SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

House, I floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [PAN AAGTS 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Shri. R. Sivaraman, Advocate ""यथ" क" ओर से /Respondent by : Shri. Shaji P. Jacob, IRS, Addl. CIT. : 22-06-2017 सुनवाई क" तार"ख/Date of Hearing घोषणा

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

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

ASIRVAD MICRO FINANCE LIMITED,ANNA SALAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1140/Chny/2025 Assessment Years: 2016-17 Asirvad Micro Finance Limited, Assistant Commissioner Of No.9, 9Th Floor, Club House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [Pan: Aagca5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.P.R.Prasanna Varma, Fca & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 25.09.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [PAN: AAGCA5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee by : Mr.P.R.Prasanna Varma, FCA & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue by : Mr.Bipin C.N, CIT सुनवाई की तारीख/Date of Hearing : 25.09.2025 घोषणा की तारीख /Date of Pronouncement : 05.12.2025 आदेश

V S TRUST,CHENNAI vs. ITO, NCW-3(5), CHENNAI

In the result, the appeal of the assessee is allowed

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

Section 56(2)(vii); that such receipt of property by the trust will not be taxable u/s 56(2)(x) of the Act. Having taken note of this position of law, we now revert back to the facts of the present case. It is not in dispute that, the settler contributing the property is an individual and that the assessee

SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

2 ITA 1172-1273-1173-1283/Chny/2025 SPL Shelters Pvt. Ltd. and Sriprop Properties Pvt. Ltd. Sadashivanagr, Bangalore-560080 PAN: AAWCS7390C Appellant) : Respondent) I.T.A. No. 1283/Chny/2025 (Assessment Year: 2018-19) DCIT, CC-1(4), Sriprop Properties Pvt. Ltd. No. 31, 2nd Main Road, Shriram No. 46, Investigation Building, Income Tax Office, Nungambakkam, Vs. House, T Chowdaiah Road, Chennai-600034. Sadashivanagr

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRIPROP PROPERTIES PRIVATE LIMITED, BANGALORE

Bench: Shri George George K & Ms Padmavathy S, Am

2 ITA 1172-1273-1173-1283/Chny/2025 SPL Shelters Pvt. Ltd. and Sriprop Properties Pvt. Ltd. Sadashivanagr, Bangalore-560080 PAN: AAWCS7390C Appellant) : Respondent) I.T.A. No. 1283/Chny/2025 (Assessment Year: 2018-19) DCIT, CC-1(4), Sriprop Properties Pvt. Ltd. No. 31, 2nd Main Road, Shriram No. 46, Investigation Building, Income Tax Office, Nungambakkam, Vs. House, T Chowdaiah Road, Chennai-600034. Sadashivanagr

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SPL SHELTERS PRIVATE LIMITED, CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

2 ITA 1172-1273-1173-1283/Chny/2025 SPL Shelters Pvt. Ltd. and Sriprop Properties Pvt. Ltd. Sadashivanagr, Bangalore-560080 PAN: AAWCS7390C Appellant) : Respondent) I.T.A. No. 1283/Chny/2025 (Assessment Year: 2018-19) DCIT, CC-1(4), Sriprop Properties Pvt. Ltd. No. 31, 2nd Main Road, Shriram No. 46, Investigation Building, Income Tax Office, Nungambakkam, Vs. House, T Chowdaiah Road, Chennai-600034. Sadashivanagr

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

properties received by an assessee for inadequate consideration, but it did not apply to companies and applies only to individuals and HUF. It was by Finance Act 2017 that with effect from Assessment Year 2018-19 that this provision was substituted by Section 56(2)(x) that extended these deeming provisions to companies also. Thus, there is no case

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule

ACIT, CHENNAI vs. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains of any business of insurance, including any such business carried on by a mutual insurance company or by a co-operative society, shall be computed in accordance with the rules contained in the First Schedule.” Rule