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].

section 2(22)(e) of the Act. After considering the submissions of the assessee, the Assessing Officer has observed that the money advanced by the assessee to the company for subscription of shares and money received as advances from the company are completely two different transactions. Moreover, the personal loans taken by the assessee and for meeting the construction expenses

ACIT, CIRCLE-1, , TIRUPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING (P) LTD., TIRUPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This bunch of eight appeals filed by the Department as well as different assessees are directed against different orders passed by the ld. Commissioner of Income Tax (Appeals), Coimbatore-3, Coimbatore, for the assessment years 2017-18, 2018-19 and 2020-21. 3 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23

DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE-1, TIRUPPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING P LTD, TIRUPPUR,TAMILNADU

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This bunch of eight appeals filed by the Department as well as different assessees are directed against different orders passed by the ld. Commissioner of Income Tax (Appeals), Coimbatore-3, Coimbatore, for the assessment years 2017-18, 2018-19 and 2020-21. 3 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23

GEENA GARMENTS,TIRUPPUR vs. ACIT, CIRCLE-1, TIRUPPUR, TIRUPPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

E R PER S.S. VISWANETHRA RAVI, JUDICIAL MEMBER: This bunch of eight appeals filed by the Department as well as different assessees are directed against different orders passed by the ld. Commissioner of Income Tax (Appeals), Coimbatore-3, Coimbatore, for the assessment years 2017-18, 2018-19 and 2020-21. 3 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23

MRS.JOTHI NARAYANAN ,CHENNAI vs. ACIT , CHENNAI

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

House property as returned - (Rs.42,16,950) Add: Interest on borrowed capital disallowed as in para (12.1 to 12.4) - Rs.8,14,484/- Add: Deemed rental income from Thillai Ganga Nagar property (as in para 13.2) - Rs.96,000/- Add: Additional deemed rental income from Ponniamman Koil Street property (as in para 13.2) - Rs.24,000/- Add: Disallowance of deduction

MR. THANUSHKODI NARAYANAN,CHENNAI vs. ADDL. CIT CENTRAL CIRCLE 3(2), CHENNAI

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

Bench: Shri Mahavir Singh & Shri Manjunatha.G

House property as returned - (Rs.42,16,950) Add: Interest on borrowed capital disallowed as in para (12.1 to 12.4) - Rs.8,14,484/- Add: Deemed rental income from Thillai Ganga Nagar property (as in para 13.2) - Rs.96,000/- Add: Additional deemed rental income from Ponniamman Koil Street property (as in para 13.2) - Rs.24,000/- Add: Disallowance of deduction

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

22 I.T.A. Nos.1667 to 1670/Chny/24 case of Eicher Limited v. CIT 294 ITR 310 (SC) and argued that the change of opinion applies only when the Assessing Officer revisits previously assessed facts. 24. Heard both the parties and perused the material available on record. We note that the assessee filed its return of income declaring a total income at Rs.Nil

DCIT, CC2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

E R PER ABY T. VARKEY, JM: These appeals preferred by the Revenue and the cross-objections of the assessee are against the orders passed by the Learned Commissioner of Income Tax (Appeals)-19, (hereinafter referred to as ‘Ld. CIT(A)‘), Chennai, both dated 12.02.2025, for the Assessment Years (hereinafter ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

E R PER ABY T. VARKEY, JM: These appeals preferred by the Revenue and the cross-objections of the assessee are against the orders passed by the Learned Commissioner of Income Tax (Appeals)-19, (hereinafter referred to as ‘Ld. CIT(A)‘), Chennai, both dated 12.02.2025, for the Assessment Years (hereinafter ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025

POWERMATIC PACKAGING PVT. LTD.,,CHENNAI vs. ITO, CORPORATE WARD - 5 (2),, CHENNAI

The appeal stand partly allowed in terms of our above order

Bench: Shri Manoj Kumar Aggarwal & Shri Manomohan Dasआयकर अपील सं./Ita No.733/Chny/2020 िनधा)रण वष) /Assessment Year: 2016-17

e) in the hands of the shareholder. Having heard rival submissions and after perusal of case records, our adjudication would be as under. 2. The registry has noted a delay of 100 days, the condonation of which has been sought by Ld. AR. Considering the fact that the time available to prefer the appeal fall within the lockdown situation arising

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Jagadish

property held for charitable or religious purpose shall not be included in the total income of the previous year of the person in receipt of the income to be given effect in the manner as specified therein: The term 'charitable purpose' has not been defined under the statute; but for the inclusive nature of the term as specified under

M/S. INNOVATIVE MICRFINANCE FOR POVERTY ALLEVIATION & COMMUNITY TRANSFORMATION,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, the appeal of the assessee is dismissed

E) in ITA No.763/Bang/2016 dated\n16.02.2021, wherein the ITAT, Bangalore ‘B' Bench held as under; “16. Now we\nshall examine various reasons given by the AO for rejecting the claim of\nexemption u/s 11 of the Act. The first reason given is that the assessee is charging\nPage - 7 - of 26\nexorbitant interest rates on the loan given

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

housing and therefore it should be regarded as building used for business purposes. The AO following the orders passed by his predecessors held that, the depreciation rate allowable on residential buildings as per the Income-tax Rules was 5% and not 10% and that this Tribunal in assessee’s own case for AY 2006-07 had also held that

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

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

22)(e) (as Rs. 1,38,70,048/-\nin paras 14.1 to 14.13)\nAdd: Addition u/s 56(2) (vii)(c) (as in Rs. 92,95,305/-\nparas 15.1 to 15.5)\nGross Total income Rs. 2,37,25,823/-\nLess: Deduction under Chapter VIA Rs. 2,60,72,169/-\nRs. 1,00,000/-\nTotal income Rs. 2,59,72,169/-\nAssessed

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

In the result the appeal is dismissed

e-filed his R/l belatedly on 31.03.2018\nadmitting an income of Rs.14,69,64,500/-. The case was selected for\nlimited scrutiny as he had claimed large deduction/exemption from\ncapital gain. On a perusal of the R/I, it is seen that\nassessee had declared income from capital gains which is calculated as\nfollows:-\n1. Full value of consideration received

MERCY EDUCATION TRUST,CHENNAI vs. ITO, NCW-19(6), CHENNAI

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 2231/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mercy Education Trust, The Income Tax Officer, No.66, Sree Gokulam Towers, Vs. Non-Corporate Ward 19(6), Arcot Road, Chennai. Kodambakkam, Chennai – 600 024. Pan: Aactm 6190M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri N. Arjun Raj, Advocate ""यथ" क" ओर से/Respondent By : Shri N. Rajakumar, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 27.01.2026 घोषणा क" तारीख/Date Of Pronouncement : 29.01.2026

22. After having considered the judicial precedent on the issue, we are of the view that the validity of the 147 order passed by the AO can be assailed before us, even if for any reason, the assessee didn’t challenge the validity of proceedings u/s.147 of the Act by filing appeal [i.e. against the order framed u/s.147

NEURO UPDATE CHENNAI,CHENNAI vs. ITO, EXEMPTION WARD-1, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri S.R.Raghunatha

E R PER S. R. RAGHUNATHA, AM : This appeal by the assessee is filed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2016-17, dated 08.05.2025. 2. The grounds of appeal raised by the assessee are as under: - 1. The Commissioner of Income-tax (Appeals) ("CIT(A)") erred

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

22)(e) (as Rs. 1,38,70,048/-\nin paras 14.1 to 14.13)\nAdd: Addition u/s 56(2) (vii)(c) (as in Rs. 92,95,305/-\nparas 15.1 to 15.5)\nGross Total income Rs. 2,37,25,823/-\nLess: Deduction under Chapter VIA Rs. 2,60,72,169/-\nRs. 1,00,000/-\nTotal income Rs. 2,59,72,169/-\nAssessed

DEPUTY COMMISSIONER OF INCOME TAX, NON-CORPORATE CIRCLE 7(1), CHENNAI vs. VELLORE SUBRAMANIAN SARAVANAN, CHENNAI

In the result, appeal filed by the Re

Bench: Shri Aby T. Varkey & Shri Jagadish

2 years & 1 month before the sale of 1 month before the sale of long term capital asset on 31.03.2015 m capital asset on 31.03.2015). 6. Brief facts are that the assessee purchased a land on 01.02.2013 Brief facts are that the assessee purchased a land on 01.02.2013 Brief facts are that the assessee purchased a land