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

Bench: This Tribunal.

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

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

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

Bench: This Tribunal. 2. Since, The Facts Are The Identical Across All The Appeals / For All The Assessment Years, Except For The Nature Of The Additions / Disallowances Varying In Few Of The Assessment Year(S) Before This Tribunal In The Present Batch Of 6 Appeals, The Appeal Arising From The A.Y. 2012-13 Is Being Taken Up As The Lead Case With The Consent Of The Both The Ld. Ar As Well As The Departmental Representatives. 3. The Brief Fact Of The Present Case Is That The Assessee, Shri Thanushkodi Narayanan, Is The Managing Director Of M/S.Annai Builders Real Estates Pvt Ltd. The Assessee Filed His Original Return Of Income For The A.Y. 2012-13 On 27.09.2012 In Declaring A Total Income Of Rs.24,87,430/-. 4. A Search & Seizure Operation Was Carried Out In Terms Of Section 132 Of The Act On 04.10.2017 In The Residential Premises Of The Assessee & Also In The Premises Of M/S.Annai Builders Real Estates Pvt. Ltd. In Which The Assessee Is The Managing Director. 5. Thereafter, A Notice U/S.153A Of The Act For The A.Y.2012-13 Was Issued On 25.09.2018 To The Assessee By The Assessing Officer (In Short “Ao”) & In Response To The Same, The Assessee Had Filed E-Return Of Income For The A.Y. 2012-13 On 17.08.2019 In Declaring Total Income Of Rs.14,53,440/-. :-3-:

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

S.SAROJA,CHENNAI vs. ACIT, NON CORPORAE CIRCLE-19(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 418/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 S. Saroja, Deputy Commissioner Of Door No. 47, Pandian Street, V. Income Tax, Sankaran Avenue, Velachery, Non Corporate Circle – 19(1), Chennai – 600 042. Chennai. [Pan: Baeps-1299-G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. B. Sakthivel, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 31.05.2023 घोषणा क" तारीख/Date Of Pronouncement : 31.05.2023

92,192/- for under-reporting of income by misreporting of its income. The assessee carried the matter in appeal before the first appellant authority, but could not succeed. The ld. CIT(A), for the reasons stated in their appellant order dated 21.2.2023 sustained penalty levied by the AO u/s. 270A of the Act. 3. The ld. Counsel for the assessee

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

DCIT, CHENNAI vs. CHARUMATHY SESHADRI, CHENNAI

In the result, the Revenue’s appeal is treated as partly allowed for

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

property, namely the officer should have deducted the entire Rs. 11 lakhs paid for purchasing 1 acre 92 cents with the farm house. 12. Section

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 property by investing the said Rs.6.45 crores in Capital Gain Account :-3-: ITA. No:710/Chny/2025 Scheme (CGAS) with SBI. The assessee’s case was selected for scrutiny and the order u/s.143(3) of the Act was finalized determining his total income as Rs.6,92,04,950/-. 5. During the assessment proceedings AO found that the assessee had purchased

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

92. We have heard the arguments of the Ld.AR as well as the ld.DR and pursued the records. We find that the plea for bifurcation of the assessment of the house property income attributable to the Property at Navin Building, Madipakkam in view of the admitted fact of the same being a property held in joint capacity

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

92. We have heard the arguments of the Ld.AR as well as the ld.DR and pursued the records. We find that the plea for bifurcation of the assessment of the house property income attributable to the Property at Navin Building, Madipakkam in view of the admitted fact of the same being a property held in joint capacity

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

92. We have heard the arguments of the Ld.AR as well as the ld.DR and pursued the records. We find that the plea for bifurcation of the assessment of the house property income attributable to the Property at Navin Building, Madipakkam in view of the admitted fact of the same being a property held in joint capacity

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

92. We have heard the arguments of the Ld.AR as well as the ld.DR and pursued the records. We find that the plea for bifurcation of the assessment of the house property income attributable to the Property at Navin Building, Madipakkam in view of the admitted fact of the same being a property held in joint capacity

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

92. We have heard the arguments of the Ld.AR as well as the ld.DR and pursued the records. We find that the plea for bifurcation of the assessment of the house property income attributable to the Property at Navin Building, Madipakkam in view of the admitted fact of the same being a property held in joint capacity

PROTECTRON ELECTROMECH PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.403/Mds/2017 "नधा"रण वष"/Assessment Year:2012-13 M/S. Protectron Electromech The Deputy Commissioner Of Private Limited, No. 9, Athipattan Vs. Income Tax, Corporate Circle 5(2), Street, Mount Road, Aayakar Bhavan, Chennai 600 002. Chennai 600 034. [Pan:Aabcp1103B] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri N. Devanathan, Advocate ""यथ" क" ओर से/Respondent By : Shri Guru Bhashyam, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 23.01.2018 घोषणा क" तार"ख /Date Of Pronouncement : 20.04.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 3, Chennai Dated 28.10.2016 Relevant To The Assessment Year 2012-13. The Assessee Has Raised Two Effective Grounds In The Appeal Viz., (I) The Ld. Cit(A) Erred In Confirming The Disallowance Made Under Section 14A R.W. Rule 8D & (Ii) The Ld. Cit(A) Erred In Confirming The Disallowance Made Under The Head “Income From Other Source”.

section 14A r.w. Rule 8D of ₹.21,90,466/-. Since the assessee has already disallowed a sum of ₹.2,98,421/- in the computation of income, the balance amount of ₹.18,92,045/- was disallowed and brought to tax. 3 I.T.A. No.403/M/17 2.2 In the statement of income filed along with the return, the assessee had returned income from house

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92 B does add that the expression international transaction shall include “the purchase, sale, transfer, lease or use of intangible property, including the transfer of ownership or the provision of use of rights regarding land use, copyrights, patents, trademarks, licences, franchises, customer list, marketing channel, brand, commercial secret, know-how, industrial property right, exterior design or practical and new design

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92 B does add that the expression international transaction shall include “the purchase, sale, transfer, lease or use of intangible property, including the transfer of ownership or the provision of use of rights regarding land use, copyrights, patents, trademarks, licences, franchises, customer list, marketing channel, brand, commercial secret, know-how, industrial property right, exterior design or practical and new design