D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 निर्धारण वर्ष/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, 5, S V Illam, Mohanapuri Lake View Street, Adambakkam, Chennai 600 088. [Pan: Aaatc5967A] (अपीलार्थी/Appellant) अपीलार्थी की ओर से / Appellant By Vs. The Income Tax Officer, Exemption Ward 4, Chennai. (प्रत्यर्थी/Respondent) Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate Ms. Gouthami Manivasagam, Jcit 28.10.2025 21.01.2026 : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख / Date Of Hearing : घोषणा की तारीख / Date Of Pronouncement : आदेश/Order 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 Id. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The

reassessment order dated 30.09.2021 and the Id. CIT(A) order dated 05.04.2024 denying exemption under sections 11 & 12 of the Act. Further, she prays to dismiss the assessee's grounds of appeal by treating its activities are commercial and not charitable under section 2

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S.MAC QUALITY BUILDERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

11 Taxmann.com 100/199 Taxman 341//20127 340 ITR 14 wherein the Hon'ble Delhi High Court has held that the provisions of section 2(22) (e) of the Act is not attracted if the recipient is not a shareholder: (b) The decision of the Jurisdictional High Court in the case of CIT v. Checkpoint Apparel Labelling Solutions (India

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MUKUNDA LAND DEVELOPERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

11 Taxmann.com 100/199 Taxman 341//20127 340 ITR 14 wherein the Hon'ble Delhi High Court has held that the provisions of section 2(22) (e) of the Act is not attracted if the recipient is not a shareholder: (b) The decision of the Jurisdictional High Court in the case of CIT v. Checkpoint Apparel Labelling Solutions (India

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S.MINAL CONSTRACTORS AND BUILDERS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

11 Taxmann.com 100/199 Taxman 341//20127 340 ITR 14 wherein the Hon'ble Delhi High Court has held that the provisions of section 2(22) (e) of the Act is not attracted if the recipient is not a shareholder: (b) The decision of the Jurisdictional High Court in the case of CIT v. Checkpoint Apparel Labelling Solutions (India

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MEADOW INFRASTRUCTURE PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

11 Taxmann.com 100/199 Taxman 341//20127 340 ITR 14 wherein the Hon'ble Delhi High Court has held that the provisions of section 2(22) (e) of the Act is not attracted if the recipient is not a shareholder: (b) The decision of the Jurisdictional High Court in the case of CIT v. Checkpoint Apparel Labelling Solutions (India

DCIT, CENTRAL CIRCLE-2(2), CHENNAI vs. M/S. MUKILANSTRUCTURALS PVT LIT., CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.642/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of Vs. M/S. Mukunda Land Developers Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Income Tax, Central Circle 2(2), Investigation Building, Sai Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aahcp7751K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.643/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mugilan Structurals Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Vs. Investigation Building, Nagar, Okkiam Thoraipakkam, Chennai 34. Chennai 600 097. [Pan:Aajcm3182D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.644/Chny/2023 िनधा"रण वष"/Assessment Year: 2021-22 The Deputy Commissioner Of M/S. Mac Quality Builders Pvt. Ltd., Plot No. 198, 13Th Cross Street, Sri Sai Income Tax, Central Circle 2(2), Investigation Building, Nagar, Okkiam Thoraipakkam, Vs. Chennai 34. Chennai 600 097. [Pan:Aaecv8582B] (अपीलाथ"/Appellant) (""थ"/Respondent)

11 Taxmann.com 100/199 Taxman 341//20127 340 ITR 14 wherein the Hon'ble Delhi High Court has held that the provisions of section 2(22) (e) of the Act is not attracted if the recipient is not a shareholder: (b) The decision of the Jurisdictional High Court in the case of CIT v. Checkpoint Apparel Labelling Solutions (India

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

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

11) of Section 2 or for the purpose of carrying on any general insurance business: Provided further that in the case of an insurer carrying on any general insurance business no such notification shall be issued having effect for more than three years at any one time: Provided also that no insurer other than an Indian insurance company shall begin

ACIT, CHENNAI vs. CHETTINAD ACADEMY OF RESEARCH AND EDUCATION, CHENNAI

In the result, the appeal of the revenue is dismissed

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

2) of section 11 that it is mandatory for the person claiming the benefit of section 11 to intimate to the assessing authority the particulars required under rule 17 in Form No. 10 of the Act. If during the assessment proceedings the Assessing Officer does not have the necessary information, question of excluding such income from assessment does not arise

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

11(2), if return of income is not filed within due date or not has to be seen in the given facts and circumstances of the Act. In this case, the assessee has given reasons for not filing return of income within due date specified u/s.139(1) of the Act, as per which the person in-charge of finance