SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), 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

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

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRIPROP PROPERTIES PRIVATE LIMITED, BANGALORE

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

disallowance of agricultural income to Rs.3,21,569/- as against Rs.15,87,241/- made by the AO. 8. Aggrieved by the order of the ld.CIT(A), the assessee filed an appeal before this Tribunal on various grounds challenging the validity of the assessment order, addition u/s.56(2)(vii) of the Act and addition u/s.50C of the Act mentioned

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

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].

disallowance of claim made by the assessee under section 54F of the Act has nothing to do with the show cause notice issued by the undersigned. Accordingly the objection raised on this issue is settled. 5.1. With regard to the issue of 50C, it is verified from the records that the assessee has sold 4 plots bearing plots nos.99

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:

disallowed the difference amount, which attracts the provisions of section 56(2)(vii)(b) of the Act. The Assessing Officer has further noted that as per section 56(2)(vii)(b) of the Act provides that in case of where there is transfer of an immovable property either without consideration or a consideration which is less than the stamp duty

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

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

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

disallowance of expenditure u/s. 40(a)(ia) of the Act. Aggrieved by the CIT(A) order, the assessee is in appeal before us. 7. The first issue that came up for our consideration from ground no. 2 to 5 of assesse’s appeal is addition of Rs. 8,25,000/- u/s. 56(2)(vii)(c) of the Act, towards difference

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

2.—For the removal of doubts, it is hereby declared that the\ndetermination of the value of an asset or liability for the sole purpose of payment of\nstamp duty, registration fees or other similar taxes or fees shall not be regarded as\nassignment of values to individual assets or liabilities;\n23. The Section does not permit identification / value attribution

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

SCHNEIDER ELECTRIC SYSTEMS INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE - JAO - ACIT, CORPORATE CIRCLE, 3(1), CHENNAI

In the result all the four appeals of the Assessee and both the appeals of the revenue are partly allowed

Bench: Shri George George K & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2754, 2755, 2756 & 2757/Cnny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17, 2017-18, 2018-19 & Sa 22/Chny/2025 [In Ita 2757/Chny/2024] धनिाजरण वर्ज / Assessment Year: 2018-19 Schneider Electric Systems Acit India Private Limited, Vs. Corporate Circle 3(1) Sp Plot, 16-20 & 20A, Chennai. Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.: 2958 & 2959/Chny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17 Acit Schneider Electric Systems India Private Limited, Corporate Circle 3(1) Vs. Chennai. Sp Plot, 16-20 & 20A, Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) धनिाजररती की ओर से/Assessee By : Shri. Rohit Tiwari, Advocate & Ms. Tanya, Advocate (Virtual) राजस्व की ओर से /Revenue By : Shri. Arv Sreenivasan, Cit.

2 5. The Assessee has reimbursed its AE on cost to cost basis in relation to Support Services received from its AE during all above referred AY’s. However, the TPO during the course of assessment, has called upon the Assessee to furnish evidence to substantiate the receipt of support services. The Assessee seem to have not furnished the required

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

In the result all the four appeals of the Assessee and both the appeals of the revenue are partly allowed

Bench: Shri George George K & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2754, 2755, 2756 & 2757/Cnny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17, 2017-18, 2018-19 & Sa 22/Chny/2025 [In Ita 2757/Chny/2024] धनिाजरण वर्ज / Assessment Year: 2018-19 Schneider Electric Systems Acit India Private Limited, Vs. Corporate Circle 3(1) Sp Plot, 16-20 & 20A, Chennai. Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.: 2958 & 2959/Chny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17 Acit Schneider Electric Systems India Private Limited, Corporate Circle 3(1) Vs. Chennai. Sp Plot, 16-20 & 20A, Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) धनिाजररती की ओर से/Assessee By : Shri. Rohit Tiwari, Advocate & Ms. Tanya, Advocate (Virtual) राजस्व की ओर से /Revenue By : Shri. Arv Sreenivasan, Cit.

2 5. The Assessee has reimbursed its AE on cost to cost basis in relation to Support Services received from its AE during all above referred AY’s. However, the TPO during the course of assessment, has called upon the Assessee to furnish evidence to substantiate the receipt of support services. The Assessee seem to have not furnished the required

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

In the result all the four appeals of the Assessee and both the appeals of the revenue are partly allowed

Bench: Shri George George K & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 2754, 2755, 2756 & 2757/Cnny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17, 2017-18, 2018-19 & Sa 22/Chny/2025 [In Ita 2757/Chny/2024] धनिाजरण वर्ज / Assessment Year: 2018-19 Schneider Electric Systems Acit India Private Limited, Vs. Corporate Circle 3(1) Sp Plot, 16-20 & 20A, Chennai. Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) आयकर अपील सं./Ita Nos.: 2958 & 2959/Chny/2024 धनिाजरण वर्ज / Assessment Year: 2015-16, 2016-17 Acit Schneider Electric Systems India Private Limited, Corporate Circle 3(1) Vs. Chennai. Sp Plot, 16-20 & 20A, Tamarai Tech Park, Inner Ring Road, Thiru Vi Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aabcs-8027-M] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) धनिाजररती की ओर से/Assessee By : Shri. Rohit Tiwari, Advocate & Ms. Tanya, Advocate (Virtual) राजस्व की ओर से /Revenue By : Shri. Arv Sreenivasan, Cit.

2 5. The Assessee has reimbursed its AE on cost to cost basis in relation to Support Services received from its AE during all above referred AY’s. However, the TPO during the course of assessment, has called upon the Assessee to furnish evidence to substantiate the receipt of support services. The Assessee seem to have not furnished the required