DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

173\nRs.5626/\ngm\n2976/gm\n10. Without prejudice while before Ld CIT(A) the ‘A' submitted the value of gold\njewellery gifted by ‘A's mother to her grandchildren (minor daughters of the ‘A’) to be at\nRs. 2,05,16,000/- the value of the same as per the fixed assets statement of the ‘A' as on\n31.03.2017 stands

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

68\nof the Act. By making an addition u/s.69 of the Act, the AO has clearly exceeded\nthe jurisdiction vested in him and travelled beyond the scope of limited scrutiny.\n96. For this reason, we are unable to subscribe to the reasoning adopted by\nthe Ld.CIT(A) that since the asset was included in the gain arising\non account

ACIT, NCC-11,, CHENNAI vs. SMT. DEVAKUMARI,, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.3066/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Smt. Devakumari, Vs. The Assistant Commissioner Of No. 48, Venkata Maistry Street, Income Tax, Mannady, Chennai 600 001. Non Corporate Circle 11, Chennai. [Pan:Aagpd0150L] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.3181/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Assistant Commissioner Of Vs. Smt. Devakumari, Income Tax, No. 48, Venkata Maistry Street, Non Corporate Circle 11(1), Mannady, Chennai 600 001. Chennai.

68 of the Act as well as disallowance of interest relating thereon of ₹.1,01,050/-. 7.1 Before us, the ld. Counsel for the assessee has submitted that both the minors have received gifts in the previous assessment year and the amounts were lying in the bank accounts of the minors unused. Thus, the 11 I.T.A. Nos.3066 & 3181/Chny/19 minors offered

SMT. DEVAKUMARI,CHENNAI vs. ACIT, NCC-11, , CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.Corrigendum To I.T.A. No.3066/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Smt. Devakumari, Vs. The Assistant Commissioner Of No. 48, Venkata Maistry Street, Income Tax, Mannady, Chennai 600 001. Non Corporate Circle 11, [Pan:Aagpd0150L] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) शु""प" आदेश /Corrignendum Order Per V. Durga Rao: The Appeal Of The Assessee In Ita No. 3066/Chny/2019 As Well As The Appeal Filed By The Revenue In Ita No. 3181/Chny/2019 For The Assessment Year 2014-15 Were Disposed Off By The Division Bench ‘B’, Chennai Benches, Chennai Vide Common Order Dated 13.09.2023. The Ld. Counsel For The Assessee Has Brought To The Notice That There Is A Typographical Error In Last Sentence In Para 9 Of The Order, Wherein, The Bench Has Observed That The Element Of Personal Usage Cannot Be Ruled Out In The Absence Of Production Of Electricity Bills & Thereby, The Addition To The Extent Of ₹.2,00,000/- Has Been Sustained Out Of Addition Confirmed By The Ld. Cit(A). However, It Was Also Mentioned That The “Balance Addition Of ₹.3,00,000/- Stands Sustained” Is A Typographical Error.

68 of the Act as well as disallowance of interest relating thereon of ₹.1,01,050/-. 7.1 Before us, the ld. Counsel for the assessee has submitted that both the minors have received gifts in the previous assessment year and the amounts were lying in the bank accounts of the minors unused. Thus, the 14 I.T.A. Nos.3066 & 3181/Chny/19 minors offered

ACIT CENTRAL CIRCLE 3(1), CHENNAI vs. SHIV SAHAI & SONS (INDIA) LTD., 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

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

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

ACIT CENTRAL CIRCLE 3(2) , CHENNAI vs. CMG STEELS PVT. LTD. , CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 1985/Chny/2017 िनधा"रण वष" / Assessment Year: 2011-12 The Asst. Commissioner Of M/S. Cmg Steels Pvt. Ltd., Income Tax, V. No.8, Elanthanur, Central Circle – 3(2), Ponneri High Road, Chennai – 34. Chennai – 600 103. Pan: Aadcc 7579C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co No.: 155/Chny/2017 (In Ita No.1985/Chny/2017) िनधा"रण वष" / Assessment Year: 2011-12 M/S. Cmg Steels Pvt. Ltd., The Asst. Commissioner Of Income Tax, V. No.8, Elanthanur, Central Circle – 3(2), Ponneri High Road, Chennai – 34. Chennai – 600 103. Pan: Aadcc 7579C (अपीलाथ"/Appellant) (""यथ"/Respondent) राज" की ओर से /Revenue By : Shri S. Bharath, Cit "नधा"रती क" ओर से/Assessee By : Shri T. Banusekar, Advocate सुनवाई क" तार"ख/Date Of Hearing : 25.03.2021 घोषणा क" तार"ख/Date Of Pronouncement : 09.06.2021

Section 68 of the Act and made additions to total income. Similarly, the AO has made addition towards interest paid on said loans u/s.37 of the Act. 6. Being aggrieved by the assessment order, assessee preferred an appeal before the ld.CIT(A). Before the ld.CIT(A), the assessee has challenged assessment framed u/s.143(3) r.w.s. 153C

M.KIRAN KUMAR,CHENNAI vs. ACIT CENTRAL CIRCLE-1(4), CHENNAI

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

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

68,072/- and addition on excess jewellery found during the course of search for Rs.10,17,000/-. The AO has made additions towards undisclosed income of Rs.20 crores on the ground that although the assessee has surrendered undisclosed income during the course of search u/s.132(4) of the Act, for not explaining various discrepancies noticed in respect of excess wastage

M/S SUNSMART TECHNOLOGIES PVT LTD.,CHENNAI vs. PCIT, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh & Shri Manjunatha. Gआयकर अपील सं./Ita No.: 173/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 M/S. Sunsmart Technologies Principal Commissioner Of Pvt Ltd., V. Income Tax-3, 25 Yellow Buildings, Chennai-34. 25 R.K. Salai, V Floor Opp. Hsbc Bank, Mylapore, Chennai – 600 004 [Pan: Aajcs-7454-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Ms. Lekha, Ca अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. Ravi Babu, Cit सुनवाई की तारीख/Date Of Hearing : 31.10.2023 घोषणा की तारीख/Date Of Pronouncement : 31.10.2023

68,58, 173/- relates to SSG Technologies, Dubai, for want of deduction of tax at source u/s.195 of the Income Tax Act, 1961. 2.1 The assessee had filed an appeal against this assessment order. Meanwhile, the learned CIT in his order u/s.263 of the Act observed that apart from the above payment, an additional expenditure of rs.2

M/S. CASTLEWICK FZE,DUBAI vs. ACIT,INTERNATIONAL TAXATION, CIRCLE-1(1), CHENNAI

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

68 SOT 178\n(Mumbai) [13-02-2015] discussed herein supra. Under section 90(2),\nwhere the government has entered into a tax treaty with any tax\njurisdiction, the provisions of Income Tax Act shall apply to the extent they\nare more beneficial to such assesses to whom such treaty applies. In my\nconsidered view, where there

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

173 & 182 of the Paper Book-I and the summary of his stay at Page 9 of Paperbook-II to show that, his stay in India for rendering such consultancy services to the assessee was actually less than 183 days during the year. Having taken note of these facts / details, according to us, the taxability of the impugned payment made

CENTRE FOR URBANISATION BUILDINGS AND ENVIRONMENT (CUBE), ,CHENNAI vs. ITO, EXEMPTIONS WARD 4,, CHENNAI

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.3280/Chny/2024 िनधा9रण वष9 /Assessment Year: 2024-25

section 143(3) dated 27-03-2025 for 19 207 213 AY-2023-24 F Scrutiny Assessment for AY-2019-20 20 Scrutiny Assessment Order dated 24-09-2021 for AY-2019-20 214 222 G Assessee’s projects and Activities 21 Project wise activities carried on by CUBE in AY-2023-24 223 227 Detailed description