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

68,76,690 21,53,308 7,17,42,510 3,76,53,308 2016-17 98,29,529 30,56,909 8,87,83,560 5,63,13,914 2017-18 1,44,35,318 50,05,920 1,64,84,811 62,86,626 2018-19 1,73,70,240 60,21,575 2

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

68,76,690 21,53,308 7,17,42,510 3,76,53,308 2016-17 98,29,529 30,56,909 8,87,83,560 5,63,13,914 2017-18 1,44,35,318 50,05,920 1,64,84,811 62,86,626 2018-19 1,73,70,240 60,21,575 2

DCIT CORPORATE CIRCLE 1, COIMBATORE vs. KOVAI MEDIA P. LTD., COIMBATORE

In the result, the appeal filed by the Revenue and cross

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunatha

127 (E) dated 19.02.2019 as the assessment order making an addition of Rs.2,72,80,664/- under section 56(2)(viib) was passed on 15.12.2018, whereas the date of issue of Notification is 19.02.2019. Hence, para no.4 of the Notification based on which the Ld. CIT(A) has given relief to the assessee is not applicable to this assessee

KALYANASUNDARAM SURESH,CHENNAI vs. ACIT NON CORPORATE CIRCLE 2, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.297/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 Shri Kalyanasundaram Suresh, Vs. The Assistant Commissioner Of Old No. 12-A, New No. 24, Income Tax, Swarnamangalam East Road, West Non Corporate Circle 2, Cit Nagar, Nandanam, Chennai. Chennai 600 035. [Pan: Aobps4696F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ravi Kannan, Advocate & Shri Varun Ranganathan, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 23.07.2024 घोषणा की तारीख /Date Of Pronouncement : 28.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.12.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals)-2, Chennai For The Assessment Year 2013-14. 2. The Ld. Ar Shri K. Ravi Kannan, Advocate Drew Our Attention To The Additional Grounds Of Appeal Filed On 10.12.2023 & Submits That The Said 3 Grounds Of Appeal May Be Taken Up First The Ld. Dr Shri R.V.

127 of the Act are not applicable and held the entire assessment proceedings are valid under law. Therefore, since, we held that assessment proceedings are valid under law, again remanding the matter to the file of the ld. CIT(A) on the issue of deciding as to whether the assessment proceedings made under revised return of income is valid

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

sections": [ "143(3)", "133A", "139(1)", "143(2)", "142(1)", "68", "115BBE", "127", "120", "2(7A)" ], "issues": "1. Validity

SMT. LINGAMMAL RAMARAJU SHASTRA PRATHISHTA TRUST,RAJAPALAYAM vs. ACIT (EXEMPTIONS), COIMBATORE

In the result, the appeal stands allowed

Section 2(15) of the\nAct. With these observations, the Ld. CIT(E) directed the AO to deny the\nexemption u/s 11 of the Act.\n7. Being aggrieved by the impugned order of the Ld. CIT(E), the\nassessee has preferred the present appeal before us.\n8. Assailing the action

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

68. The ld. AR, alternatively, pleads for remanding the matter to the file of the Assessing officer to re examine the conditions stipulated in terms of Section 2(14) of the Act and this alternate plea is made especially in view of the non adjudication of the compliance of statutory conditions 36 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

68. The ld. AR, alternatively, pleads for remanding the matter to the file of the Assessing officer to re examine the conditions stipulated in terms of Section 2(14) of the Act and this alternate plea is made especially in view of the non adjudication of the compliance of statutory conditions 36 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

68. The ld. AR, alternatively, pleads for remanding the matter to the file of the Assessing officer to re examine the conditions stipulated in terms of Section 2(14) of the Act and this alternate plea is made especially in view of the non adjudication of the compliance of statutory conditions 36 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

68. The ld. AR, alternatively, pleads for remanding the matter to the file of the Assessing officer to re examine the conditions stipulated in terms of Section 2(14) of the Act and this alternate plea is made especially in view of the non adjudication of the compliance of statutory conditions 36 I.T.A. Nos.1623-1625 & 1646 & WTA 43-44/Chny/18

BONDALAPATI SHIVAJI RAO,CHENNAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(2), CHENNAI, CHENNAI

In the result, appeal filed by the assessee stands allowed and\nappeal filed by the Revenue is dismissed

127 of the Act dated\n01.03.2021. It is an admitted fact that, the AO has recorded his\nsatisfaction note on 12.03.2021 and thereafter initiated proceedings\nu/s.153C of the Act albeit for AYs 2013-14 to 2018-19 by issuing notice\nu/s.153C of the Act dated 12.03.2021. For the relevant AY 2019-20, the\nAO is noted to have issued notice

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(2), CHENNAI, CHENNAI vs. BONDALAPATI SHIVAJI RAO, CHENNAI

In the result, appeal filed by the assessee stands allowed and appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1044/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. Shri Bondalapati Shivaji Rao, The Dcit, 121, Shankar Nagar, M.G. Road, Central Circle-1(2), Pammal, Chennai-600 075. Chennai. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.1103/Chny/2023 िनधा"रण वष"/Assessment Year: 2019-20 V. The Dcit, Shri Bondalapati Shivaji Rao, Central Circle-1(2), 121, Shankar Nagar, Chennai. M.G. Road, Pammal, Chennai-600 075. [Pan: Aahpb 0083 D] (अपीलाथ"/Appellant) (""थ"/Respondent)

127 of the Act dated 01.03.2021. It is an admitted fact that, the AO has recorded his satisfaction note on 12.03.2021 and thereafter initiated proceedings u/s.153C of the Act albeit for AYs 2013-14 to 2018-19 by issuing notice u/s.153C of the Act dated 12.03.2021. For the relevant AY 2019-20, the AO is noted to have issued notice

SUNDARAM SUBRAMANIAN REP. BY LEGAL HEIR S SUNDARAM,PUDUKKOTTAI vs. ITO, CIRCLE-2(1), TRICHY

In the result, both the appeals of the Assessee are partly allowed

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

section 68 operates independently, and rejection of books is required only where income is sought to be estimated, or the correctness of accounts as a whole is in dispute. The addition made by the AO, irrespective of its correctness, is not pivoted to the entries in the books of accounts and its accuracy. Moreover, the addition is not made

SUNDARAM SUBRAMANIAN,PUDUKKOTTAI vs. ITO, CIRCLE-2(1), TRICHY

In the result, both the appeals of the Assessee are partly allowed

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

section 68 operates independently, and rejection of books is required only where income is sought to be estimated, or the correctness of accounts as a whole is in dispute. The addition made by the AO, irrespective of its correctness, is not pivoted to the entries in the books of accounts and its accuracy. Moreover, the addition is not made

R MURUGAPPA @ MURUVAPPAN,PONDICHERRY vs. ITO, WARD-4, PONDICHERRY

In the result, appeal filed by the assessee is allowed

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

68 of the Act consequently in the hands of the Appellant was wrong, erroneous, unjustified, incorrect and not sustainable in law. 4. The CIT (Appeals) failed to appreciate that the sustenance of the addition made in the hands of the Appellant was wrong, erroneous, unjustified, incorrect and not sustainable in law. 5. The CIT (Appeals) went wrong in recording

M/S SHRIRAM PROPERTIES LIMITED,CHENNAI vs. PCIT-CENTRAL1, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 431/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

68,61,895 equity shares in Shriram Properties & Infrastructure Pvt. Ltd. were pledged with Deutsche Pfandbrief Bank AG against compulsory convertible debenture issued by Shriram Properties & Infrastructure Pvt.Ltd. There is no information as to fair value measurement adopted to these combined financial instruments. As per information in Schedule 15, shares and debenture bonds were pledged with banks to avail certain

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted

SAHAI & SONS (I) LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

Section 68 of the Act, from sales accounted by the assessee. As mentioned by us at para 53 and 54 above, it is an undisputed position that credits in bullion margin money account were generally transferred to sales account. Addition of credit in bullion margin money account has been sustained by us, only to the extent not transferred/accounted