingly, henceforth

DCIT, CHENNAI vs. AVALON TECHNOLOGIES P. LTD.,, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2009-10 in ITA No

Bench: Shri Mahavir Singhand Dr. M.L. Meena

sections 32, 40(a)(ia), 40A(3) , 43B, etc. of the Act and other specific disallowances, related to the business activity against which the Chapter VI-A deduction has been claimed, result inenhancement of the profits of the eligible business, and that deduction under Chapter VI- A is admissible on the profits so enhanced by the disallowance. 4. Accordingly, henceforth

AVALON TECHNOLOIGES (P) LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2009-10 in ITA No

Bench: Shri Mahavir Singhand Dr. M.L. Meena

sections 32, 40(a)(ia), 40A(3) , 43B, etc. of the Act and other specific disallowances, related to the business activity against which the Chapter VI-A deduction has been claimed, result inenhancement of the profits of the eligible business, and that deduction under Chapter VI- A is admissible on the profits so enhanced by the disallowance. 4. Accordingly, henceforth

JCIT (OSD) LTU 2 , CHENNAI vs. TI FINANCIAL HOLDINGS LIMITED, CHENNAI

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.1974/Chny/2019 िनधा"रण वष"/Assessment Year:2015-16 The Joint Commissioner Of M/S. Ti Financial Holdings Limited, Income Tax (Osd), Vs. Date House, No. 234, Large Taxpayer Unit – 2, Room No. Nsc Bose Road, 711, 7Th Floor, Wanaparthy Block, No. Chennai 600 001. 121, M.G. Road, Chennai 34. [Pan:Aaact1249H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. R. Anita, Jcit ""थ" की ओर से/Respondent By : Shri R. Vijayaraghavan, Advocate सुनवाई की तारीख/ Date Of Hearing : 21.10.2019 घोषणा की तारीख /Date Of Pronouncement : 01.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai Dated 21.03.2019 Relevant To The Assessment Year 2015-16. The Grounds Raised In The Appeal Of The Revenue Are That The Ld. Cit(A) Has Erred In Directing The Assessing Officer To Recomputed The Disallowance Under Section 14A To The Extent Of Investments Which Yield Exempt Income During The Year Under Consideration & The Ld. Cit(A) Has Erred In Holding That The 2

4 I.T.A. No.1974/Chny/19 exempt income during the year. If an investment has yielded exempt income in a particular year then, it will enter the computation of average value of investments for the purposes of Rule 8D(2)(iii). Accordingly, by following the above decision, the ld. CIT(A) directed the Assessing Officer to recomputed the disallowance in line with

ALAGUMALAI IMPEX PVT LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowing ₹.6,39,234/- under section 14A of the Act. 3 I.T.A. Nos.214, 2911 & 721/M/14 3. The assessee carried the matter in appeal before the ld. CIT(A). After considering the submissions of the assessee and by following various decisions, the ld. CIT(A) partly allowed the appeal filed by the assessee. 4. With regard to the claim of deduction

DCIT, CHENNAI vs. ALAGUMALAI IMPEX P. LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowing ₹.6,39,234/- under section 14A of the Act. 3 I.T.A. Nos.214, 2911 & 721/M/14 3. The assessee carried the matter in appeal before the ld. CIT(A). After considering the submissions of the assessee and by following various decisions, the ld. CIT(A) partly allowed the appeal filed by the assessee. 4. With regard to the claim of deduction

M/S. ALAGUMALAI IMPEX PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowing ₹.6,39,234/- under section 14A of the Act. 3 I.T.A. Nos.214, 2911 & 721/M/14 3. The assessee carried the matter in appeal before the ld. CIT(A). After considering the submissions of the assessee and by following various decisions, the ld. CIT(A) partly allowed the appeal filed by the assessee. 4. With regard to the claim of deduction

T vs. AUTOMOBILE SOLUTIONS PRIVATE LIMITED,MADURAIVS.ITO CORPORATE WARD 3, MADURAI

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 809/Chny/2019 िनधा"रण वष"/Assessment Year:2014-15 M/S. Tvs Automobile Solutions Private The Income Tax Officer, Limited, 7-B, Tvs Building, West Veli Vs. Corporate Ward 3, Street, Madurai 625 001. Madurai. [Pan:Aagcm0329K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Ca For Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri R. Clement Ramesh Kumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 10.07.2019 घोषणा की तारीख /Date Of Pronouncement : 24.09.2019 आदेश /O R D E R Per Duvvuru Rl Reddy:

4 I.T.A. No. 809/Chny/19 6. The next ground raised by the assessee relates to inclusion of disallowance under section 14A while computing book profit under section 115JB of the Act. The Assessing Officer included the expenditure attributable to earning of exempt income under section 14A r.w. Rule 8D while computing book profit under section 115JB of the Act. On appeal

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

255 ITR 220. In Vipan Khanna v. Commissioner of Income Tax (supra), the Punjab and Haryana High Court held that assessment proceedings come to an end and the matter becomes final the moment there was no scrutiny notice within stipulated period of time. "..... Another important change incorporated in sub- section (2) of section 143 of the Act is that

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

255 ITR 220. In Vipan Khanna v. Commissioner of Income Tax (supra), the Punjab and Haryana High Court held that assessment proceedings come to an end and the matter becomes final the moment there was no scrutiny notice within stipulated period of time. "..... Another important change incorporated in sub- section (2) of section 143 of the Act is that

SRI JANARTHANA SPINNING MILLS,COIMBATORE vs. ACIT, COIMBATORE

In the result, the appeal of the assessee stands dismissed

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy]

255/-. While doing so, the AO made the following additions:- a) Disallowance of Depreciation on windmill : 2,03,87,136/- b) Disallowance of purchase expenses u/s.40A(3) : 28,17,587/- c) Disallowance of Commission given to M/s, Balakrishnan Minor HUF : 2,00,000/- u/s.40A(2)(b) Being aggrieved, an appeal was preferred before ld. CIT(A), 3. who vide impugned

ACIT CIRCLE 1, KUMBAKONAM vs. CITY UNION BANK LTD., KUMBAKONAM

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

255/- 4. The Learned Commissioner (Appeals) erred in confirming CSR expenses of Rs.3,53,83,891/- 4.1. The Learned Commissioner (Appeals) failed to appreciate the fact the expenses have resulted in generation of goodwill for the bank. 4.2. The Learned Commissioner (Appeals) failed to appreciate the fact it is only pure CSR expenses without any other benefit are covered

M/S. CITY UNION BANK,,KUMBAKONAM vs. DCIT, CIRCLE - 2 (1),, TRICHY

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

255/- 4. The Learned Commissioner (Appeals) erred in confirming CSR expenses of Rs.3,53,83,891/- 4.1. The Learned Commissioner (Appeals) failed to appreciate the fact the expenses have resulted in generation of goodwill for the bank. 4.2. The Learned Commissioner (Appeals) failed to appreciate the fact it is only pure CSR expenses without any other benefit are covered