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

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

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

9,64,431 25,32,83,101 Loan E Plot Loan 19,35,14,433 19,09,930 19,54,24,363 F Repairs Loan 2,54,18,073 78,800 2,54,96,876 Total 403,06,97,480 264,22,322 405,71,19,802 A + B + C + D + E + F The learned counsel for the assessee

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

In the result, appeal of the assessee is allowed

Bench: Shri Abraham P. George]

property prior to due date under section 139(4). Contention of Revenue that deposit in Capital Gain Scheme should have been made prior to due date under section 139(1) is untenable (259 CTR 388 P&H) - Copy enclosed. (b) Investment under section 54 B can be made within the period prescribed by Section 139

ACIT COMPANY CIRCLE VI(1), CHENNAI vs. SAIPEM INDIA PROJECTS PRIVATE LIMITED, CHENNAI

In the result, the appeal filed by Revenue in ITA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा'रण वष' /Assessment Year: 2014-15

property rights inherent in and attached to the software product in favour of the licencee/customer is what is contemplated by the definition clause in the Act as well as the treaty. As observed earlier, those rights are incorporated in s.14. Merely authorizing or enabling a customer to have the benefit of data or instructions contained therein without any further right

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

M.K.JAILANI,CHENNAI vs. ITO, CHENNAI

In the result, appeal of the assessee is allowed pro-tanto

Bench: Shri Abraham P. George]

139 thirty per cent of, such sum shall be allowed as a deduction in computing the income of the previous year in which such tax has been paid. Provided further that where an assessee fails to deduct the whole or any part of the tax in accordance with the provisions of Chapter XVII-B on any such

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

139 in an account in any such bank or institution as may be specified in, and utilised in accordance with, any scheme which the Central Government may, by notification in the Official Gazette, frame in this behalf and such return shall be accompanied by proof of such deposit ; and, for the purposes of sub-section (1), the amount

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

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 property”.] The assessee has complied the provisions considering the dates as under:- (i) Date of transfer of original asset : 14.02.2005. (ii) The date of filing of return : 17.03.2006. (iii) Due date of return for the Assessment year 2005-06 : 31.07.2005. (iv) Due date of filing belated return : 31.03.2007. (v) Possession of the property : 15.12.2007. On considering the provisions

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

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

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

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].

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]. 2 I.T.A. No.2153/M/17 2. Brief facts of the case

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