DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

Housing v. CIT [2013] 357 ITR 698/38\ntaxmann.com 203 held that where after a search was conducted, the\nassessee filed the return of his income and the Department had accepted\nsuch return, then levy of penalty under Section 271(1)(c) was not justified.\nFrom the above cases it would be clear that when an assessee has filed\nrevised returns

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

Housing v. CIT [2013] 357 ITR 698/38\ntaxmann.com 203 held that where after a search was conducted, the\nassessee filed the return of his income and the Department had accepted\nsuch return, then levy of penalty under Section 271(1)(c) was not justified.\nFrom the above cases it would be clear that when an assessee has filed\nrevised returns

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

Housing v. CIT [2013] 357 ITR 698/38\ntaxmann.com 203 held that where after a search was conducted, the\nassessee filed the return of his income and the Department had accepted\nsuch return, then levy of penalty under Section 271(1)(c) was not justified.\nFrom the above cases it would be clear that when an assessee has filed\nrevised returns

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

Housing v. CIT [2013] 357 ITR 698/38\ntaxmann.com 203 held that where after a search was conducted, the\nassessee filed the return of his income and the Department had accepted\nsuch return, then levy of penalty under Section 271(1)(c) was not justified.\nFrom the above cases it would be clear that when an assessee has filed\nrevised returns

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

9. The Ld. Counsel for the assessee, submitted that the Ld. CIT(A) failed to appreciate fact that the assessee has claimed exemption u/s. 54 of the Act, but not u/s. 54F of the Act, because what was transferred by the assessee is a residential house property. He further submitted that, up to assessment year 2014-15, there

JANET CHRISTINE DEPENNING,CHENNAI vs. ITO, INTERNATIONAL TAXATION WARD-1(1),, CHENNAI

In the result, the appeal of the Revenue is allowed for statistical purpose

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1319, 1320, 1321, 1322 & 1323/Chny/2024 िनधा<रण वष< /Assessment Years:2014-15, 2015-16, 2016-17, 2017-18 & 2020-21 Janet Christine Depenning, The Income Tax Officer, 120, Velachery Main Road, Vs. International Taxation Ward-1(1), Guindy,Chennai – 600 032. Chennai. [Pan: Aebpd 2408L]

property service, which requires patents and trade mark to be registered in various countries. The assessee has engaged foreign associate and paid them without deducting the tax u/s 195 of the Act. The assessee has argued that the foreign associates are predominantly individuals and in some cases are body corporate and these services rendered are either professional services or business

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

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

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

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

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:

house property. He held the view that the issue required a detailed examination. Similarly on the issue of treatment of declared short time capital gains as long term capital gains he has held that such a claim could have been allowed only after due examination of the agreement of the sale, corresponding purchase agreement, period of holding etc and which

ZANNATHU FIRDOUSE,CHENNAI vs. ITO, INTNL. TAXN WARD-2(2), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manjunatha. G, Hon’Ble & Shri Manomohan Das, Hon’Bleआयकर अपील सं./Ita No.: 422/Chny/2023 िनधा"रण वष" / Assessment Year: 2012-13 Zannathul Firdouse, The Income Tax Officer, Flat C-104, Raheja Regency, V. International Taxation Ward - 147, Santhome High Road, 2(2), R A Puram, Chennai. Chennai – 600 028. [Pan: Aadpz-6639-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. B. Ramakrishna, Fca : Shri. D. Hema Bhupal, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 28.08.2023 घोषणा क" तारीख/Date Of Pronouncement : 31.08.2023 आदेश /O R D E R

139(1) of the Act and thus, she need not to keep sale consideration in capital gains deposit account scheme as per the provisions of section 54F(4) of the Act. Since, the :-10-: ITA. No: 422/Chny/2023 appellant has satisfied all conditions prescribed for claiming deduction u/s. 54F of the Act, in our considered view, the ld. CIT(A) ought

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

RANJIT V SRIVATSAA,CHENNAI vs. ITO, NCW-3(2), CHENNAI

In the result the appeal of the assessee is allowed

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

9. The ld.AR for the assessee assailing the action of the ld.CIT(A), submitted that the ld.CIT(A) has erred in understanding the provisions of section 54 of the Act and confirmed the action of the AO. The ld.AR submitted a paper book containing 72 pages consisting of copy of agreement for construction of new flat, copy of sale deed

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

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

ARTHUR JAGARAJ DEVAPRAGASAM,CHENNAI vs. DCIT NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:710/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Arthur Jagaraj Devapragasam, The Deputy Commissioner Of No.C-5, Marble Arch Apartments, Vs. Income Tax, No.2 Valliammal Street, Non-Corporate Circle-8(1) Vepery, Chennai-600 007. Chennai. [Pan: Acypa-9529-J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. R.Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, J.C.I.T. सुनवाई की तारीख/Date Of Hearing : 26.06.2025 घोषणा की तारीख/Date Of Pronouncement : 24.07.2025

9. The ld. AR for the assessee submitted that both the AO and ld.CIT(A) have incorrectly interpreted the provisions of section 54(2) of the Act and its proviso. He argued that their conclusion that the failure to purchase a residential property within 2 years or to construct within 3 years automatically renders the entire net sale consideration