K.R.JAYARAM,CHENNAI vs. ACIT, COIMBATORE

In the result, the appeal of the assessee is partly allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

Section 50C. Thus there is no escapement warranting reassessment on any fresh material information but only change of opinion. 3. The Commissioner

RAMDOSS RAMVIJAY KUMAR,,CHENNAI vs. ITO, NCW - 14(5),, CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.: 3096/Chny/2019 िनधा"रण वष" / Assessment Year: 2006-07

50C of the Act. The Assessing Officer never examined the applicability of :-6-: ITA. No: 3096/Chny/2019 the provisions of section SOC during the course of original assessment proceedings. Therefore, the question of change of opinion does not arise in this case. 6. During the course of appeal proceedings the AR of the appellant also submitted that the appellant

SARAVANAN ARUMUGAM,CHENNAI vs. ITO, CHENNAI

reassessment. Explanation.—In this section, —Valuation Officer|| has the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957).] 1. Subs 2[143. Assessment.—3[(1) Where a return has been made under section 139, or in response to a notice under sub-section (1) of section 142, such return shall

SUNDARAKRISHNAN,CHENNAI vs. PCIT, COIMBATORE

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1935/Chny/2024 िनधा"रण वष" / Assessment Year: 2014-15 Sundarakrishnan, Principal Commissioner Of No. 15, 5Th Main Road, V. Income Tax, Kasturba Nagar, Coimbatore -1. Adyar – 600 020. [Pan: Arbps-4782-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Y. Sridhar, Fca ""यथ" क" ओर से/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 04.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 11.02.2025 आदेश /O R D E R Per S. R. Raghunatha:

reassessment order u/s.147 of the Act. 5.2 The ld.AR submitted that the issue of enforcing the provisions of Section 50C

ARTHI BALIGA,CHENNAI vs. ACIT, NFAC, , DELHI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.1559/Chny/2024 िनधा"रण वष"/Assessment Year: 2017-18 Arthi Baliga, Vs. The Principal Commissioner Of No. 15, Flat No. 3-C, Coral Woods Income Tax, Chennai-4, Apartment, Sri Ram Nagar, South Chennai. Street, Alwarpet, Chennai 600 018. [Pan:Bkjpb5416P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ravi Kannan, Advocate & Shri Varun Ranganathan, Advocate ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 05.12.2024 घोषणा की तारीख /Date Of Pronouncement : 28.02.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax, Chennai-4, Chennai For The Assessment Year 2017-18 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

section 50C of the Income Tax Act and the possibility of making reference to the Valuation Officer. Thus, he prayed to dismiss the grounds raised by the assessee and sustain the revision order passed by the ld. PCIT. 19. Heard both the parties, perused the material available on record. We note that the partnership firm, in question, by name

KALYANASUNDARAM BHARATH HARI,CHITTLAPAKKAM,CHENNAI vs. ITO, INT. TAX WARD 1(1), CHENNAI, CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

50C and within the meaning of section 147 of the Income Tax Act, for a sum Rs.29,20,000/-. Therefore, for the year under consideration, the assessee had undervalued his inform from long term capital gains out of the above said transactions and provisions of clause (c) of explanation 2 to sec.147 are applicable to facts of this case

M/S MADRAS RACE CLUB,CHENNAI vs. DCIT, CENRAL CIRCLE-1(2), CHENNAI

In the result the appeal of the assessee stands allowed

Bench: Hon’Bleshri Manu Kumar Giriand Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.688/Chny/2024 िनधा"रण वष"/Assessment Year:2007-2008 M/S.Madras Race Club, The Deputy Commissioner Of Race Course Road, Vs. Income Tax, Guindy Industrial Estate S.O., Central Circle 1(2) Guindy, Chennai Chennai 600 032. Pan: Aaacm 7640R (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. R. Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nandakumar, Irs, Cit.

reassessment, the Assessing Officer has treated the lease agreement as a deemed sale and has applied provisions of Section 50C

EDWIN SELVARAJ SUNDRARAJ,SALEM vs. THE ITO, WARD -1(4), SALEM

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.: 783/Chny/2022 िनधा"रण वष" / Assessment Year: 2014-15

section 50C of the Act and considered 1/3rd share of the assessee which works out to Rs. 31,49,500/- and computed long term capital gain of Rs. 13,99,344/-. The AO, while arriving at income from capital gains has allowed relief to the extent of Rs. 5,58,321/-, towards capital gains admitted by the assessee

LATE P.S.ULAGARAKSHAGAN,CHENNAI vs. THE PCIT-3, CHENNAI

In the result, the appeal filed by the assessee is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.249/Chny/2021 िनधा"रण वष"/Assessment Year: 2015-16 Late P.S. Ulagarakshagan Vs. The Principal Commissioner Of Ambika U, L/H Of Ulagarakshagan, Income Tax-3, No. 4, Anushya Street, Nagarjuna Chennai – 34. Nagar, 2Nd Street, Rangarajapuram, Kodambakkam, Chennai 600 024. [Pan:Aaipu8947Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A. ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 09.03.2023 घोषणा की तारीख /Date Of Pronouncement : 15.03.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax, Chennai – 3, Chennai Dated 11.03.2021 Relevant To The Assessment Year 2015-16 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

50C, the ld. CIT (A) has also failed to appreciate that merely because the guideline value was higher than sale consideration in the deed of conveyance, cannot be the sole reason for holding that the assessment is erroneous and prejudicial to the interest of revenue. 5. With regard to applicability of Section 56, the ld. CIT (A) failed to consider

ABDUL LATHIEF MAHAMMED ARIF,COIMBATORE vs. ITO, NCW-5(2), COIMBATORE

In the result, the appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

50C of the Act. Abdul Lathief Mohammed Arif (Vs.) ITO Ward 5(2) :: 3 :: 2.2 During reassessment proceedings, statements were recorded from the assessee, his mother and sisters. The sisters categorically stated that they had received only their respective shares through demand drafts and that no cash was received by them. The Assessing Officer held that the entire alleged

BALASUBRAMANIAN ADITYAN LEGAL HEIR OF DR. B SIVANTHI ADITYAN,CHENNAI vs. DCIT CORPORATE CIRCLE 6 (2), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1700/Chny/2018 िनधा"रण वष"/Assessment Year: 2007-08 Balasubramanian Adityan, Vs. The Deputy Commissioner Of Legal Heir Of Dr. B. Sivanthi Adityan, Income Tax, No. 6, E.V.K. Sampath Road, Corporate Circle 6(2), Vepery, Chennai 600 007. Chennai 600 034. [Pan:Aampa7576R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V.S. Jayakumar, Sr. Advocate For Shri Pmn Bhagavath Krishnan, Adv. ""थ" की ओर से/Respondent By : Shri Clement Ramesh Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 19.07.2023 घोषणा की तारीख /Date Of Pronouncement : 30.08.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 28.02.2018 Relevant To The Assessment Year 2007-08. In The Appeal, The Assessee Has Raised Following Grounds: 1. The Order Of The Commissioner Of Income Tax Appeals Is Contrary To Law & Facts Of The Case. 2. Reassessment Made Us 147: (I) The Commissioner Of Income Tax Appeals Erred In Confirming The Reassessment Made U/S 147 Of The Income Tax Act. 1961. 2

reassessment made on the appellant, which is inapplicable to the facts of the case., The Commissioner of Income Tax Appeals failed to note that the in the facts of the appellant's case the original notice was served on the dead person. 3. Merits of the case: valuation for the purpose of levy of capital gains tax: (i) The Commissioner

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order passed by the AO. It was submitted that total consideration in the agreement was Rs. 15 Crs. while it is claimed by the ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 47 -: assessee that they had only received Rs. 12 Crs. It was submitted that assessee received Rs. 4.25 Crs. and then paid to ‘Indian bank’ to clear the loan taken

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order passed by the AO. It was submitted that total consideration in the agreement was Rs. 15 Crs. while it is claimed by the ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 47 -: assessee that they had only received Rs. 12 Crs. It was submitted that assessee received Rs. 4.25 Crs. and then paid to ‘Indian bank’ to clear the loan taken

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order passed by the AO. It was submitted that total consideration in the agreement was Rs. 15 Crs. while it is claimed by the ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 47 -: assessee that they had only received Rs. 12 Crs. It was submitted that assessee received Rs. 4.25 Crs. and then paid to ‘Indian bank’ to clear the loan taken

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

reassessment order passed by the AO. It was submitted that total consideration in the agreement was Rs. 15 Crs. while it is claimed by the ITA No.307/Chny/2010 & ITA Nos.1015 & 1016/Chny/2012 & :- 47 -: assessee that they had only received Rs. 12 Crs. It was submitted that assessee received Rs. 4.25 Crs. and then paid to ‘Indian bank’ to clear the loan taken

P.PANJURAJAN,SIVAKASI vs. DCIT, CC-2,, MADURAI

In the result, appeal filed by the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)

section 143(3) of the Act dated 27.03.2014 before the Ld. CIT(A) wherein the assessee failed to bring on record any documentary evidence to contradict the cash receipt issued by the vendor. Accordingly, the assessment was confirmed on merits against which assessee is in further appeal before us. 4. At the outset, Ld. Counsel for the appellant submitted that

M/S. RAGHUNATH GREEN POWER (P) LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 3084 & 3086/Chny/2019 िनधा"रण वष"/Assessment Year: 2005-06 M/S. Raghunath Green Power Pvt. Ltd., The Assistant Commissioner Of No. 16, Cenotaph Road, Teynampet, Vs. Income Tax, Company Circle V(3), Chennai 600 018. Chennai. [Pan:Aadcr1513K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri G. Chandrababu, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.01.2021 घोषणा की तारीख /Date Of Pronouncement : 11.03.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 3, Chennai, Dated 18.09.2019 Relevant To The Assessment Year 2014-15 Passed Against The Assessment Order Under Section 143(3) R.W. Section 147 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Against The Rectification Order Passed Under Section 154 Of The Act.

section 143(3) r.w.s. 147 of the Act, the assessee has raised the following grounds: 3 I.T.A. Nos. 3084 & 3086/Chny/19 “1.1 The order of the CIT(A) is erroneous, opposed to law and facts and liable to be set aside insofar as the same is passed in a casual and summary manner. 1.2 The CIT(A) erred in disposing

M/S. RAGHUNATH GREEN POWER (P) LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 3084 & 3086/Chny/2019 िनधा"रण वष"/Assessment Year: 2005-06 M/S. Raghunath Green Power Pvt. Ltd., The Assistant Commissioner Of No. 16, Cenotaph Road, Teynampet, Vs. Income Tax, Company Circle V(3), Chennai 600 018. Chennai. [Pan:Aadcr1513K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate ""थ" की ओर से/Respondent By : Shri G. Chandrababu, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.01.2021 घोषणा की तारीख /Date Of Pronouncement : 11.03.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 3, Chennai, Dated 18.09.2019 Relevant To The Assessment Year 2014-15 Passed Against The Assessment Order Under Section 143(3) R.W. Section 147 Of The Income Tax Act, 1961 [“Act” In Short] As Well As Against The Rectification Order Passed Under Section 154 Of The Act.

section 143(3) r.w.s. 147 of the Act, the assessee has raised the following grounds: 3 I.T.A. Nos. 3084 & 3086/Chny/19 “1.1 The order of the CIT(A) is erroneous, opposed to law and facts and liable to be set aside insofar as the same is passed in a casual and summary manner. 1.2 The CIT(A) erred in disposing