DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SPL SHELTERS PRIVATE LIMITED, CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case for AY 2018-19. The ld. AR in this regard relied

SARAVANAN ARUMUGAM,CHENNAI vs. ITO, CHENNAI

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

50C\nand sub-section (15) of section 155 shall, as far as may be, apply in relation\nto the stamp duty value of such property for the purpose of sub-clause (b) as\nthey apply for valuation of capital asset under those sections:\nSection 142A\n1[142A. Estimationof value of assets by Valuation Officer.—(1) The Assessing\nOfficermay

SHRIPROP PROPERTIES PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Accordingly.\n15. In result, appeal of both the assessees in ITA No. 1172 & 1173/Chny/2025\nare allowed and the appeal of the revenue in ITA No

disallowance of interest on TDS.\nThe assessee and the revenue are in appeal against the order of the CIT(A).\n5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is\nretrospective in nature and therefore should be applied in assessee's case for AY\n2018-19. The ld. AR in this regard relied

TIRUCHANGODU RAMASAMY KHANNAIYANN SARASUWATHI,COIMBATORE vs. DCIT, CENTRAL CIRCLE-1,, COIMBATORE

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

50C of the Income Tax Act despite the fact that the appellant had sought for reference to the DVO in respect of the valuation of the impugned property. 13. For that the Commissioner of Income Tax (Appeals) erred in not acceding to the request of the appellant for reference to the DVO for valuation of the impugned property. Levy

ASIRVAD MICRO FINANCE LIMITED,ANNA SALAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1140/Chny/2025 Assessment Years: 2016-17 Asirvad Micro Finance Limited, Assistant Commissioner Of No.9, 9Th Floor, Club House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [Pan: Aagca5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.P.R.Prasanna Varma, Fca & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 25.09.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

disallowance of Rs.42,29,48,758/- by the Ld.CIT(A) which was made by the Ld.AO invoking provisions of section 56(2)(viib) of the Act. It was contested that the addition by the Ld.AO was based upon an arbitrary application of Rule-11UA of the Income Tax Rules. 3.0 During the course of present proceedings, the Ld.Counsel

SMT ELIZEBETH VASHEELAKUMARI,NAGERCOIL vs. ACI, CIRCLE-I, NAGERCOIL RANGE, NAGERCOIL

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.783/Chny/2020 िनधा"रण वष"/Assessment Year: 2015-16 Smt. Elizebeth Vasheelakumari, Vs. The Assistant Commissioner Of No. 3, Parama Street, W.C.C. Road, Income Tax, Circle I, Nagercoil 629 001. Nagercoil Range, Nagercoil. [Pan:Abqpe8121P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 31.01.2023 घोषणा की तारीख /Date Of Pronouncement : 03.02.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax/Cit 1, Madurai, Dated 21.03.2020 Relevant To The Assessment Year 2015-16 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

1,60,00,000) was not brought to tax as required under section 50C of the Act, the ld. PCIT has observed that the assessment order passed under section 143(3) of the Act is erroneous and prejudicial to the interest of the Revenue and issued show-cause notice under section 263 of the Act dated 23.07.2019. 3 I.T.A. No.783/Chny/20

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

disallowed this sum of Rs.5,14,200/- The AO noted that the assessee vide submissions dated 07.12.2021 produced sample copies of vouchers for claim of incurring of expenditure towards helper allowances. The CIT(A) also confirmed the action of AO as these are neither fresh claim arising out of search proceedings found during the course of search and even

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

disallowed this sum of Rs.5,14,200/- The AO noted that the assessee vide submissions dated 07.12.2021 produced sample copies of vouchers for claim of incurring of expenditure towards helper allowances. The CIT(A) also confirmed the action of AO as these are neither fresh claim arising out of search proceedings found during the course of search and even

AVANASIYAPPAN ESWARAN,TIRUPPUR vs. ITO,WARD 1(2), TIRUPPUR

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri George George K & Shri S.R. Raghunatha

disallowed the claim of exemption under Section 54F. 4. Aggrieved by the order of the FAA, assessee has filed the present appeal before the Tribunal raising the following grounds:- 1) The Order of the Ld. CIT(A), NFAC is unsustainable, both on law and on the facts of the case. 2) The Ld. CIT(A) failed to appreciate that

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

disallowing the deduction u/s 80-IAB of the Act. The Ld. CIT, DR thereafter took us through the provisions contained in the SEZ Act and the SEZ Rules and explained the purpose behind the deduction granted u/s 80-IAB of the Act, which was to promote the development of infrastructure in the SEZ. The Ld. CIT, DR particularly invited

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14\n& 2014-15 stands dismissed

disallowing the deduction u/s\n80-IAB of the Act. The Ld. CIT, DR thereafter took us through the\nprovisions contained in the SEZ Act and the SEZ Rules and explained the\npurpose behind the deduction granted u/s 80-IAB of the Act, which was to\npromote the development of infrastructure in the SEZ. The Ld. CIT, DR\nparticularly invited

ACIT CORPORATE CIRCLE 4(1), CHENNAI vs. MANGAL TIRTH ESTATE LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 1965/Chny/2018 िनधा"रण वष" / Assessment Year: 2014-15 Assistant Commissioner Of M/S. Mangal Tirth Estate Ltd., Income-Tax, V. No. 769, Spencer Plaza, Corporate Circle-4(1), Anna Salai, Chennai – 600 002. Chennai. [Pan: Aaacm-4614-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By : Shri. N.V. Balaji, Advocate सुनवाई क" तारीख/Date Of Hearing : 29.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 31.01.2023

section 50C of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) and adopted deemed consideration for computation of long term capital gains. The relevant findings of the AO are as under: From the above noting the following points emerged : 1. As on 31.03.1999, Out of 1,50,000 sq.ft. the assessee company had handed over 1

LACHHMAN,SALEM vs. ITO , SALE

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.526/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Shri Lachhman, Vs. The Income Tax Officer, No. 9/1, Sait Extension, Rajaji Road, Ward I(4), Salem, 636 007. Salem. [Pan:Abspl0425F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate (Erode) ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 16.02.2023 घोषणा की तारीख /Date Of Pronouncement : 28.02.2023 आदेश /O R D E R Per V. Durga Rao:

1) of 2 I.T.A. No.526/Chny/22 the Income Tax Act, 1961 [“Act” in short]. Subsequently, the case was selected for scrutiny through CASS and notice under section 143(2) of the Act was issued on 21.09.2018 and the same was served on the assessee on 26.09.2018. After following due procedure, the assessment was completed under section

SCHNEIDER ELECTRIC SYSTEMS INDIA PRIVATE LIMITED,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX CORPORATE CIRCLE, 3(1), CHENNAI

1) of the Act and was selected for scrutiny\nassessment.\n:-3-:\nITA. Nos:2754 to 2757/Chny/2024,\nITA. Nos:2958 & 2959/Chny/2024 &\nSA No.:22/Chny/2025\n3. During the scrutiny assessment proceedings, the Transfer Pricing Officer\n('TPO') and the Assessing Officer ('AO') made certain adjustments /\ndisallowances to the assessee's income. Against the draft assessment order of\nthe AO, the assessee

DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), CHENNAI vs. RADIANCE REALTY DEVELOPERS INDIA LTD., CHENNAI

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 44AD, 44AAD of the Act wherein the income is are envisaged in section 44AD, 44AAD of the Act wherein the income is are envisaged in section 44AD, 44AAD of the Act wherein the income is allowed to be estimated upon percentage. The provisions of section allowed to be estimated upon percentage. The provisions of section allowed to be estimated

MAHINDRA RESIDENTIAL DEVELOPERS LTD.,CHENGALPUT vs. ITO, CHENNAI

disallowing the deduction u/s\n80-IAB of the Act. The Ld. CIT, DR thereafter took us through the\nprovisions contained in the SEZ Act and the SEZ Rules and explained the\npurpose behind the deduction granted u/s 80-IAB of the Act, which was to\npromote the development of infrastructure in the SEZ. The Ld. CIT, DR\nparticularly invited

PENUPETRUNI CHINNA RAO,CHENNAI vs. ITO, INTERNATIONAL TAXATION, WARD-1(1), CHENNAI

In the result, the appeal stand partly allowed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.401/Chny/2022 (िनधा*रण वष* / Assessment Year: 2016-17) Mr. Penupatruni Chinna Rao Ito बनाम 8, Pughs Road, Sundaram Salai, International Taxation, / Vs. R.A. Puram, Chennai-600 028. Ward-1(1), Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aecpc-1481-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. N.V. Lakshmi (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Shri D. Hema Bhupal (Jcit)- Ld. Sr. Dr सुनवाईकीतारीख/Date Of Final Hearing : 04-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 25-04-2024 आदेश / O R D E R

50C(1) of the Act which has been held to have retrospective operation for the purpose of guideline value, the agreement of sale which took place in the previous year relevant to the AY 2013-14, only should have been considered as the date of transfer. H. The learned CIT(A) erred in endorsing the view of the AO that

THIDUVIL BALAKRISHNAN,CHENNAI vs. ITO, NONCORP, WARD 4(5), CHENNAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T. Varkery, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 963/Chny/2022 िनधा"रण वष" / Assessment Year: 2016-17 Thiduvil Balakrishnan, Deputy Commissioner Of Old No.3, New No. 4, V. Income-Tax, 5Th Street, 4Th Cross, Central Circle -2(2), Seetharam Nagar, Chennai – 600 034. Chennai – 600 112. [Pan: Afmpb-5184-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. T. Vasudevan, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. P. Sajit Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 20.03.2023 घोषणा की तारीख/Date Of Pronouncement : 24.03.2023

50C of the Act, if difference between guideline value and consideration paid for purchase of property is less than the tolerance band, then said difference cannot be considered as deemed consideration in the hands of the seller and consequently the provisions of section :-9-: ITA. No:963/Chny/2022 56(2)(vii)(c) of the Act cannot be invoked in the hands