ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

68,89,00,000 under Section 56(2)(viia) of the Act; and o Disallowance of interest expenditure of INR 5,70,62,500 under Section 36(1)(iii) of the Act, being computed at 10% of the buyback value, i.e., 57,06,25,000 :-9-: ITA Nos.:1339, 1616/Chny/2025 & C.O.No.66/Chny/2025 • Pursuant to the appeal filed

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

SRINIVASA FASHINS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(4), CHENNAI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy)नधा+रण वष+ /Assessment Year: 2014-15 Heard Through Video Conferencing V. M/S.Srinivasa Fashions Pvt. Ltd., The Income Tax Officer, No.57G, Sidco Industrial Estate, Corporate Ward-6(4), Ambattur, Chennai. Chennai-600 098. [Pan: Aaics 9511 R] (अपीलाथ./Appellant) (/0यथ./Respondent) : अपीलाथ. क1 ओर से/ Appellant By Mr.N.Vijay Kumar, Ca : Mr.Ar.V.Sreenivasan, Jcit /0यथ. क1 ओर से /Respondent By : 28.09.2020 सुनवाई क1 तार"ख/Date Of Hearing : 28.09.2020 घोषणा क1 तार"ख /Date Of Pronouncement आदेश / O R D E R Per Ramit Kochar:

68 are not invocable in the facts and circumstances of the case. 7. For that the Commissioner of Income Tax (Appeals) erred in concluding that the difference on account of exchange fluctuation in the foreign loan is in the capital field and that the same is not an allowable deduction. PRAYER For these grounds and such other grounds that

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ARCHANA FEMALE CHILD TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ANISHKUMAR MALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

ANISH KUMAR WIFE TRUST,CHENNAI vs. ITO, NCW - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ANISH KUMAR EDUCATION TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

M/S. ANISH KUMAR FEMALE CHILD TRUST,CHENNAI vs. ITO, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

ANISH KUMAR MARRIAGE TRUST,,CHENNAI vs. ITO, NCC - 11 (1),, CHENNAI

In the result, the appeals of the assessees are dismissed

Bench: Shri Mahavir Singhand Shri G. Manjunatha

68 ITR 760 (SC), means that he is not liable to be assessed by a proceeding for rectification under Sec. 35, sub-section (1), he is not ‘denying his liability to be assessed under this Act’. His objection then is only against a proceeding for assessment under a particular provision of the Act. He does

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

150 taxmann.com 108 (SC). Even earlier\nthe hon'ble Delhi High Court had held in PCIT v Vikas Telecom Ltd\n[2022] 135 taxmann.com 362 (Delhi) had held that post-search\nenquiries cannot be the basis of\nassessments under Section 153A/153C. Therefore, the reliance\nplaced by the AO on the TP orders passed after the search\ncannot be countenanced

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

150 230,46,51,600 0 0 0 230,46,51,600 206.77\n2013-14 2,28,08,394 22,80,83,940 547,40,14,560 28,30,976 283,09,760 67,94,347,240 615,34,48,800 99.96\n2014-15 6,39,837 63,98,370 15,35,60,880 2

INVESTOR FINANCIAL EDUCATION ACADEMY,CHENNAI vs. ITO (EXEMPTION) - 4, CHENNAI

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

68 ITR 786] wherein, in a matter arising under the Agriculture Income Tax Act, the Court observed that the Government themselves, though in a different context, have recognised the partition, it is expected that in 6 I.T.A. Nos. 3006 & 3007/Chny/18 Revenue Department, which deals with Agriculture Income Tax too, there should be co-ordination. We have referred to this decision

INVESTOR FINANCIAL EDUCATION ACADEMY,CHENNAI vs. ITO (EXEMPTION) - 4, CHENNAI

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

68 ITR 786] wherein, in a matter arising under the Agriculture Income Tax Act, the Court observed that the Government themselves, though in a different context, have recognised the partition, it is expected that in 6 I.T.A. Nos. 3006 & 3007/Chny/18 Revenue Department, which deals with Agriculture Income Tax too, there should be co-ordination. We have referred to this decision