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167 results for “disallowance”+ Section 54F(1)clear

Sorted by relevance

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Key Topics

Section 54F265Section 5493Section 143(3)58Exemption57Deduction55Disallowance54Capital Gains47Addition to Income46Section 271(1)(c)44Long Term Capital Gains

M/S ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

ITA 1164/CHNY/2023[2015-16]Status: DisposedITAT Chennai06 Mar 2024AY 2015-16

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 271Section 271(1)(C)Section 271ASection 274

disallowance of marketing expenses. Had search been not conducted in the case of the assessee, the modus operandi of the assessee and generation of unaccounted income was gone unnoticed. Therefore, the arguments of the assessee that it has not furnished inaccurate particulars of income or concealment of particulars of income, is incorrect. The Ld.DR further submitted that the assessee

M/S.ENRICA ENTERPRISES PVT LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Showing 1–20 of 167 · Page 1 of 9

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Section 26330
Section 153A26
ITA 1165/CHNY/2023[2016-17]Status: DisposedITAT Chennai06 Mar 2024AY 2016-17

Bench: Shri Manjunatha. G & Shri Manomohan Das

Section 271Section 271(1)(C)Section 271ASection 274

disallowance of marketing expenses. Had search been not conducted in the case of the assessee, the modus operandi of the assessee and generation of unaccounted income was gone unnoticed. Therefore, the arguments of the assessee that it has not furnished inaccurate particulars of income or concealment of particulars of income, is incorrect. The Ld.DR further submitted that the assessee

ASSISTANT COMMISSIONER OF INCOME TAX NON CORPORATE CIRCLE 18(1), CHENNAI vs. SHRI. B SUNDARAJAN, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and appeal of the assessee is allowed for statistical purposes

ITA 431/CHNY/2018[2008-09]Status: DisposedITAT Chennai16 Sept 2021AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 431/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 The Assistant Commissioner Of Vs. Shri B. Sundararajan, Income Tax, No. 34, Umapathy Street, Non Corporate Circle 18(1), West Mambalam, Chennai 600 033. Chennai 600 034. [Pan:Aasps3969C] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 95/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 Shri B. Sundararajan, The Deputy Commissioner Of No. 34, Umapathy Street, Vs. Income Tax, West Mambalam, Chennai 600 033. Non Corporate Circle 18(1), Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Mrs. V.S. Sreelekha, Cit Assessee By Shri N. Arjunraj, Ca For : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2017 Relevant To The Assessment Year 2008-09. 2

For Respondent: Mrs. V.S. Sreelekha, CIT
Section 143(1)Section 143(3)Section 147Section 148Section 54F

1) and sub- section (2) of section 54F of the Act that the assessee is eligible for claiming deduction under section 54F of the Act only for one property. Since the assessee purchased two properties on 19.03.2008 one for an amount of ₹.11,97,00,180/- and the other one for an amount of ₹.6,52,39,980/-, the claim

B.SUNDARARAJAN,CHENNAI vs. DCIT, NON CORPORATE CIRCLE, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and appeal of the assessee is allowed for statistical purposes

ITA 95/CHNY/2018[2008-09]Status: DisposedITAT Chennai16 Sept 2021AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 431/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 The Assistant Commissioner Of Vs. Shri B. Sundararajan, Income Tax, No. 34, Umapathy Street, Non Corporate Circle 18(1), West Mambalam, Chennai 600 033. Chennai 600 034. [Pan:Aasps3969C] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 95/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 Shri B. Sundararajan, The Deputy Commissioner Of No. 34, Umapathy Street, Vs. Income Tax, West Mambalam, Chennai 600 033. Non Corporate Circle 18(1), Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Mrs. V.S. Sreelekha, Cit Assessee By Shri N. Arjunraj, Ca For : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2017 Relevant To The Assessment Year 2008-09. 2

For Respondent: Mrs. V.S. Sreelekha, CIT
Section 143(1)Section 143(3)Section 147Section 148Section 54F

1) and sub- section (2) of section 54F of the Act that the assessee is eligible for claiming deduction under section 54F of the Act only for one property. Since the assessee purchased two properties on 19.03.2008 one for an amount of ₹.11,97,00,180/- and the other one for an amount of ₹.6,52,39,980/-, the claim

ITO NON CORP WARD 14 (4), CHENNAI vs. SMT. B VATHSALA, CHENNAI

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

ITA 1112/CHNY/2018[2008-09]Status: DisposedITAT Chennai27 Dec 2019AY 2008-09

Bench: Shri Ramit Kochar & Shri Duvvuru R.L. Reddyआयकर अपील सं./I.T.A. No. 1112/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 The Income Tax Officer, Smt. B. Vathsala, Non-Corporate Ward-14(4), Vs. No.34/30, Umapathy Street, Chennai. West Mambalam, Chennai – 600 033. [Pan: Actpb 9534H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Srinivasa Rao Vana, Jcit ""थ" की ओर से/Respondent By : Shri N. Arjun Raj, C.A For Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 19.11.2019 घोषणा की तारीख /Date Of Pronouncement : 27.12.2019 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)-14, Chennai Dated 15.12.2017 Relevant To The Assessment Year 2008-09. The Only Effective Ground In This Appeal Raised By The Revenue Is That The Ld. Cit(A) Has Erred In Directing The Assessing Officer To Allow The Assessee’S Claim Of Deduction Under Section 54F Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Shri Srinivasa Rao Vana, JCITFor Respondent: Shri N. Arjun Raj, C.A for Shri S. Sridhar, Advocate
Section 143(1)Section 143(3)Section 147Section 148Section 54F

1) and sub- section (2) of section 54F of the Act that the assessee is eligible for claiming deduction under section 54F of the Act only for one property. Since the assessee purchased two properties on 19.03.2008 one for an amount of ₹.11,97,00,180/- and the other one for an amount of ₹.6,52,39,980/-, the claim

SHRI D. RAVIKUMAR,,CHENNAI vs. ACIT, NCC-14,, CHENNAI

In the result, the orders of the Assessing Officer and Commissioner of Income Tax (Appeals) and Income Tax

ITA 3314/CHNY/2019[2007-08]Status: DisposedITAT Chennai27 Jul 2022AY 2007-08

Bench: Shri V. Durga Rao & Shri G. Manjunatha

For Appellant: Mr. P.Sajit Kumar, JCITFor Respondent: 14.07.2022
Section 54F

section 54F(1) of the Act to the appellant is hereby quashed. In the result, appeal is allowed.” 7. In this view of the matter, and by respectfully following decision of the Hon’ble Karnataka High Court in the case of Navin Vs, ITO (supra), we are of the considered view that the assessee is entitled for deduction u/s.54F

DEPUTY COMMISSIONER OF INCOME TAX, NON-CORPORATE CIRCLE 7(1), CHENNAI vs. VELLORE SUBRAMANIAN SARAVANAN, CHENNAI

In the result, appeal filed by the Re

ITA 1132/CHNY/2023[2015]Status: DisposedITAT Chennai25 Mar 2025

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. D. Anand, AdvocateFor Respondent: Ms. Anita, Addl. CIT
Section 54F

Section 54F(1) as the assessee has carried out the construction of a residential building f a residential building, which includes the purchase of the purchase of land, and therefore, the assessee was entitled to the benefit of the assessee was entitled to the benefit of the assessee was entitled to the benefit of sec.54F for the above said amount

VANAVIL ESTATE,CHENNAI vs. PCIT(CENTRAL), CHENNAI

In the result, the appeal for both AYs 2017

ITA 925/CHNY/2024[2017-18]Status: DisposedITAT Chennai12 Feb 2025AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

1(c) provides that, when the appeal is when the appeal is pending before the Commissioner pending before the Commissioner (Appeals), then jurisdiction under jurisdiction under Section 263 of the Act Section 263 of the Act cannot be exercised. In the decided case, the In the decided case, the assessee had originally filed the return of income disclosing long term

VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

ITA 926/CHNY/2024[2018-19]Status: DisposedITAT Chennai12 Feb 2025AY 2018-19

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri R. Clement Ramesh-
Section 133ASection 148Section 263

1(c) provides that, when the appeal is when the appeal is pending before the Commissioner pending before the Commissioner (Appeals), then jurisdiction under jurisdiction under Section 263 of the Act Section 263 of the Act cannot be exercised. In the decided case, the In the decided case, the assessee had originally filed the return of income disclosing long term

JAGANNATHAN SAILAJA CHITTA,CHENNAI vs. ITO, CHENNAI

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

ITA 1207/CHNY/2017[2012-13]Status: DisposedITAT Chennai27 Sept 2017AY 2012-13

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

For Appellant: Shri B. Ramakrishnan, C.AFor Respondent: Shri A. Srinivasan, JCIT
Section 142(1)Section 143(2)Section 143(3)Section 234BSection 50CSection 50C(1)Section 54Section 54F

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 2 I.T.A. No.1207/M/17 of cost incurred for acquisition of properties as well as levy of interest under section 234B and 234C of the Act. 2. Brief facts of the case

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 908/CHNY/2020[2001-02]Status: DisposedITAT Chennai13 May 2022AY 2001-02

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 912/CHNY/2020[2005-06]Status: DisposedITAT Chennai13 May 2022AY 2005-06

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 910/CHNY/2020[2003-04]Status: DisposedITAT Chennai13 May 2022AY 2003-04

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 911/CHNY/2020[2004-05]Status: DisposedITAT Chennai13 May 2022AY 2004-05

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 909/CHNY/2020[2002-03]Status: DisposedITAT Chennai13 May 2022AY 2002-03

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 905/CHNY/2020[1998-99]Status: DisposedITAT Chennai13 May 2022AY 1998-99

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 906/CHNY/2020[1999-2000]Status: DisposedITAT Chennai13 May 2022AY 1999-2000

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

SHRI MAHAVEERCHAND JAIN,CHENNAI vs. DCIT,CC4(2), CHENNAI

The appeals stand allowed on similar lines

ITA 907/CHNY/2020[2000-01]Status: DisposedITAT Chennai13 May 2022AY 2000-01

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri D. Anand (Advocate) – Ld. ARFor Respondent: Shri G. Johnson (Addl. CIT) –Ld. Sr. DR
Section 271Section 271(1)(c)Section 274

disallowance of a certain claim made by the assessee which would neither mean that the assessee has concealed any income or furnished inaccurate particulars warranting levy of penalty. 7. The learned Commissioner (Appeals) ought to have seen that for sustaining penalty, the bona fide explanation of the assessee has to be considered and that merely because the assessment proceedings have

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

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

ITA 1535/CHNY/2024[2016-17]Status: DisposedITAT Chennai31 Oct 2025AY 2016-17

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

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

disallowance of deduction u/s 54F automatically stand deleted. Having held so, we refrain from going into the merits of individual additions. Levy of interest under sections 234A, 234B and 234C being consequential, and initiation of penalty u/s 271(1

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

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

ITA 1801/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Oct 2025AY 2015-16

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

For Appellant: Mr.T.S. LakshmiFor Respondent: Mr.Shiva Srinivas, CIT
Section 115BSection 143(3)Section 153ASection 250Section 250(6)Section 37Section 68

disallowance of deduction u/s 54F automatically stand deleted. Having held so, we refrain from going into the merits of individual additions. Levy of interest under sections 234A, 234B and 234C being consequential, and initiation of penalty u/s 271(1