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)

54 of the paper book. Further, he 15 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23 referred to order dated 15.06.2023 passed by the Amritsar Bench of ITAT in the case of ACIT v. Gravita Metal Inc. in ITA No. 594/Asr/2019 dated 15.06.2023 and argued that the Tribunal held that exemption from excise duty do not fall

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)

54 of the paper book. Further, he 15 I.T.A. Nos.3326/Chny/19, 326 & 1014/Chny/24, 706, 768,358/Chny/22 & 94 & 1348Chny/23 referred to order dated 15.06.2023 passed by the Amritsar Bench of ITAT in the case of ACIT v. Gravita Metal Inc. in ITA No. 594/Asr/2019 dated 15.06.2023 and argued that the Tribunal held that exemption from excise duty do not fall

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

ANNIRUTHA RAGHUVEER,CHENNAI vs. ITO, NCW-1(1), CHENNAI

In the result, appeal filed by the assessee is allow

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

house at Neelankarai which was built which was built for a total cost of Rs.2,00,75,384/ of Rs.2,00,75,384/-. However, the AO has denied the . However, the AO has denied the exemption claimed u/s. 54 of the Act on the ground that ass exemption claimed u/s. 54 of the Act on the ground that ass exemption

KM KNIT WEAR,TIRUPUR vs. ADIT,CPC, BANGALORE

In the result, ITA Nos. 3326/Chny/2019, 326/Chny/2024 &\n768/Chny/2022 are dismissed; ITA No

54 of the paper book. Further, he\nreferred to order dated 15.06.2023 passed by the Amritsar Bench of ITAT\nin the case of ACIT v. Gravita Metal Inc. in ITA No. 594/Asr/2019 dated\n15.06.2023 and argued that the Tribunal held that exemption from excise\nduty do not fall in the definition of income as envisaged under section\n2(24)(xviii

VICTUS DYEINGS ,TIRUPUR vs. ACIT , CIRCLE-1, TIRUPUR

54 of the paper book. Further, he\nreferred to order dated 15.06.2023 passed by the Amritsar Bench of ITAT\nin the case of ACIT v. Gravita Metal Inc in ITA No. 594/Asr/2019 dated\n15.06.2023 and argued that the Tribunal held that exemption from excise\nduty do not fall in the definition of income as envisaged under section\n2(24)(xviii

GATES WEARS,TIRUPPUR vs. DCIT CIRCLE 1, TIRUPPUR

In the result, ITA Nos. 3326/Chny/2019, 326/Chny/2024 &\n768/Chny/2022 are dismissed; ITA No

54 of the paper book. Further, he\nreferred to order dated 15.06.2023 passed by the Amritsar Bench of ITAT\nin the case of ACIT v. Gravita Metal Inc. in ITA No. 594/Asr/2019 dated\n15.06.2023 and argued that the Tribunal held that exemption from excise\nduty do not fall in the definition of income as envisaged under section\n2(24)(xviii

SAN TEX INC.,TIRUPUR vs. ACIT CIRCLE 1, TIRUPUR

54 of the paper book. Further, he\n15\nI.T.A. Nos.3326/Chny/19, 326 T 1014/Chny/24,\n706, 768,358/Chny/22 & 94 T 1348Chny/23\nreferred to order dated 15.06.2023 passed by the Amritsar Bench of ITAT\nin the case of ACIT v. Gravita Metal Inc. in ITA No. 594/Asr/2019 dated\n15.06.2023 and argued that the Tribunal held that exemption from excise\nduty do not fall

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

KIRTHISIMHAN WIJEYANAYAKE,COIMBATORE vs. ACIT NON CORPORATE CIRCLE 2, COIMBATORE

The appeal stands partly allowed in terms of our above order

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

2) Act, 2014, with effect from 01.04.2015." 10. The above-said amendment to Section 54F of the Income Tax Act, which will come into effect only from 01.04.2015, makes it very clear that the benefit of Section 54F of the Income Tax Act will be applicable to constructed, one residential house in India and that clarifies the situation

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

Property Developers. The assessee firm is also involved in the business of money lending which is carried out in the name & style of M/s Jayapriya Financiers. The assessee also operates a guest house and theatre by the name of M/s Jayapriya Guest House and M/s Jayapriya Theatre respectively. A search action u/s 132 of the Act was conducted upon

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

Property Developers. The assessee firm is also involved in the business of money lending which is carried out in the name & style of M/s Jayapriya Financiers. The assessee also operates a guest house and theatre by the name of M/s Jayapriya Guest House and M/s Jayapriya Theatre respectively. A search action u/s 132 of the Act was conducted upon

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

In the result the appeal is dismissed

2) of section 54, it is clear that the said word\nis not used in the sense of legal transfer and, therefore, the holding of a\nlegal title within a period of one year is not a condition precedent for\nattracting section 54 of the Act.\n8.\nThe CIT (Appeals) and AO failed to take note of judgment

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

In the result, the appeal of the assessee is dismissed

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

ARTHUR JAGARAJ DEVAPRAGASAM,CHENNAI vs. DCIT NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:710/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Arthur Jagaraj Devapragasam, The Deputy Commissioner Of No.C-5, Marble Arch Apartments, Vs. Income Tax, No.2 Valliammal Street, Non-Corporate Circle-8(1) Vepery, Chennai-600 007. Chennai. [Pan: Acypa-9529-J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Shri. R.Vijayaraghavan, Advocate (Virtual) ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, J.C.I.T. सुनवाई की तारीख/Date Of Hearing : 26.06.2025 घोषणा की तारीख/Date Of Pronouncement : 24.07.2025

house within a period of 3 years, the entire unutilized balance of Rs.6.45 crores was correctly offered to tax as capital gains in AY 2020-21. 7. The AO, however misconstrued the provisions of Section 54 and wrongly concluded that the purchase of the residential property did not occur within 2

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

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

NATARAJAN,CUDDALORE vs. ITO,ITWARD-1(1) , CHENNAI

The appeal of the assessee is partly allowed

Bench: Hon’Ble Shri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.123/Chny/2023 िनधा"रण वष"/Assessment Year:2011-2012 Shri Natarajan The Income Tax Officer, 353, Pudupettai Main Road, Vs. International Taxation, Indira Nagar, C. Puthupettai, Ward 2(1), Parangipettai Post, Chennai 600 006 Cuddalore 608 502. Pan: Anfpn 9506Q (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. J. Saravanan, Advocate ""यथ"क"ओरसे/Respondent By : Dr. Samuel Pitta, Irs, Jcit.

house, I remembered the closed cover and handed over the same to him. 6. That I then understood that the cover contained the order of the CIT(A)-16, Chennai, dated 28.02.2022 and that a delay in filing an appeal against the said order had occurred. 7. That I submit that only due to genuine inadvertence, I forgot to inform