INCOME TAX OFFICER, COIMBATORE vs. DAMAYANTI RAMACHANDRAN, GN MILLS POST, COIMBATORE

In the result, both the appeals of revenue for the A

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.103/Chny/2025, ननिाारण वर्ा/Assessment Year: 2015-16

45 of Income tax determined and given to sharing rights. Act. him, what he receives is his share in the partnership and The Memorandum of However, in case of not any consideration for Family Arrangement Ramachandran Family transfer of his interest in the impounded during the Group, the memorandum partnership to the Survey establishes that of Family Arrangement continuing partners

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

4. The appellant assessee sold a residential house property at No.137, Sundar Nagar, New Delhi on 15.1.2010 in favour of one Smt.Vanadana Manchanda, for Nagar, New Delhi on 15.1.2010 in favour of one Smt.Vanadana Manchanda, for Nagar, New Delhi on 15.1.2010 in favour of one Smt.Vanadana Manchanda, for a total consideration of Rs.12,50,00,000/ consideration of Rs.12

DCIT , COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED , ERODE

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

housing or other activities being an\nintegral part of the highway project.....\nThe issue has been examined by the Board. It has been decided that\nwidening of an existing Road by constructing additional lanes as a part\nof a highway project by an undertaking would be regarded as a new\ninfrastructure 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\ndismissed

housing or other activities being an\nintegral part of the highway project.....\nThe issue has been examined by the Board. It has been decided that\nwidening of an existing Road by constructing additional lanes as a part\nof a highway project by an undertaking would be regarded as a new\ninfrastructure facility for the purpose of section

INCOME TAX OFFICER, COIMBATORE vs. DAMAYANTI RAMACHANDRAN, GN MILLS POST, COIMBATORE

45 of Income tax\nAct.\nHowever, in case of\nRamachandran Family\nGroup, the memorandum\nof Family Arrangement\nclearly establishes that,\nthe withdrawals from\nfirm is in lieu for\nreduction of profit\nsharing rights.\nAlso, the funds\nwithdrawn are from the\ncurrent account of\npartners and not the\ncapital account.\n6.6 Therefore, the AO has contended that the assessee has withdrawn

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

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

section 54F of the Act. Since, the construction of property was not completed even as on 04.03.2016, the Assessing Officer denied deduction u/s. 54F of the Act and computed long term capital gains at Rs. 64,92,456/- and added back to the total income. :-4-: ITA. No: 422/Chny/2023 4. Being aggrieved by the assessment order, the assessee preferred

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

LATE S. YOGARATHINAM, REP. BY L/H Y. SHANMUGA DURAI,CHENNAI vs. ACIT, CIRCLE-1(2), CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.:626/Chny/2024 िनधा"रण वष"/Assessment Year:2010-11 Shri Y. Shanmuga Durai, L/H Of Acit Late S.Yogarathinam Vs. Circle -1(2) Old No.24, No.14, Chennai. 17/24, Ramanathan Street, T.Nagar, Chennai-600 017. Pan: Aakpy-9845-P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Mr. N. Arjun Raj, Advocate ""यथ"क"ओरसे/Respondent By : Mr. Ar.V. Sreenivasan, Cit सुनवाई क" तारीख/Date Of Hearing : 06.03.2025 घोषणा क" तारीख/Date Of Pronouncement : 17.03.2025

45 of the Act and further ought to have appreciated that the in absence of "transfer" within the ambit of provisions in Section 2(47) of the Act between the two individuals within the family, there could not be a scope for invoking the provisions relating to computation of capital gains on such presumed transfer of property, thereby vitiating

JUSTICE N.KANNADASAN,CHENNAI vs. ITO NON CORPORATE WARD 15(3), CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

4. The CIT(A) after considering the facts in entirety allowed the claim of exemption u/s.54F of the Act by considering that the property was sold when possession was handed over on receipt of full consideration. As regards to AO’s observation that the assessee has two houses, the AO has not considered that as on that date another property

ACIT NON CORPORATE CIRCLE 15, CHENNAI vs. JUSTICE N.KANNADASAN, CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

4. The CIT(A) after considering the facts in entirety allowed the claim of exemption u/s.54F of the Act by considering that the property was sold when possession was handed over on receipt of full consideration. As regards to AO’s observation that the assessee has two houses, the AO has not considered that as on that date another property

JUSTICE N.KANNADASAN,CHENNAI vs. ITO NON CORPORATE WARD 15(3), CHENNAI

In the result, the appeal filed by the Revenue in ITA

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

4. The CIT(A) after considering the facts in entirety allowed the claim of exemption u/s.54F of the Act by considering that the property was sold when possession was handed over on receipt of full consideration. As regards to AO’s observation that the assessee has two houses, the AO has not considered that as on that date another property

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. A S CARGO MOVERS PRIVATE LIMITED, CHENNAI

In the result, the appeal of the Revenue and assessee are decided as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1688 /Chny/2024, Assessment Years: 2015-16 आयकर अपील सं./Ita No.1796 /Chny/2024, Assessment Years: 2017-18 Assistant Commissioner Of Income A.S.Cargo Movers Private Limited, Tax, New No.173, Old No.103, 9Th Floor B Corporate Circle-1(1), Block, Navins Presidium, Chennai. Nelson Manickam Road, Aminjikarai, Chennai-600 029. [Pan: Aaaca7739D] आयकर अपील सं./Co No.56 /Chny/2024 (Ita No.1688/Chny/2024) निर्ाारण वर्ा /Assessment Year: 2015-16 A.S.Cargo Movers Private Limited, Assistant Commissioner Of Income New No.173, Old No.103, 9Th Floor B Tax, Block, Navins Presidium, Corporate Circle-1(1), Nelson Manickam Road, Chennai. Aminjikarai, Chennai-600 029. [Pan: Aaaca7739D] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri N.Quadir Hoseyn, Advocate & Dr.L.Natarajan, Ca. प्रत्यर्थी की ओर से /Revenue By : Shri K.N.Dhandapani, Cit सुिवाई की तारीख/Date Of Hearing : 04.12.2024 घोर्णा की तारीख /Date Of Pronouncement : 24.01.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

4 of his order. The Ld. AO noted that the assessee was not earning rental income from all the properties. He proceeded to premise that the assessee was entitled for allowance of interest only in respect of that property from which the rental income was offered. Consequently he withdrew interest claim of Rs.8,45,03,079/- and reworked the income