MUTHU DANIEL RAJAN,CHENNAI vs. CIT CORPORATE CIRCLE 1, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 54F, and had denied the benefit of claim of exemption U/s 54F, amounting to a value of Rs 2,60,54,377/-. 3. The appellant had purchased a residential house at Besant Nagar in the Assessment Year of 2012-13; and to meet out the costs of purchase; had sold his lands at Kunnakkadu in this Assessment Year

DCIT NON CORPORATE CIRCLE 1, CHENNAI vs. MUTHU DANIEL RAJAN, CHENNAI

In the result, appeal filed by the Revenue in ITA No

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1675/Chny/2019 िनधा"रण वष" /Assessment Year: 2013-14 Mr.Muthu Daniel Rajan, V. The Asst. Commissioner- No.10, Appar Street, Of Income Tax, Kalakshetra Colony, Non-Corporate Circle-1(1), Besant Nagar, Chennai. Chennai-600 090. [Pan: Aadpd 9713 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 54F, and had denied the benefit of claim of exemption U/s 54F, amounting to a value of Rs 2,60,54,377/-. 3. The appellant had purchased a residential house at Besant Nagar in the Assessment Year of 2012-13; and to meet out the costs of purchase; had sold his lands at Kunnakkadu in this Assessment Year

ITO, CHENNAI vs. S. LAKSHMANAN, CHENNAI

In the result, Department appeal is dismissed

Bench: Shri N.R.S. Ganesan & Shri Chandra Poojariआयकर अपील सं./Ita No.2103/Mds/2013 "नधा"रण वष" / Assessment Year : 2010-11 Shri S. Lakshmanan, The Income Tax Officer, 99-46, C-3, Ashok Amoga Business Ward Iv(1), V. Apartments, 1St Main Road, Gandhi Nagar, Chennai - 600 034. Adyar, Chennai - 600 020. Pan : Aaupl 4308 C (अपीलाथ"/Appellant) (""यथ"/Respondent)

96 and also shown an amount of rent receipt at `7,800/- along with the property tax paid. The AR of the appellant has also made an alternative claim that if the Assessing Officer version that the property sold was not residential property and it is only lands the sale proceeds have been reinvested in purchasing another residential 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

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

Bench: This Tribunal.

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

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 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

C.ARYAMA SUNDARAM,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

96,46,446/-, it was explained that the assessee has demolished the House and constructed new residential property with total cost of Rs. 2,77,39,045/- and filed details. The Ld. AO find that the assessee has not complied the conditions and provisions of section

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

96,46,446/-. After demolishing the existing superstructure, the . After demolishing the existing superstructure, the . After demolishing the existing superstructure, the appellant appellant appellant assessee assessee assessee constructed constructed constructed a a a residential residential residential house house house at at at a a a cost cost cost of of of Rs.18,73,85,491/-. Thus, the appellant assessee claimed

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 :

96,682/-. The Ld.Counsel submitted that the Ld.CIT(A) has rightly reversed the decision of the Ld.AO as discussed by him in page 16 & 17 of his order. The Ld. DR argued that the action of the Ld. AO is correct and deserves to be upheld. 6.0 We have heard rival submissions in the light of material available on records

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, 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 :

96,682/-. The Ld.Counsel submitted that the Ld.CIT(A) has rightly reversed the decision of the Ld.AO as discussed by him in page 16 & 17 of his order. The Ld. DR argued that the action of the Ld. AO is correct and deserves to be upheld. 6.0 We have heard rival submissions in the light of material available on records

M/S SASI ENTERPRISES,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1287/Mds/2008 "नधा"रण वष" / Assessment Year : 2000-01 M/S Sasi Enterprises, The Assistant Commissioner Of No.36, Poes Garden, V. Income Tax, Chennai - 600 086. Central Circle Ii(2), Chennai - 600 034. Pan : Aacfs 4669 P (अपीलाथ"/Appellant) (""यथ"/Respondent)

house property at Raja Nagar, Neelankarai, at `90,000/-. The Assessing Officer found that during the assessment year 1996-97, the very same property was let out for `3,30,000/-. When the property fetched `3,30,000/- for assessment year 1996- 97, it is not known how the property would fetch `90,000/- after four years. According

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

96,347/-, the balance amount of `38,03,653/- was added as undisclosed income for the block period. Therefore, addition of `38,03,653/- is not justified. Similarly, the addition made by the Assessing Officer towards interest of `7,46,930/- is also not justified. 8. Now coming to assessment year 2010-11, the Ld. representative for the assessee submitted

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

96,347/-, the balance amount of `38,03,653/- was added as undisclosed income for the block period. Therefore, addition of `38,03,653/- is not justified. Similarly, the addition made by the Assessing Officer towards interest of `7,46,930/- is also not justified. 8. Now coming to assessment year 2010-11, the Ld. representative for the assessee submitted

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

96,347/-, the balance amount of `38,03,653/- was added as undisclosed income for the block period. Therefore, addition of `38,03,653/- is not justified. Similarly, the addition made by the Assessing Officer towards interest of `7,46,930/- is also not justified. 8. Now coming to assessment year 2010-11, the Ld. representative for the assessee submitted

K.S.RAVIKUMAR,COIMBATORE vs. ACIT, TRICHY

In the result, the appeals of the assessee are allowed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1505, 1506, 1507, 1508 & 1509/Mds/2014 "नधा"रण वष" / Assessment Years : 2007-08 To 2011-12 Shri K.S. Ravikumar, The Assistant Commissioner Of No.26/3, Sasti Illam, V. Income Tax, Vivekananda Nagar, Singanallur, Central Circle Ii, Coimbatore – 641 005. Trichy. Pan : Ajhpr 3493 A (अपीलाथ"/Appellant) (""यथ"/Respondent)

96,347/-, the balance amount of `38,03,653/- was added as undisclosed income for the block period. Therefore, addition of `38,03,653/- is not justified. Similarly, the addition made by the Assessing Officer towards interest of `7,46,930/- is also not justified. 8. Now coming to assessment year 2010-11, the Ld. representative for the assessee submitted