MOSBACHER INDIA LLC,CHENNAI vs. ADDL. DIT, CHENNAI

In the result, the appeal is partly allowed in the terms indicated above

property of any kind held by an assessee, whether or not connected with business or profession”, these participation interests are required to be treated as capital assets. Under section 45, “any profits or gains arising from the transfer of a capital asset, effected in the previous year shall, save as otherwise provided in sections 54, 54B, 54D, 54 E, 54EA

DCIT CORPORATE CIRCLE 5(1), CHENNAI vs. REPCO HOME FINANCE P LTD., CHENNAI

In the result, the appeal of Revenue in ITA no

Bench: Shri George Mathan & Shri Ramit Kochar

4) of section 80-IA ; and (iii) an undertaking referred to in sub-section (10) of section 80- IB; (h) "long-term finance" means any loan or advance where the terms under which moneys are loaned or advanced provide for repayment along with interest thereof during a period of not less than five years;” Thus, as can be seen from

M/S. CHENNAI BUSINESS TOWER PVT. LTD.,KANCHIPURAM vs. PCIT-4, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 1570/Chny/2025, धनिाारण वर्ा / Assessment Years: 2010-11 M/S. Chennai Business Tower Pcit-4, Private Limited (Formerly Known Vs Chennai. As Rmz Infinity (Chennai) Pvt. . Ltd), 110, Mount Poonamallee Road, Porur, Porur S.O. Kanchipuram – 600 116. [Pan:Aaacd-2287-R] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. B. Ramakrishnan, Fca. प्रत्यथी की ओर से/Respondent By : Shri. R. Raghupathy, Addl. Cit. सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 12.09.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

b. Active ownership of property - if the property yields rental income by virtue of its own legal existence, it would be classified as passive ownership and the rental income arising is to be taxed under the head 'Income from House Property'. c. However, if the renting out of property is being done as part of a systematic and regular business

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

housing, factory and corporate office thereby virtually preventing all from ingress and egress. In the meantime the secured creditor – Bank of Baroda, which had earlier advanced loan against the security of all the assets, including Stock-in-Trade, had moved petition before DRT (Debts Recovery Tribunal) and also under SARFAESI Act (The 4 - - ITA 1216 & 2106/13 Securitization and Reconstruction

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

housing, factory and corporate office thereby virtually preventing all from ingress and egress. In the meantime the secured creditor – Bank of Baroda, which had earlier advanced loan against the security of all the assets, including Stock-in-Trade, had moved petition before DRT (Debts Recovery Tribunal) and also under SARFAESI Act (The 4 - - ITA 1216 & 2106/13 Securitization and Reconstruction

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

120/- paid in accordance with the payment terms... 2. Schedule-B: All that place & parcel of land bearing Plot no. ….. measuring … sq.ft. of land area, along with premiere villa/deluxe villa/luxury villa/deluxe admeasuring a built up area of 2402 sq. Comprised in survey numbers... 3: ASSIGNMENT/ TRANSFER: The Lessee shell be entitled to assign/mortgage/transfer his/her/its rights under this Lease Deed

ACIT, CHENNAI vs. ESKAY DESIGNS, CHENNAI

In the result, the appeal filed by the Revenue is partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 247/Mds/2017 "नधा"रण वष"/Assessment Year:2012-13 The Assistant Commissioner Of M/S. Eskay Designs, No. 25, 1St Street, Cenotaph Road, Income Tax, Non-Corporate Circle 3, Vs. 121, Mahatma Gandhi Road, Teynampet, Chennai 600 018. Nungambakkam, Chennai 600 034. [Pan:Aaafe1480C] (Appellant) (Respondent) अपीलाथ" क" ओर से / Appellant By : Mrs. S. Vijayaprabha, Jcit ""यथ" क" ओर से/Respondent By : Shri K. Ravi, Advocate सुनवाई क" तार"ख/ Date Of Hearing : 07.02.2018 घोषणा क" तार"ख /Date Of Pronouncement : 28.02.2018 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) 4, Chennai Dated 31.10.2016 Relevant To The Assessment Year 2012-13. The First Issue Raised In The Appeal Of The Revenue Is That The Ld. Cit(A) Erred In Directing To Assess The Rental Income Received By The Assessee On Sub-Letting Of Its Leased Out Properties Under The Head “Income From House Property” & The Second Issue Is That The Ld. Cit(A) Erred In Directing To Allow The Expenses If They Are Paid As On 2

120/- from various properties, which represents lease rental income of the property. It was the submission of the assessee that the property for which rental income has been offered has been taken in lease and in turn, the same were sub-leased by the assessee to various tenants. Since the Assessing Officer considered the above as income from business

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

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

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

House property. Therefore, claim of appellant that just because AO happened to not make disallowance during previous year, same disallowance can't be made for current year does not sound reasonable. Therefore, I am of considered view that AO has correctly made disallowance of interest Rs.14,94,644/- which has no nexus with earning ITA Nos.1535 & 1801/Chny/2024

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

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

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

House property. Therefore, claim of appellant that just because AO happened to not make disallowance during previous year, same disallowance can't be made for current year does not sound reasonable. Therefore, I am of considered view that AO has correctly made disallowance of interest Rs.14,94,644/- which has no nexus with earning ITA Nos.1535 & 1801/Chny/2024

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

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.690/Chny/2020 निर्धारण वर्ष /Assessment Years: 2016-17 Ramakrishnan Prabhu Jyothi, Race Course, Coimbatore, Tamil Nadu-641018, [Pan: Adjpp4946N] Asst. Commissioner Of Income Tax, Non-Corporate Circle-5, Coimbatore. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Shri N.P.Vijay Kumar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/Date Of Hearing : 27.05.2024 घोषणा की तारीख /Date Of Pronouncement : 23.08.2024 आदेश / Order Per Amitabh Shukla, A.M : This Appeal Is Filed Against The Order Bearing Din & Order No.Itba/Apl/S/250/2029-20/1026334108(1) Dated 09.03.2020 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), For The

120 ITR 46 SC) wherein it was held that the word 'purchase' in Section 54F(1) of the Act must be given it common meaning i.e. buying for price or payment in kind or adjustment towards debt or for monetary consideration. That the issue of ownership and possession nowhere form part of the provision and concept of transfer is alien

MAHINDRA RESIDENTIAL DEVELOPERS LTD.,CHENGALPUT vs. ITO, CHENNAI

120/- paid in accordance with the payment\nterms...\nat\n2. Schedule-B: All that place & parcel of land bearing Plot no.\nmeasuring sq.ft. of land area, along with premiere villa/deluxe\nvilla/luxury villa/deluxe admeasuring a built up area of 2402 sq.\nComprised in survey numbers...\n3: ASSIGNMENT/ TRANSFER:\nThe Lessee shell be entitled to assign/mortgage/transfer his/her/its\nrights under this Lease Deed

VUMMIDI BARATH,CHENNAI vs. ITO, CHENNAI

In the result, the appeal was allowed

Bench: Shri A. Mohan Alankamony

B. Jaisheila, CA अपीलाथ"क"ओरसे/ Appellant by : Shri Supriyopal, JCIT ""यथ"क"ओरसे/Respondent by : 14.06.2017 सुनवाईक"तार"ख/Date of hearing : 17.08.2017 घोषणाक"तार"ख /Date of Pronouncement आदेश / O R D E R This appeal by the assessee is directed against the order passed by the Ld. Commissioner of Income Tax (Appeals)-2, Chennai dated

M/S. RMZ INFINITY (CHENNAI) PVT. LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.511/Chny/2025 Assessment Years: 2009-10 M/S.Rmz Infinity(Chennai) Pvt. Ltd, The Principal Commissioner Of No.110, Mount Poonamallee Road, Income Tax-4, Porur, Porur S.O, Circle-1, Ltu, Kanchipuram Dist, Chennai Tamil Nadu-600 116. [Pan: Aaacd2287R]

120; (b) ―record‖1[shall include and shall be deemed always to have included] all records relating to any proceeding under this Act available at the time of examination by the 1[Principal Commissioner or Commissioner]; (c) where any order referred to in this sub-section and passed by the Assessing Officer had been the subject matter of any appeal

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

SEVUGAN PETHAPERUMAL,MADURAI vs. PCIT, MADURAI-1,, MADURAI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1196/Chny/2025 Assessment Years: 2020-21 Sevugan Pethaperumal, Principal Commissioner Of Income No.41, First Main Street, Tax, Narayanapuram West, Madurai-1, Madurai, Madurai. Tamil Nadu-625 014. [Pan: Afjpp5984J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri G.Tarun, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख /Date Of Pronouncement : 25.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

4 - of 13 order under the said section]. 36[ 37[Explanation 1.]-For the removal of doubts 38, it is hereby declared that, for the purposes of this sub-section,- (a) an order passed 39[on or before or after the 1st day of June, 1988] by the Assessing Officer 40[or the Transfer Pricing Officer, as the case