M P SANTHOSH KUMAR, ITO, CHENNAI vs. GREENPEACE ENVIRONMENT TRUST, CHENNAI

In the result the appeal filed by the Revenue stands dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 509/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2017-18 Income Tax Officer, Greenpeace Environment Trust, Exemptions, Ward-1, Vs. New No.49, Old No.23, Chennai. Ellaiamman Colony, Gopalapuram, Chennai-600 086. [Pan:Aaatg-3538-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. Kumar Chandan, Jcit. प्रत्यथी की ओर से/Respondent By : Shri. Y.Sridhar, F.C.A. सुनवाई की तारीख/Date Of Hearing : 19.06.2025 घोर्णा की तारीख/Date Of Pronouncement : 25.08.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

747 B. ADHOC DISALLOWANCE - GROUND 4 : 2. In the Order, the Appellant's Charitable activity and nature have not been questioned by the AO and it is undisputed. This is clear inter alia from the fact that 15% exemption, capital additions of Rs.5,47,908/- and application of preceding years' accumulation under Section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:1872, 1873, 1875, 1877 & 1878/Chny/2025 निर्धारण वर्ष / Assessment Years: 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18 Acit, Central Circle -2, Madurai. Vs. Transworld Garnet India Pvt. Ltd., 500, Pantheaon Road, Egmore S.O., Chennai - 600 008. [Pan: Aaact-3408-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. R.Venkata Raman, C.A. प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, C.I.T. सुनवाई की तारीख /Date Of Hearing : 24.09.2025 घोषणा की तारीख/Date Of Pronouncement : 23.10.2025 आदेश /Order Per S. R. Raghunatha, Am : These Five Appeals Preferred By The Revenue Are Directed Against The Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [Hereinafter Referred To As “The Id.Cit(A)”]. The Impugned Orders Of The Id.Cit(A) Arise Out Of The Assessment Orders Framed By The Assistant Commissioner Of Income Tax, Central Circle-2, Madurai [Hereinafter Referred To As “The Ao”], In Respect Of The Assessment Years 2013-14 To 2017-18. The Particulars Of The Respective Appeals Filed By The Revenue Are Set Out Hereinbelow:- S. No

Disallowance u/s.40A(3) of Rs.5,41,05,184/-; Unaccounted cash receipts of Rs.16,18,61,715/-; and Inflated expenses of Rs.16,92,44,747/- (Based on the seized material, the AO discussed in the assessment order that this addition pertained to A.Y.2015-16. However, in the computation section

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

Disallowance u/s.40A(3) of Rs.5,41,05,184/-; iii. Unaccounted cash receipts of Rs.16,18,61,715/-; and iv. Inflated expenses of Rs.16,92,44,747/- (Based on the seized material, the AO discussed in the assessment order that this addition pertained to A.Y.2015-16. However, in the computation section

M/S. PKF PROSERV PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.3086/Mds/2016 "नधा"रण वष"/Assessment Year:2012-13 M/S. Pkf Preserv Private Limited, The Assistant Commissioner Of [Formerly S&S Business Solutions Pvt. Vs. Income Tax, Ltd.], No. 195, New No. 28, Non Corporate Circle 15(1), North Usman Road, T. Nagar, Chennai Chennai 600 017. [Pan: Aafcs3710E] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S.Hariharan, C.A. ""यथ" क" ओर से/Respondent By : Shri S. Mohamed Mustafa, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 25.05.2017 घोषणा क" तार"ख /Date Of Pronouncement : 12.07.2017

disallowance, against which, the assessee is in appeal before the Tribunal. 5. We have heard both sides, perused the materials available on record and gone through the orders of authorities below. By filing written submission, the ld. Counsel for the assessee has submitted that out of total interest debited in the accounts of ₹.27,56,592/-, ₹.4,86,747 pertains

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

ITO, VELLORE vs. N.BALAKRISHNAN, TIRUVANNAMALAI

In the result, Revenue’s appeals in I

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.991/Mds/2014 "नधा"रण वष" / Assessment Year : 2008-09

747/-. It is not in dispute that the paddy was purchased from agriculturists. The agricultural produce in this country are sold in unregulated market. Expecting bills from the farmers for purchase of paddy is something impossible in this country. Majority of the agriculturists in this country are illiterate and they would sell the agricultural produce, including the paddy

ITO, VELLORE vs. N.BALAKRISHNAN, TIRUVANNAMALAI

In the result, Revenue’s appeals in I

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.991/Mds/2014 "नधा"रण वष" / Assessment Year : 2008-09

747/-. It is not in dispute that the paddy was purchased from agriculturists. The agricultural produce in this country are sold in unregulated market. Expecting bills from the farmers for purchase of paddy is something impossible in this country. Majority of the agriculturists in this country are illiterate and they would sell the agricultural produce, including the paddy

ITO, VELLORE vs. PUNITHA BALAKRISHNAN, TIRUVANNAMALAI

In the result, Revenue’s appeals in I

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.991/Mds/2014 "नधा"रण वष" / Assessment Year : 2008-09

747/-. It is not in dispute that the paddy was purchased from agriculturists. The agricultural produce in this country are sold in unregulated market. Expecting bills from the farmers for purchase of paddy is something impossible in this country. Majority of the agriculturists in this country are illiterate and they would sell the agricultural produce, including the paddy

NAPC LIMITED,CHENNAI vs. ITO,CORPORATE CIRCLE 4(2), CHENNAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha.G, Hon’Bleआयकर अपील सं./Ita No.487/Chny/2023 िनधा"रण वष" /Assessment Year: 2018-19 V. M/S.Napc Ltd., The Income Tax Officer, No.1A, Royal Court, Corporate Circle-4(2), First Floor, Chennai. No.41, Venkatnarayana Road, T. Nagar, Chennai-600 017. [Pan: Aaccn 3625 P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Mr.H.Yeshwanth Kumar, Ca ""थ" की ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 25.07.2023 घोषणा की तारीख /Date Of Pronouncement : 02.08.2023

747/- by making disallowance of Rs.2,02,67,165/- towards employees’ contribution to PF & ESI u/s.36(1)(va) r.w.s.43B of the Act. The assessee carried the matter in appeal before the First Appellate Authority, and the Ld.CIT(A) for the reasons stated in his appellate order dated 06.03.2023, rejected the arguments of the assessee and sustained :: 3 :: the additions made

T vs. CREDIT SERVICES LIMITED,CHENNAIVS.ACIT CORPORATE CIRCLE 3(1), CHENNAI

Appeal of the Revenue is dismissed whereas that of cross objection of the assessee is party allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

Section 56(2) (vii) of the Act. Assessee had given the breakup of the sum of "93,200/- as under:- Sl.No Name Relationship Amount in " 1 Rakesh P. Sheth Husband 25,000 2 JyothiChundur Mother 15,000 3 Premsaichundur Brother 15,000 4 Staff Staff 5,000 5 Premkumaar K.Sheth Father-in-law 33,200 Total 93,200 Ld. Assessing

S ANAND L/H OF LATE V SAMPATH,CHENNAI vs. ACIT NON CORPORATE CIRCLE 2 , CHENNAI

In the result, the assessee’s appeal is treated as allowed

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. No. 1231/Chny/2018 "नधा"रणवष"/Assessment Year : 2010-11

disallowed Rs. 77,65,747/- paid to M/s. Anand and Venkatesh, a partnership firm, without deducting tax at source u/s. 40a(ia). Aggrieved against that order, the assessee filed an appeal before the Ld. CIT(A) pleading, inter alia, that the payments made to M/s. Anand and Venkatesh was accounted and offered by them and they have paid the taxes

ASVINI FISHERIES (P) LTD. ,CHENNAI vs. DCITCOMPANY CIRCLE 1(1) , CHENNAI

In the result, the assessee’s above appeals are treated as allowed for

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. Nos. 1708 & 1709/Chny/2017 "नधा"रणवष"/Assessment Year : 2010-11 & 2011-12

section 73 of the Income tax Act, 1961. Such losses from speculation business of Rs.2,56,46,747/ - is allowed to be carried forward for set off against any future speculation income accrue in succeeding period and in relevant assessment years, as per the provisions of the Act on 'Set-off of Losses'. [ Disallowance

ASVINI FISHERIES (P) LTD. ,CHENNAI vs. DCITCOMPANY CIRCLE 1(1) , CHENNAI

In the result, the assessee’s above appeals are treated as allowed for

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. Nos. 1708 & 1709/Chny/2017 "नधा"रणवष"/Assessment Year : 2010-11 & 2011-12

section 73 of the Income tax Act, 1961. Such losses from speculation business of Rs.2,56,46,747/ - is allowed to be carried forward for set off against any future speculation income accrue in succeeding period and in relevant assessment years, as per the provisions of the Act on 'Set-off of Losses'. [ Disallowance

DCIT, CHENNAI vs. ASVINI FISHERIES P LTD., CHENNAI

In the result, the Revenue’s appeals in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

section 73 of the Income tax Act, 1961. Such losses from speculation business of Rs.2,56,46,747/ - is allowed to be carried forward for set off against any future speculation income accrue in succeeding period and in relevant assessment years, as per the provisions of the Act on 'Set-off of Losses'. [ Disallowance

DCIT, CHENNAI vs. ASVINI FISHERIES P LTD., CHENNAI

In the result, the Revenue’s appeals in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

section 73 of the Income tax Act, 1961. Such losses from speculation business of Rs.2,56,46,747/ - is allowed to be carried forward for set off against any future speculation income accrue in succeeding period and in relevant assessment years, as per the provisions of the Act on 'Set-off of Losses'. [ Disallowance

MMRF REALITY AND INFRASTRUCTURE PVT LTD,CHENNAI vs. DCIT CORPORATE CIRCLE 4 (1), CHENNAI

In the result, the assessee’s appeal is partly allowed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.627/Chny/2018 िनधा"रण वष"/Assessment Year: 2012-13 Mmrf Realty & Infrastructure Pvt. The Deputy Commissioner Of Vs. Ltd., No. 21, Indira Nagar, Income Tax, 1St Avenue, Adyar, Corporate Circle -4(1), Chennai – 600 020. Chennai. [Pan: Aahcm1575E] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I. Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 04.01.2022 घोषणा की तारीख /Date Of Pronouncement : 24.01.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee Is Against The Impugned Order Of The Ld. Commissioner Of Income Tax (Appeals) 8, Chennai Dated 20.12.2017 In Ita No. 162/15-16 For The Assessment Year 2012-13. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. The Order Of The Commissioner Of Income Tax (Appeals) Enhancing The Assessment Is Wrong, Illegal, Unjust, Arbitrary & Is Liable To Set Aside.

747/ as expenditure covered u/s.35D on the assumption that the Appellant's business operations had not commenced. 4. The commissioner of Income Tax (Appeals) erred in disallowing the depreciation of Rs. 13,503/-on office furniture and computer. 5.1. The Commissioner of Income Tax (Appeals) erred in holding that the professional charges of Rs. 7,50,000/- is attributable

C.R.ANAND EDUCATIONAL TRUST,MADURAI vs. ITO, EXEMPTION, MADURAI

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri C.M. Garg, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.2802/Chny/2019 (धििाारण वर्ा / Assessment Year : 2009-10) C.R. Anand Educational Trust, V Ito, Exemption, Madurai. No. 34, Ganeshapuram, S K. Pudur, Madurai – 625 007. Pan No. : Aabtc1675J (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्ाारिती की ओर से /Assessee By : Shri S. Sankaralingam, Cit (Rtd) & Shri B. Gopalakrishnan, Advocate Ar िाजस्व की ओर से /Revenue By : Shri G. Johnson, Addl. Cit Dr सुिवाई की तािीख / Date Of Hearing : 15/02/2022 घोषणा की तािीख/Date Of Pronouncement : 22/02/2022 आदेश / O R D E R Per Arun Khodpia, Am:

747 & 748/ASR/2013, order dated 18.03.2014) and submitted that the registration was granted on 21.06.2013 and the ld. CIT(A) decided appeal on 29.07.2019, therefore, the assessment proceedings has to be deemed as proceedings as the appellate proceedings are in 7 continuation of assessment proceedings. Therefore, first proviso to Section 12A(2) of the Act is applicable to the present case

DR.K.VANITHA,CHENNAI vs. DCIT, CHENNAI

In the result, all the appeals of the assessee is allowed and appeal of the revenue in ITA No

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeassessment Year: 2006-07

Section 153A of the Act. 6. Referring to the assessment year 2005-06, 2006-07 and 2007-08, the learned counsel for the assessee submitted that the assessment proceeding for assessment years 2005-06, 2006-07 and 2007-08 was pending on the date of search. The first addition made by the assessing officer is disallowance of Rs.84,606/- towards