M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

147 squarely applied, and the impugned notices were barred by limitation mentioned in the proviso. The revenue relied on section 153(3)(ii ) and submitted that there was no bar of limitation in view of the said provision. There was no merit in such ITA Nos.1632 to 1638/Chny/2023 :: 19 :: a plea. Section 153 relates to passing of an order

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

147, section 148, section 149, section 151 and section 153, in the\ncase of a person where a search is initiated under section 132 or books of account,\nother documents or any assets are requisitioned under section 132A after the 31st day of\nMay, 2003, the Assessing Officer shall-\n(a) issue notice to such person requiring him to furnish

DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, appeal filed by the revenue is dismissed and\ncross objection filed by the assessee is allowed

House, Chenai\nAnnexe Building,\nG.P.O., Parrys,\nNo. 121, M.G. Road,\nChennai - 600 001.\nChennai - 600 034.\n[PAN:AABCC-6633-K]\n(अपीलार्थी/Appellant)\n(Respondent/Cross Objector)\nAssessee by\n: Ms. Kamakshi, Advocate for\nMr. SandeepBagmar, Advocate\nDepartment by\n: Mr.NilayBaranSom, CIT\nसुनवाई की तारीख/Date of Hearing\n: 09.08.2024\nघोषणा की तारीख/Date of Pronouncement : 06.11.2024\nआदेश / ORDER\nPER

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

ASSISSTANT COMMISIONER OF INCOME TAX, CHENNAI vs. ESTRA ENTERPRISES PRIVATE LIMITED, CHENNAI

property is registered in the name of\nbuyer.\nc. The Joint development agreement entered into by the assesee with\nthe developer is a legal transfer agreement in respect of sale of land\nproportionate to 60% of the total built up area. As the assessee has\nrelinquished his right over the 60% share, liability to pay tax arises\nirrespective of incidence

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

house and\nresidential institutions for students both connected with the institution\".\nWe find no dispute with regard to objects of the assessee mentioned\nhereinabove from the AO, CIT(A) and Id. DR and their objection is only\nthat there was no charitable activity in the form of education during the\nyears under consideration and section 11 exemption is not available

MADANRAJ HAMIRMAL SHAH,MUMBAI vs. ITO, ERODE

In the result the appeal of the assessee is partly allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं./Ita Nos.: 1334 & 1335/Chny/2024 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Madanraj Hamirmal Shah Income Tax Officer, C-405, Royal Samrat, Ward -1(2), S.V. Road,Goregoan West, V. Erode. Mumbai – 400 062. [Pan: Adwpm-2343-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/Appellant By : Shri. P.C. Jain, Advocate & Shri. Mohit Bangani, Advocate ""थ"कीओरसे/Respondent By : Shri. P. Vijaideepan, Jcit सुनवाई की तारीख/Date Of Hearing : 11.02.2025 घोषणा की तारीख/Date Of Pronouncement : 26.03.2025

147 and issuing notice under Section 148 despite knowing the appellant’s non-resident status with an address in Mumbai as his Indian Address. 2. Reassessment Based on Borrowed Satisfaction: :-10-: ITA. Nos:1334 & 1335/Chny/2024 The AO initiated reassessment based on insufficient information and lacked valid "reasons to believe" 3. Violation of Natural Justice: The appellant was not given adequate

MADANRAJ HAMIRMAL SHAH,MUMBAI vs. ITO, ERODE

In the result the appeal of the assessee is partly allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं./Ita Nos.: 1334 & 1335/Chny/2024 िनधा"रणवष" / Assessment Years: 2011-12 & 2012-13 Madanraj Hamirmal Shah Income Tax Officer, C-405, Royal Samrat, Ward -1(2), S.V. Road,Goregoan West, V. Erode. Mumbai – 400 062. [Pan: Adwpm-2343-M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ"कीओरसे/Appellant By : Shri. P.C. Jain, Advocate & Shri. Mohit Bangani, Advocate ""थ"कीओरसे/Respondent By : Shri. P. Vijaideepan, Jcit सुनवाई की तारीख/Date Of Hearing : 11.02.2025 घोषणा की तारीख/Date Of Pronouncement : 26.03.2025

147 and issuing notice under Section 148 despite knowing the appellant’s non-resident status with an address in Mumbai as his Indian Address. 2. Reassessment Based on Borrowed Satisfaction: :-10-: ITA. Nos:1334 & 1335/Chny/2024 The AO initiated reassessment based on insufficient information and lacked valid "reasons to believe" 3. Violation of Natural Justice: The appellant was not given adequate

D. SAIVENUGOPAL,CHENNAI vs. DCIT CORPORATE CIRCLE 6(1), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.107/Chny/2021 & 2417/Chny/2019 िनधा"रण वष"/Assessment Year: 2011-12 Shri D. Saivenugopal, Vs. The Deputy Commissioner Of Old No. 5, New No. 11, Sami Chetty Income Tax, Street, Pudupet, Chennai 600 002. Corporate Circle 6(1), Chennai 34. [Pan:Betps6046G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundaram, Ca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 15.03.2023 घोषणा की तारीख /Date Of Pronouncement : 24.03.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 27.06.2022 Relevant To The Assessment Year 2011-12 Passed Against Quantum Additions As Well As Rejection Of Rectification Petition Under Section 154 Of The Income Tax Act, 1961 [“Act” In Short].

house property is only from buildings or land appurtenant thereto and not from land alone as offered by the assessee. Hence, the 30% notational deduction claimed on the rent received from 3 I.T.A. Nos.107/Chny/21 & 2417/Chny/19 land was not in order and same has escaped assessment. Accordingly, the Assessing Officer issued notice under section 148 of the Act dated

SHRI D. SAIVENUGOPAL,,CHENNAI vs. DCIT, CORPORATE CIRCLE - 6 (1),, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.107/Chny/2021 & 2417/Chny/2019 िनधा"रण वष"/Assessment Year: 2011-12 Shri D. Saivenugopal, Vs. The Deputy Commissioner Of Old No. 5, New No. 11, Sami Chetty Income Tax, Street, Pudupet, Chennai 600 002. Corporate Circle 6(1), Chennai 34. [Pan:Betps6046G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundaram, Ca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 15.03.2023 घोषणा की तारीख /Date Of Pronouncement : 24.03.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 27.06.2022 Relevant To The Assessment Year 2011-12 Passed Against Quantum Additions As Well As Rejection Of Rectification Petition Under Section 154 Of The Income Tax Act, 1961 [“Act” In Short].

house property is only from buildings or land appurtenant thereto and not from land alone as offered by the assessee. Hence, the 30% notational deduction claimed on the rent received from 3 I.T.A. Nos.107/Chny/21 & 2417/Chny/19 land was not in order and same has escaped assessment. Accordingly, the Assessing Officer issued notice under section 148 of the Act dated

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

147 r.w.s. 144B of the Act, in the facts and circumstances of the\ncase.\n22. The Id. AR Shri G. Baskar, Advocate adopted the same arguments\nadvanced in earlier assessment year 2014-15 in respect of \"change of\nopinion\". He relied on the decision of Hon'ble High Court of Gujarat in the\ncase of Bimalkumar Karshanbhai Tank

ELECTRONICS CORPORATION OF TAMILNADU LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2429 & 2430/Chny/2017 िनधा"रण वष"/Assessment Years: 2001-02 & 2003-04 M/S. Electronics Corporation Of Vs. The Deputy Commissioner Of Tamilnadu Ltd., No. 692, Mhu Income Tax, Complex, Anna Salai, Nandanam, Corporate Circle 2(1), Chennai 600 035. Chennai. [Pan:Aaace1670K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 21.02.2023 घोषणा की तारीख /Date Of Pronouncement : 28.02.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai, Dated 23.06.2017 Relevant To The Assessment Years 2001-02 & 2003-04. The Assessee Has Raised The Following Grounds For The Assessment Year 2001-02: 1. The Order Of The Commissioner Of Income Tax (Appeals) 9, Chennai Dated 23.06.2017 In I.T.A.No.19/Cit(A)-9/2009-10) For The Above Mentioned Assessment Year Is Contrary To Law, Facts & In The Circumstances Of The Case.

section 147 of the Act is valid and accordingly, ground Nos. 2 & 3 raised by the assessee are dismissed. 13. So far as merits of the case is concerned in respect of ground Nos. 4 & 5, the Assessing Officer has ascertained that the property at MHU Complex was allotted to the assessee by Tamil Nadu Housing