TNCD LLP.,COIMBATORE vs. ITO, NCW-1(1), CHENNAI

In the result, the quantum appeal of the assessee in ITA

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:2602 & 2603/Chny/2025 िनधा#रण वष# / Assessment Year: 2018-19 Tncd Llp, Ito, 126, Kg House, Vs. Non Corporate Ward -1(1), Arts College Road, Coimbatore. Coimbatore – 641 018. [Pan:Aagft-8799-R] (अपीलाथ%/Appellant) (&'थ%/Respondent) अपीलाथ% की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate &'थ% की ओर से/Respondent By : Ms. R. Anitha, Addl.C.I.T. सुनवाई की तारीख/Date Of Hearing : 20.11.2025 घोषणा की तारीख/Date Of Pronouncement : 11.02.2026 आदेश /O R D E R

house property attracting the provisions of section 23(1) of the Act, after providing standard deduction at 30%. Furthermore, the AO proposed to disallow the certain payments / contributions of Provident Fund/ESI received from employee which were deposited by the assessee beyond the due date of making payment to such relevant funds within the meaning of section 36(1)(va

TNCP LLP.,COIMBATORE vs. ITO, NCW-1(1), COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:2602 & 2603/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Tncd Llp, 126, Kg House, Arts College Road, Coimbatore - 641 018. [Pan:Aagft-8799-R] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By Ito, Vs. Non Corporate Ward -1(1), Coimbatore. (प्रत्यर्थी/Respondent) : Shri. N. Arjun Raj, Advocate : Ms. R. Anitha, Addl.C.I.Τ. सुनवाई की तारीख/Date Of Hearing घोषण की तारीख/Date Of Pronouncement Per S. R. Raghunatha, Am: आदेश /Order : 20.11.2025 : 11.02.2026 These Appeals Of The Assessee Are Filed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘Ld.Cit(A)') For The Assessment Year 2018-19, Both Dated 09.07.2025 Against The Assessment Orders Passed By The Ao, Nfac, Delhi, U/S.143 (3) R.W.S 144B Of The Income Tax Act, 1961 (In Short ‘The Act') Dated 20.09.2021 & The Penalty Order Passed By The Ao, Nfac, Delhi, U/S.270A Of The Act Dated 15.01.2022 Respectively. :-2-:

house property attracting the provisions of section 23(1) of the Act, after providing standard deduction at 30%. Furthermore, the AO proposed to disallow the certain payments / contributions of Provident Fund/ESI received from employee which were deposited by the assessee beyond the due date of making payment to such relevant funds within the meaning of section 36(1)(va

HARITA FEHRER LTD.,,CHENNAI vs. DCIT, CC - 2 (2),, CHENNAI

Appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2254/Chny/2018 (िनधाBरण वषB / Assessment Year: 2011-12) & आयकरअपील सं./ Ita No.3480/Chny/2018 (िनधाBरण वषB / Assessment Year: 2013-14) & आयकरअपील सं./ Ita No.3481/Chny/2018 (िनधाBरण वषB / Assessment Year: 2014-15) & आयकरअपील सं./ Ita No.2746/Chny/2019 (िनधाBरण वषB / Assessment Year: 2016-17) M/S. Harita Fehrer Limited Dcit-Corporate Circle-2(2) / बनाम/ No.29, Jayalakshmi Estates, Acit, Salary Circle-Ii Vs. Haddows Road, Chennai-600 006. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacch-1037-R (अपीलाथ"/Appellant) : ( !थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Pradeep Dinodia, (Fca), Shri Ravikumar, (Ca) & Shri Anil Kumar, (Ca) - Ld. Ars !थ"कीओरसे/Respondent By : Shri Ar.V. Sreenivasan (Add.Cit)-Ld. Dr

36(1)(vii) of the Income tax Act, by following the decision of Hon' ble Supreme Court in the case of TRF Ltd Vs CIT (323 ITR 397).” 3. As is evident, the issues that fall for our consideration in this year are – (i) Depreciation on non-complete Fees; (ii) Applicable Rate of depreciation on computer software; (iii) Claim

HARITA FEHRER LIMITED,CHENNAI vs. ACIT SALARY CIRCLE II , CHENNAI

Appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2254/Chny/2018 (िनधाBरण वषB / Assessment Year: 2011-12) & आयकरअपील सं./ Ita No.3480/Chny/2018 (िनधाBरण वषB / Assessment Year: 2013-14) & आयकरअपील सं./ Ita No.3481/Chny/2018 (िनधाBरण वषB / Assessment Year: 2014-15) & आयकरअपील सं./ Ita No.2746/Chny/2019 (िनधाBरण वषB / Assessment Year: 2016-17) M/S. Harita Fehrer Limited Dcit-Corporate Circle-2(2) / बनाम/ No.29, Jayalakshmi Estates, Acit, Salary Circle-Ii Vs. Haddows Road, Chennai-600 006. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacch-1037-R (अपीलाथ"/Appellant) : ( !थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Pradeep Dinodia, (Fca), Shri Ravikumar, (Ca) & Shri Anil Kumar, (Ca) - Ld. Ars !थ"कीओरसे/Respondent By : Shri Ar.V. Sreenivasan (Add.Cit)-Ld. Dr

36(1)(vii) of the Income tax Act, by following the decision of Hon' ble Supreme Court in the case of TRF Ltd Vs CIT (323 ITR 397).” 3. As is evident, the issues that fall for our consideration in this year are – (i) Depreciation on non-complete Fees; (ii) Applicable Rate of depreciation on computer software; (iii) Claim

HARITA FAHRER LTD,CHENNAI vs. DCIT, CORP CIR-2(2), CHENNAI

Appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2254/Chny/2018 (िनधाBरण वषB / Assessment Year: 2011-12) & आयकरअपील सं./ Ita No.3480/Chny/2018 (िनधाBरण वषB / Assessment Year: 2013-14) & आयकरअपील सं./ Ita No.3481/Chny/2018 (िनधाBरण वषB / Assessment Year: 2014-15) & आयकरअपील सं./ Ita No.2746/Chny/2019 (िनधाBरण वषB / Assessment Year: 2016-17) M/S. Harita Fehrer Limited Dcit-Corporate Circle-2(2) / बनाम/ No.29, Jayalakshmi Estates, Acit, Salary Circle-Ii Vs. Haddows Road, Chennai-600 006. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacch-1037-R (अपीलाथ"/Appellant) : ( !थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Pradeep Dinodia, (Fca), Shri Ravikumar, (Ca) & Shri Anil Kumar, (Ca) - Ld. Ars !थ"कीओरसे/Respondent By : Shri Ar.V. Sreenivasan (Add.Cit)-Ld. Dr

36(1)(vii) of the Income tax Act, by following the decision of Hon' ble Supreme Court in the case of TRF Ltd Vs CIT (323 ITR 397).” 3. As is evident, the issues that fall for our consideration in this year are – (i) Depreciation on non-complete Fees; (ii) Applicable Rate of depreciation on computer software; (iii) Claim

HARITA FAHRER LTD,CHENNAI vs. DCIT, CORP CIR-2(2), CHENNAI

Appeals stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.2254/Chny/2018 (िनधाBरण वषB / Assessment Year: 2011-12) & आयकरअपील सं./ Ita No.3480/Chny/2018 (िनधाBरण वषB / Assessment Year: 2013-14) & आयकरअपील सं./ Ita No.3481/Chny/2018 (िनधाBरण वषB / Assessment Year: 2014-15) & आयकरअपील सं./ Ita No.2746/Chny/2019 (िनधाBरण वषB / Assessment Year: 2016-17) M/S. Harita Fehrer Limited Dcit-Corporate Circle-2(2) / बनाम/ No.29, Jayalakshmi Estates, Acit, Salary Circle-Ii Vs. Haddows Road, Chennai-600 006. Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aacch-1037-R (अपीलाथ"/Appellant) : ( !थ" / Respondent) अपीलाथ" की ओर से/ Appellant By : Shri Pradeep Dinodia, (Fca), Shri Ravikumar, (Ca) & Shri Anil Kumar, (Ca) - Ld. Ars !थ"कीओरसे/Respondent By : Shri Ar.V. Sreenivasan (Add.Cit)-Ld. Dr

36(1)(vii) of the Income tax Act, by following the decision of Hon' ble Supreme Court in the case of TRF Ltd Vs CIT (323 ITR 397).” 3. As is evident, the issues that fall for our consideration in this year are – (i) Depreciation on non-complete Fees; (ii) Applicable Rate of depreciation on computer software; (iii) Claim

DCIT CORPORATE CIRCLE 2 (2), CHENNAI vs. ISS SDB SECURITY SERVICES PRIVATE LIMITED, CHENNAI

The appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

House, 7th Avenue, Corporate Circle-2(2), / Vs. Chennai. Harrington Road, Chetpet, Chennai-600 031. "थायी लेखा सं./जीआइ आर सं./PAN/GIR No. AAACT-3628-C (अपीलाथ"/Appellant) : (""थ" / Respondent) & आयकर अपील सं./ ITA No. 3536/Chny/2018 (िनधाDरण वषD / Assessment Year: 2014-15) JCIT(OSD) M/s. ISS SDB Security Services Pvt. Ltd., बनाम Bascon Futura, 5th Floor, Corporate Circle

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. ISS SDB SECURITY SERVICES PVT. LIMITED, CHENNAI

The appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

House, 7th Avenue, Corporate Circle-2(2), / Vs. Chennai. Harrington Road, Chetpet, Chennai-600 031. "थायी लेखा सं./जीआइ आर सं./PAN/GIR No. AAACT-3628-C (अपीलाथ"/Appellant) : (""थ" / Respondent) & आयकर अपील सं./ ITA No. 3536/Chny/2018 (िनधाDरण वषD / Assessment Year: 2014-15) JCIT(OSD) M/s. ISS SDB Security Services Pvt. Ltd., बनाम Bascon Futura, 5th Floor, Corporate Circle

HARIDOSS GNANAPRAKASAM,CHENNAI vs. ITO, NON CORPORATE CIRCLE-22(1), TAMBARAM

In the result, the appeal of the assessee is allowed for statistical purposes

Bench: Shri Ss Viswanethra Ravi & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2263/Chny/2025 िनधा#रण वष# /Assessment Year: 2018-19

property has resulted in a loss of Rs. 2,00,000/-. Housing Loan interest certificate (Annexure 6) is available on record issued by the GIC Housing Finance Ltd. 8. The disallowance on account of donation expenses amounting to Rs. 89,926/-, Sir, this is the expenditure in the nature of Ayudha Pooja Expenses but the AO has treated this

P.S.SHEKAR,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddyआयकरअपीलसं./I.T.A.No.1050/Mds/2016 ("नधा"रणवष" / Assessment Year: 2011-12)

house property, income from other sources and capital gains filed his return of income for the assessment year 2011-12 on 30.07.2011 admitting income of Rs.2,85,95,470/-. Thereafter the case was taken up for scrutiny and the assessment was completed on 28.03.2014, wherein the Ld.AO treated the long term capital gain of Rs.1

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, COIMBATORE vs. M/S. RP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

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

housing or other activities being an integral part of the highway project..... The issue has been examined by the Board. It has been decided that widening of an existing Road by constructing additional lanes as a part of a highway project by an undertaking would be regarded as a new infrastructure facility for the purpose of section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

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

housing or other activities being an integral part of the highway project..... The issue has been examined by the Board. It has been decided that widening of an existing Road by constructing additional lanes as a part of a highway project by an undertaking would be regarded as a new infrastructure facility for the purpose of section

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

house property as also that the AO has not verify as to whether conditions as prescribed u/s 54F were fulfilled by the assessee or not. Thus, learned CIT vide revisionary order dated 22.01.2010 passed u/s.263 of the 1961 Act held that assessment order dated 31.12.2008 passed by AO as erroneous so far as prejudicial to the interest of Revenue

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

house property as also that the AO has not verify as to whether conditions as prescribed u/s 54F were fulfilled by the assessee or not. Thus, learned CIT vide revisionary order dated 22.01.2010 passed u/s.263 of the 1961 Act held that assessment order dated 31.12.2008 passed by AO as erroneous so far as prejudicial to the interest of Revenue

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

house property as also that the AO has not verify as to whether conditions as prescribed u/s 54F were fulfilled by the assessee or not. Thus, learned CIT vide revisionary order dated 22.01.2010 passed u/s.263 of the 1961 Act held that assessment order dated 31.12.2008 passed by AO as erroneous so far as prejudicial to the interest of Revenue

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

house property as also that the AO has not verify as to whether conditions as prescribed u/s 54F were fulfilled by the assessee or not. Thus, learned CIT vide revisionary order dated 22.01.2010 passed u/s.263 of the 1961 Act held that assessment order dated 31.12.2008 passed by AO as erroneous so far as prejudicial to the interest of Revenue

DCIT, CHENNAI vs. PVP VENTURES LTD., CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

36 and subsequently, these grounds were revised and have taken the following grounds:- 2.1 The Ld. CIT(A) erred in deleting the treatment of royalty of Rs.2 Lakh as ‘income from other sources’. 2.2 The Ld. CIT(A) erred in holding that royalties are taxable under the head of Income from Business or Profession. By virtue of section

DCIT, CHENNAI vs. PVP VENTURES LTD., CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

36 and subsequently, these grounds were revised and have taken the following grounds:- 2.1 The Ld. CIT(A) erred in deleting the treatment of royalty of Rs.2 Lakh as ‘income from other sources’. 2.2 The Ld. CIT(A) erred in holding that royalties are taxable under the head of Income from Business or Profession. By virtue of section