THAJUNNISSA BEGUM ,CHENNAI vs. ITO,NON CORPORATE WARD -10(4), CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 196/Chny/2022 िनधा"रण वष" / Assessment Year: 2013-14 Mrs. Thajunnissa Begum, Income Tax Officer, No. 3, Prasanna Vinayagar V. Non Corporate Ward -10(4), Kovil St., Chennai. 235, Poonamalle High Road, Chennai – 600 029. [Pan: Adcpt-2186-K] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Y. Sridhar, Fca ""यथ" क" 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

5. The assessee has raised the following grounds of appeal: “The order of the Commissioner of Income tax (Appeals)-12 Chennai dated 30/9/2019 is objected to on the following grounds of appeal Exemption under section 54/54F 1.The learned Commissioner (Appeals) erred in granting exemption under section 54 only in respect of one flat in the single building accommodating 13 self

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

Bench: This Tribunal.

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

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

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

ITO, CHENNAI vs. S. LAKSHMANAN, CHENNAI

In the result, Department appeal is dismissed

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojariआयकर अपील सं./Ita No.2103/Mds/2013 "नधा"रण वष" / Assessment Year : 2010-11 Shri S. Lakshmanan, The Income Tax Officer, 99-46, C-3, Ashok Amoga Business Ward Iv(1), V. Apartments, 1St Main Road, Gandhi Nagar, Chennai - 600 034. Adyar, Chennai - 600 020. Pan : Aaupl 4308 C (अपीलाथ"/Appellant) (""यथ"/Respondent)

house property. The Revenue has raised the grounds before us that the CIT(Appeals) has erred in directing the Assessing Officer to 8 I.T.A. No.2103/Mds/13 allow exemption to the assessee under Section 54 or alternative claim under Section 54F of the Act. The property was sold on 03.07.2009. Even though it is vacant land, without prejudice to the rights

K.K.SRINIVASAN,SALEM vs. ITO, SALEM

In the result, appeal of the assessee is allowed

Bench: Shri Abraham P. George]

139 provides for extension in period of due date in certain circumstances. It reads as under : "(4) Any person who has not furnished a return within the time allowed to him under sub-section (1), or within the time allowed under a notice issued under sub-section (1) of section 142, may furnish the return for any previous year

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

5. The first effective issue agitated by Revenue before the Bench in its appeal filed with Tribunal vide ground number 2.1 to 2.6 is with respect to disallowance by AO of expenditure incurred in relation to earning of an exempt income by invoking provisions of Section 14A of the 1961 Act read with Rule 8D(2)(iii) of the Income

JAGDISH RAJESH,CHENNAI vs. ITO, NCW-20(3), CHENNAI

In the result, all the appeal filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunatha

Section 54F of the Act, but if such consideration is used for purchase / construction of new asset on or before due date 4 I.T.A. No.3258/Chny/2018 u/s.139(4) or 139(5) of the Act, then deduction cannot be denied. In this regard, relied upon the decision of Hon’ble Punjab & Haryana High Court in the case of CIT vs. Jagriti Aggarwal

N RAMASWAMY,CHENNAI vs. ITO, NON CORP WARD 2(3), CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita No.925/Chny/2019 "नधा"रण वष" / Assessment Year : 2014-15

5 I.T.A. No.925/Chny/19 expenditure incurred wholly and exclusively in connection with such transfer. (2) Where the assessee purchases, within the period of two years after the date of the transfer of the original asset, or constructs, within the period of three years after such date, any residential house, the income from which is chargeable under the head “Income from house

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order 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 Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

properties, to impart any other system i.e. education training to encourage sportsmanship and adventurous spirit to make pecuniary grants by way of scholarships, to make available and provide free of costs or at concessional rates audio visual equipment, scientific and engineering equipment, scientific laboratory equipment, stores, spares and all other teaching aids and accessories to students, scholars, teachers and others

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

house and residential institutions for students both connected with the institution”. We find no dispute with regard to objects of the assessee mentioned hereinabove from the AO, CIT(A) and ld. DR and their objection is only that there was no charitable activity in the form of education during the years under consideration and section 11 exemption is not available

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

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

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

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

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

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

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

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

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

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

House Property by following the procedure laid down under the Act at para 6.4.6., had confirmed the addition of Rs.1,38,70,048/- made as deemed dividend u/s.2(22)(e) of the Act at para 6.5.3 and confirmed the addition of Rs.92,95,305/- made u/s.56(2)(viii)(c) of the Act at para 6.6.5 of the impugned order

KALPANA SUNDAR,CHENNAI vs. ITO, NON CORPORATE WARD-8(1), CHENNAI

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.2153/Mds/2017 "नधा"रण वष"/Assessment Year:2013-14 Smt. Kalpana Sundar, The Income Tax Officer, No. 4/3, Sri Janakas, 2Nd Cross Vs. Non-Corporate Ward 8(1), Street, East Kamakodi Nagar, Chennai. Valasaravakkam, Chennai 600 087. [Pan:Cnvps4092J] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri Ar. V. Sreenivasan, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 22.01.2018 घोषणा क" तार"ख /Date Of Pronouncement : 31.01.2018 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) 9, Chennai Dated 28.07.2017 Relevant To The Assessment Year 2013-14. The Only Effective Ground Raised In The Appeal Of The Assessee Is That The Ld. Cit(A) Erred In Confirming The Disallowance Of The Claim Of Tax Exemption Under Section 54 Of The Income Tax Act, 1961 [“Act” In Short].

5 I.T.A. No.2153/M/17 of the property since the construction agreement was entered into with assessee’s adult daughter. 6.1 It is an admitted fact that the assessee made entire investment within the period stipulated under section 139(4) of the Act. Since the assessee has paid ₹.44,88,986/- upto the date of filing of the return under section 139

ITO, NON CORPORATE WARD -15(3), CHENNAI vs. SHRI RAMACHANDRA RAMAN, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the Cross Objection filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.124/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 & C.O. No. 58/Chny/2018 [In I.T.A. No.124/Chny/2018] The Income Tax Officer, Vs. Shri Ramachandra Raman, Non Corporate Ward 15(3), 21B, Deccan Parvathy, 2Nd Floor, Room No. 206, Wanaparthy Kannappa Nagar Extension, Block, 121, M.G. Road, Thiruvanmiyur, Chennai 41. Chennai – 600 034. [Pan: Aehpr6467D] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) Department By : Shri Sajit Kumar, Jcit Assessee By : Shri T. Banusekar, C.A. सुनवाई की तारीख/ Date Of Hearing : 17.05.2022 घोषणा की तारीख /Date Of Pronouncement : 08.06.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Revenue & The Cross Objection Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 28.09.2017 Relevant To The Assessment Year 2009-10. 2. The Cross Objection Filed By The Assessee Is In Respect Of Reopening Of Assessment Under Section 147 Of The Income Tax Act

house property at Shanti Avenue is the ancestral property of Mr. N. Sivakumar. The deduction claimed under section 54F was duly verified and checked whether all conditions as mentioned in the Act were complied with by the assessee. The claim of deduction under section S4F is restricted to Rs.45,58,932 because of the reason mentioned in Para

DEEP DAVID,CHENNAI vs. ITO INTERNATIONAL TAXATION 1(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 791/Chny/2019 िनधा"रण वष"/Assessment Years:2013-14 Shri Deep David, The Income Tax Officer, C/O R. Bupathy & Co., “Vibgyor” Vs. International Taxation 1(1), No. 139, 1St Floor, Kodambakkam Chennai 600 034. High Road, Chennai 600 034. [Pan:Borpd3357R] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 792/Chny/2019 िनधा"रण वष"/Assessment Years:2013-14 Shri Roshan David, The Income Tax Officer, C/O R. Bupathy & Co., “Vibgyor” International Taxation 1(1), Vs. No. 139, 1St Floor, Kodambakkam Chennai 600 034. High Road, Chennai 600 034. [Pan:Borpd3355P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 29.07.2021 घोषणा की तारीख /Date Of Pronouncement : 17.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By Different Assessees Are Directed Against Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, Dated 14.02.2019 Relevant To The Assessment Year 2013-14. Since

139, 1st Floor, Kodambakkam Chennai 600 034. High Road, Chennai 600 034. [PAN:BORPD3355P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent by : Shri G. Johnson, Addl. CIT सुनवाई की तारीख/ Date of hearing : 29.07.2021 घोषणा की तारीख /Date of Pronouncement : 17.09.2021 आदेश

ROSHAN DAVID,CHENNAI vs. ITO INTERNATIONAL TAXATION 1(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 791/Chny/2019 िनधा"रण वष"/Assessment Years:2013-14 Shri Deep David, The Income Tax Officer, C/O R. Bupathy & Co., “Vibgyor” Vs. International Taxation 1(1), No. 139, 1St Floor, Kodambakkam Chennai 600 034. High Road, Chennai 600 034. [Pan:Borpd3357R] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 792/Chny/2019 िनधा"रण वष"/Assessment Years:2013-14 Shri Roshan David, The Income Tax Officer, C/O R. Bupathy & Co., “Vibgyor” International Taxation 1(1), Vs. No. 139, 1St Floor, Kodambakkam Chennai 600 034. High Road, Chennai 600 034. [Pan:Borpd3355P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 29.07.2021 घोषणा की तारीख /Date Of Pronouncement : 17.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By Different Assessees Are Directed Against Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, Dated 14.02.2019 Relevant To The Assessment Year 2013-14. Since

139, 1st Floor, Kodambakkam Chennai 600 034. High Road, Chennai 600 034. [PAN:BORPD3355P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent by : Shri G. Johnson, Addl. CIT सुनवाई की तारीख/ Date of hearing : 29.07.2021 घोषणा की तारीख /Date of Pronouncement : 17.09.2021 आदेश

C.ARYAMA SUNDARAM,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

house and the total cost of construction worked out to Rs. 2,77,39,045/-. Where, the Ld. AR arguments that land purchased on 14.05.2007 should be part of exemption allowed u/s. 54 of the Act. The Ld. AO is of the opinion that the entire capital gain was not invested in the property before due date u/s. 139