DURAISAMY SENTHIL KUMAR,ERODE vs. ITO, ERODE

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Vice- & Shri Manjunatha.Gआयकरअपीलसं./I.T.A.No.552/Chny/2023 ("नधा"रणवष" / Assessment Year: 2018-19) Shri Duraisamy Senthil Kumar Vs The Income Tax Officer, 16, Muthurangam Street, Erode. Erode-638 001. Pan: Alwps 8708C (अपीलाथ"/Appellant) (""यथ"/Respondent)

15,05,253/-would not attract automatically the presumption of misreporting of income, thereby vitiating the levy of penalty u/s 270A of the Act. 4. The NFAC, Delhi failed to appreciate that failed to appreciate that the presumption of mis-reporting of income on the factual matrix of the case was erroneous and ought to have appreciated that the bonafide

SMT. LINGAMMAL RAMARAJU SHASTRA PRATHISHTA TRUST,RAJAPALAYAM vs. ACIT (EXEMPTIONS), COIMBATORE

In the result, the appeal stands allowed

property held under trust\" includes a business undertaking\nso held. Therefore, profits derived from a business undertaking held under\ntrust also qualify for the exemption, subject to fulfilment of other\nconditions. Section 11(4A) thereafter stipulates two conditions for the\nclaim of exemption of business income u/s 11(1); one being that the\nbusiness is incidental to the attainment

DCIT NON CORPORATE CIRCLE 1, CHENNAI vs. MUTHU DANIEL RAJAN, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 54F, and had denied the benefit of claim of exemption U/s 54F, amounting to a value of Rs 2,60,54,377/-. 3. The appellant had purchased a residential house at Besant Nagar in the Assessment Year of 2012-13; and to meet out the costs of purchase; had sold his lands at Kunnakkadu in this Assessment Year

DCIT NON CORPORATE CIRCLE 1, CHENNAI vs. MUTHU DANIEL RAJAN, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 54F, and had denied the benefit of claim of exemption U/s 54F, amounting to a value of Rs 2,60,54,377/-. 3. The appellant had purchased a residential house at Besant Nagar in the Assessment Year of 2012-13; and to meet out the costs of purchase; had sold his lands at Kunnakkadu in this Assessment Year

MUTHU DANIEL RAJAN,CHENNAI vs. CIT CORPORATE CIRCLE 1, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 54F, and had denied the benefit of claim of exemption U/s 54F, amounting to a value of Rs 2,60,54,377/-. 3. The appellant had purchased a residential house at Besant Nagar in the Assessment Year of 2012-13; and to meet out the costs of purchase; had sold his lands at Kunnakkadu in this Assessment Year

NEURO UPDATE CHENNAI,CHENNAI vs. ITO, EXEMPTION WARD-1, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

house property interest on securities, capital gains, or other sources, the word "income" should be understood in its commercial sense. Le, book income, after adding back any appropriations or applications thereof towards the purposes of the trust or otherwise, and also after adding back any debits made for capital expenditure incurred for the purposes of the trust or otherwise”. 10

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 :

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

M/S COUNCIL FOR LEATHER EXPORTS,CHENNAI vs. DCIT, CHENNAI CIRCLECHENNAI, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 948/Chny/2023 िनधा"रणवष" / Assessment Year: 2016-17 The Deputy Commissioner Of M/S. Council For Leather V. Income Tax (Exemption), Exports, Chennai Circle, No.1, Sivaganga Road, Chennai-34. Nungambakkam, Chennai – 600 034. [Pan: Aaacc-4697-G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. R. Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. Krishnan Ramaswamy, Jcit सुनवाई क" तारीख/Date Of Hearing : 30.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 07.08.2024 आदेश /O R D E R

15) of section 2 become applicable in the case of such person in the said previous year". 8.4. Since, sec.11 will not operate in the assessee's case, the taxable income of the assessee is determined in a commercial sense, as envisaged by Board's Circular No.5P dated 19.6.1968. For better clarity, the relevant part of the Circular

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

House Property Home Equity Loan\n-22.02.379 -19,47,366\nWith regard to the seventh issue of addition made u/s.56(2)(vii)(c) of the Act, the Special audit report had observed as follows for the A.Y. 2012-13:\nMrs. Thanushkodi Narayanan\nSpecial Audit u/s 142(2A) of the Income Tax Act 1961 - AY 2012-13\nAnnexure-4: Deemed Dividend

RAMAKRISHNAN PRABHU JYOTHI,,COIMBATORE vs. ACOT, NCC-5, , COIMBATORE

In the result the appeal is dismissed

10 -:\nITA No.690/Chny/2020\nJeypore Sugar Mills Ltd fraudulently sold the lend and that there was no\nsale deed executed in favour of assesse has been held wrongly against\nthe assesse by CIT Appeals and AO which is baseless to conclude that\nthe assesse did not purchase the residential property when assesse has\npaid the entire purchase consideration and the assesse

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

10 accumulation\nsupporting charitable status is immaterial. She argued that the exemption\nunder section 11 of the Act is assessed based on current year activities\nbut not past or future intention as held by the Hon'ble Supreme Court in\nthe case of Baba Banda Singh Bahadur Education Trust reported in\n[2023] 150 Taxmann.com

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

10 accumulation supporting charitable status is immaterial. She argued that the exemption under section 11 of the Act is assessed based on current year activities but not past or future intention as held by the Hon’ble Supreme Court in the case of Baba Banda Singh Bahadur Education Trust reported in [2023] 150 Taxmann.com

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

House Property Home Equity Loan\n-22.02.379\n-19,47,366\nAHMAYYA & Cr\n* CHENNAI * 2 INDIA 5 MARTERED ACCOUN\nWith regard to the seventh issue of addition made u/s.56(2)(vii)(c) of the Act, the\nSpecial audit report had observed as follows for the A.Y. 2012-13:\nMrs. Thanushkodi Narayanan\nSpecial Audit u/s 142(2A) of the Income

M.CT.M.CHIDAMBARAM CHETTIAR FOUNDATION,CHENNAI vs. DCIT (EXEMPTIONS) I, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

houses and it was let-out, beyond school hours for educational purposes and promotion of fine-arts, etc., in order to augment the income to be used for educational purposes. 3. He erred in holding that letting-out of auditorium is service in the nature of trade, commerce or business. 4.The decisions relied upon the CIT(A) are distinguishable

M.CT.M.CHIDAMBARAM CHETTIAR FOUNDATION,CHENNAI vs. DCIT (EXEMPTIONS) I, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

houses and it was let-out, beyond school hours for educational purposes and promotion of fine-arts, etc., in order to augment the income to be used for educational purposes. 3. He erred in holding that letting-out of auditorium is service in the nature of trade, commerce or business. 4.The decisions relied upon the CIT(A) are distinguishable

M.CT.M.CHIDAMBARAM CHETTIAR FOUNDATION,CHENNAI vs. DCIT (EXEMPTIONS) I, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

houses and it was let-out, beyond school hours for educational purposes and promotion of fine-arts, etc., in order to augment the income to be used for educational purposes. 3. He erred in holding that letting-out of auditorium is service in the nature of trade, commerce or business. 4.The decisions relied upon the CIT(A) are distinguishable

M.CT.M.CHIDAMBARAM CHETTIAR FOUNDATION,CHENNAI vs. DCIT (EXEMPTIONS) I, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

houses and it was let-out, beyond school hours for educational purposes and promotion of fine-arts, etc., in order to augment the income to be used for educational purposes. 3. He erred in holding that letting-out of auditorium is service in the nature of trade, commerce or business. 4.The decisions relied upon the CIT(A) are distinguishable

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

10 accumulation\nsupporting charitable status is immaterial. She argued that the exemption\nunder section 11 of the Act is assessed based on current year activities\nbut not past or future intention as held by the Hon'ble Supreme Court in\nthe case of Baba Banda Singh Bahadur Education Trust reported in\n[2023] 150 Taxmann.com