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

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

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

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

50C (b) "fair market value" of a property, other than an immovable property, means the value determined in accordance with the method as may be prescribed; (c) "jewellery" shall have the meaning assigned to it in the Explanation to sub-clause (ii) of clause (14) of section 2; (d) "property" means the following capital asset of the assessee, namely

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

50C (b) "fair market value" of a property, other than an immovable property, means the value determined in accordance with the method as may be prescribed; (c) "jewellery" shall have the meaning assigned to it in the Explanation to sub-clause (ii) of clause (14) of section 2; (d) "property" means the following capital asset of the assessee, namely

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

SARAVANAN ARUMUGAM,CHENNAI vs. ITO, CHENNAI

2[(iii) disallowance of loss claimed, if return of the previous year for which set off of loss is claimed was furnished beyond the due date specified under sub-section (1) of section 139; (iv) disallowance of expenditure indicated in the audit report but not taken into account in computing the total income in the return; (v) disallowance of deduction

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

S.BHUVANESWARI,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, assessee’s appeal is allowed

Bench: Shri V.Durga Rao & Shri G.Manjunathaआयकरअपीलसं./I.T.A.No.2944/Chny/2017 ("नधा"रणवष" / Assessment Year: 2013-14) Mrs. S.Bhuvaneswari Vs The Deputy Commissioner Of Hallmark Towers, 4Th Floor, Income Tax, 550 (Old No.136) Ttk Road, Corporate Circle-1(2) Alwarpet, Chennai-600 018. Chennai. Pan: Aadpb 1269K (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowed. The Court went on to hold that a proviso which is inserted to remedy 12 unintended consequences and make the provision workable, a proviso which supplies an obvious omission in the section required to be treated as retrospective so that a reasonable interpretation can be given to the section as a whole. In this case, however, sub-section

JAGANNATHAN SAILAJA CHITTA,CHENNAI vs. ITO, CHENNAI

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

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.1207/Mds/2017 "नधा"रण वष"/Assessment Year:2012-13 Smt. Jagannathan Sailaja Chitta, The Income Tax Officer, New No. 4, Old No. 33, Vs. International Taxation 2(2), Krishna Street, T. Nagar, Chennai 34. Chennai – 17. [Pan:Biqps3751R] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri B. Ramakrishnan, C.A. ""यथ" क" ओर से/Respondent By : Shri A. Srinivasan, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 13.07.2017 घोषणा क" तार"ख /Date Of Pronouncement : 27.09.2017 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) 16, Chennai, Dated 27.03.2017 Relevant To The Assessment Year 2012-13, Wherein, Besides The Ld. Cit(A) Has Not Adjudicated The Additional Ground Raised By The Assessee With Regard To The Claim Of Exemption Under Section 54F Of The Income Tax Act, 1961 [“Act” In Short], The Ld. Cit(A) Has Erred In Confirming Various Disallowances Made Under Section 50C Of The Act, Confirming Disallowance

section 50C of the Act, confirming disallowance 2 I.T.A. No.1207/M/17 of cost incurred for acquisition of properties as well as levy

K.R.JAYARAM,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

Section 50C. Thus there is no escapement warranting reassessment on any fresh material information but only change of opinion. 3. The Commissioner of Income Tax Appeals erred treating the profit as short term capital gains while it was arising out of an adventure in the nature of trade. 4. The Commissioner of Income Tax Appeals has erred in confirming

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

ACIT, CHENNAI vs. M/S. SGP EXIM PVT. LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 2005/Chny/2019 िनधा"रण वष" / Assessment Year: 2012-13 Deputy Commissioner Of M/S. S.G.P. Exim Pvt Ltd., Income Tax, V. No. 68, Cathedral Road, Corporate Circle 6(1), Goapalapuram, Chennai. Chennai – 600 086. [Pan: Aabcs-0551-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. P. Sajit Kumar, Jcit ""यथ" क" ओर से/Respondent By : Shri. G. Baskar, Advocate सुनवाई क" तारीख/Date Of Hearing : 24.11.2022 घोषणा क" तारीख/Date Of Pronouncement : 02.12.2022

2. The Ld. CIT(A) erred in deleting the disallowance of interest expenses of Rs. 6,29,504/- relying on the decision of the Chennai Bench of the Hon'ble Tribunal vide its order ITA No. 1903 & 1599/Mds/2008 dated 17-01-2010 for the AYs 2003-04 & 2004-05 in the assessee's own case, decided in favour

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

DCIT CORPORATE CIRCLE I(1), CHENNAI vs. A V A CHOLAYIL HEALTHCARE PVT. LTD., CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No.783/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 The Deputy Commissioner Of M/S. Ava Cholayil Healthcare Pvt. Ltd., 1583, J. Block, 6Th Avenue, 15Th Main Income Tax, Corporate Circle 1(1), Vs. Chennai 600 034. Road, Chennai 600 102. [Pan: Aaica2178A] (अपीलाथ" /Appellant) (""थ"/Respondent) Department By : Shri G. Chandrababu, Addl. Cit Assessee By : Mrs. Pushya Sitaraman, Advocate सुनवाई की तारीख/ Date Of Hearing : 03.02.2021 घोषणा की तारीख /Date Of Pronouncement : 11.03.2021 आदेश /O R D E R Per Duvvurul Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 4, Chennai Dated 28.12.2018 Relevant To The Assessment Year 2013-14. The Revenue Has Raised The Following Grounds: “1. The Order Of The Ld. Cit(A) Is Contrary To Law, Facts & Circumstances Of The Case. 2. The Ld. Cit(A) Erred In Giving Relief To The Assessee By Deleting The Disallowance Of Rs.44,22,711/- For Ay 2013-14 & Rs.45,56,529/- For Ay 2014-15 Claimed Under Section 36( 1 )(Iii) When The Assessee Company Has Not Produced Any Evidence Regarding The Transaction For Validating The Claim That It Arose

section 50C were satisfied or not by the assessee. 6. For these and other grounds that may be adduced at the time of hearing, it is prayed that the order of the ld. CIT(A) be set aside and that of the AO restored.” 2. The first effective ground raised by the Revenue relates to deletion of disallowance

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