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

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

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

65,000 11,16,97,115 1999-00 2,71,55,378 5,50,06,760 8,21,62,138 1998-99 1,99,85,049 3,54,08,920 5,53,93,969 ITA Nos2125 to 2128 :- 5 -: & 2219 to 2222 /2017 (vi) Hon’ble Apex Court in the case of Mohini Jain (Miss) vs. State of Karnataka

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

65,000 11,16,97,115 1999-00 2,71,55,378 5,50,06,760 8,21,62,138 1998-99 1,99,85,049 3,54,08,920 5,53,93,969 ITA Nos2125 to 2128 :- 5 -: & 2219 to 2222 /2017 (vi) Hon’ble Apex Court in the case of Mohini Jain (Miss) vs. State of Karnataka

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

65,000 11,16,97,115 1999-00 2,71,55,378 5,50,06,760 8,21,62,138 1998-99 1,99,85,049 3,54,08,920 5,53,93,969 ITA Nos2125 to 2128 :- 5 -: & 2219 to 2222 /2017 (vi) Hon’ble Apex Court in the case of Mohini Jain (Miss) vs. State of Karnataka

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

65,000 11,16,97,115 1999-00 2,71,55,378 5,50,06,760 8,21,62,138 1998-99 1,99,85,049 3,54,08,920 5,53,93,969 ITA Nos2125 to 2128 :- 5 -: & 2219 to 2222 /2017 (vi) Hon’ble Apex Court in the case of Mohini Jain (Miss) vs. State of Karnataka

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

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

House property Rs. (35,27,428/-)\nas returned\nAdd: Interest on borrowed capital Rs. 8,14,484/-\ndisallowed (as in para 13.4)\nAdd: Addition to deemed rental income Rs. 1,68,000/-\n(as in para 12.5)\nAdd: Disallowance of deduction u/s 24(a) Rs. 25,200/-\n(as in para 12.6)\nAdd: Further estimated addition in respect

M/S. CEEBROS HOTELS PVT. LTD.,,CHENNAI vs. DCIT, CC - 1 (2),, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

housing project in view of the major work of demolition of the existing structure newly built by the previous order for hotel business by the appellant. Hence, it was submitted that there was nothing absolutely wrong in treating the property as inventory in the compilation of financial statements. It was also stated that the inventory in the business/holding

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

housing, factory and corporate office thereby virtually preventing all from ingress and egress. In the meantime the secured creditor – Bank of Baroda, which had earlier advanced loan against the security of all the assets, including Stock-in-Trade, had moved petition before DRT (Debts Recovery Tribunal) and also under SARFAESI Act (The 4 - - ITA 1216 & 2106/13 Securitization and Reconstruction

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

housing, factory and corporate office thereby virtually preventing all from ingress and egress. In the meantime the secured creditor – Bank of Baroda, which had earlier advanced loan against the security of all the assets, including Stock-in-Trade, had moved petition before DRT (Debts Recovery Tribunal) and also under SARFAESI Act (The 4 - - ITA 1216 & 2106/13 Securitization and Reconstruction

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

properties. 7.7.6 It is noticed that amendment to section 54F was made by Finance Act, 2014 w.e.f 01.04.2015 wherein deduction u/s 54F is restricted to only one residential house. Relevant provisions of section are submitted as under: 54F. (1) 65

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

properties. 7.7.6 It is noticed that amendment to section 54F was made by Finance Act, 2014 w.e.f 01.04.2015 wherein deduction u/s 54F is restricted to only one residential house. Relevant provisions of section are submitted as under: 54F. (1) 65

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

House property Rs. (35,27,428/-)\nas returned\nAdd: Interest on borrowed capital Rs. 8,14,484/-\ndisallowed (as in para 13.4)\nAdd: Addition to deemed rental income Rs. 1,68,000/-\n(as in para 12.5)\nAdd: Disallowance of deduction u/s 24(a) Rs. 25,200/-\n(as in para 12.6)\nAdd: Further estimated addition in respect

P.R.EASWAR KUMAR ,CHENNAI vs. ACIT NON CORPORATE CIRCLE 16 , CHENNAI

In the result the appeal of the assessee is allowed for statistical purposes as indicated herein above

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddy

section 54 reads as follows, "…….. and the assessee has within a period of one year before or two years after the date on which the transfer took place purchased or has within a period of three years after that date constructed a residential house." From the above, it is evidently clear that the investment in the construction of new house

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. AMPA HOUSING DEVELOPMENT PVT. LTD.,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2202, 2203, 2204 & 2205/Chny/2019 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Ampa Housing Development (P) Income Tax, Corporate Circle 1(1), Limited, No. 19, Raman Street, Chennai 600 034. T. Nagar, Chennai 600 017. [Pan:Aacca7430R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Dr. I.P. Roopa Jcit ""थ" की ओर से/Respondent By : Shri B. Ramakrishnan, Ca सुनवाई की तारीख/ Date Of Hearing : 06.01.2022 घोषणा की तारीख /Date Of Pronouncement : 23.02.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai Dated 15.03.2019 Relevant To The Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15. The Only Common Effective Ground Raised By The Revenue For All The Assessment Years Relates To Apportioning The Intermingled Common Expenditure With Relation To Business Income & Let Out Property Income In The Ratio Of 50:50 Without Valid Basis.

house property and business. 7.2 After considering the submissions of the assessee the ld. CIT(A) has observed as under: “I have carefully considered the submissions of the appellant. As pointed out by the appellant that the said expenses have to be incurred for carrying out his business, irrespective of the quantum of revenue/turnover involved. If this proportionate method

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. AMPA HOUSING DEVELOPMENT PVT. LTD.,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2202, 2203, 2204 & 2205/Chny/2019 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Ampa Housing Development (P) Income Tax, Corporate Circle 1(1), Limited, No. 19, Raman Street, Chennai 600 034. T. Nagar, Chennai 600 017. [Pan:Aacca7430R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Dr. I.P. Roopa Jcit ""थ" की ओर से/Respondent By : Shri B. Ramakrishnan, Ca सुनवाई की तारीख/ Date Of Hearing : 06.01.2022 घोषणा की तारीख /Date Of Pronouncement : 23.02.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai Dated 15.03.2019 Relevant To The Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15. The Only Common Effective Ground Raised By The Revenue For All The Assessment Years Relates To Apportioning The Intermingled Common Expenditure With Relation To Business Income & Let Out Property Income In The Ratio Of 50:50 Without Valid Basis.

house property and business. 7.2 After considering the submissions of the assessee the ld. CIT(A) has observed as under: “I have carefully considered the submissions of the appellant. As pointed out by the appellant that the said expenses have to be incurred for carrying out his business, irrespective of the quantum of revenue/turnover involved. If this proportionate method

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. AMPA HOUSING DEVELOPMENT PVT. LTD.,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2202, 2203, 2204 & 2205/Chny/2019 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Ampa Housing Development (P) Income Tax, Corporate Circle 1(1), Limited, No. 19, Raman Street, Chennai 600 034. T. Nagar, Chennai 600 017. [Pan:Aacca7430R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Dr. I.P. Roopa Jcit ""थ" की ओर से/Respondent By : Shri B. Ramakrishnan, Ca सुनवाई की तारीख/ Date Of Hearing : 06.01.2022 घोषणा की तारीख /Date Of Pronouncement : 23.02.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai Dated 15.03.2019 Relevant To The Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15. The Only Common Effective Ground Raised By The Revenue For All The Assessment Years Relates To Apportioning The Intermingled Common Expenditure With Relation To Business Income & Let Out Property Income In The Ratio Of 50:50 Without Valid Basis.

house property and business. 7.2 After considering the submissions of the assessee the ld. CIT(A) has observed as under: “I have carefully considered the submissions of the appellant. As pointed out by the appellant that the said expenses have to be incurred for carrying out his business, irrespective of the quantum of revenue/turnover involved. If this proportionate method

DCIT, CORPORATE CIRCLE - 1 (1),, CHENNAI vs. M/S. AMPA HOUSING DEVELOPMENT PVT. LTD.,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2202, 2203, 2204 & 2205/Chny/2019 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 The Deputy Commissioner Of Vs. M/S. Ampa Housing Development (P) Income Tax, Corporate Circle 1(1), Limited, No. 19, Raman Street, Chennai 600 034. T. Nagar, Chennai 600 017. [Pan:Aacca7430R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Dr. I.P. Roopa Jcit ""थ" की ओर से/Respondent By : Shri B. Ramakrishnan, Ca सुनवाई की तारीख/ Date Of Hearing : 06.01.2022 घोषणा की तारीख /Date Of Pronouncement : 23.02.2022 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai Dated 15.03.2019 Relevant To The Assessment Years 2011-12, 2012-13, 2013-14 & 2014-15. The Only Common Effective Ground Raised By The Revenue For All The Assessment Years Relates To Apportioning The Intermingled Common Expenditure With Relation To Business Income & Let Out Property Income In The Ratio Of 50:50 Without Valid Basis.

house property and business. 7.2 After considering the submissions of the assessee the ld. CIT(A) has observed as under: “I have carefully considered the submissions of the appellant. As pointed out by the appellant that the said expenses have to be incurred for carrying out his business, irrespective of the quantum of revenue/turnover involved. If this proportionate method