ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

276 ITR 549 (Ori), there being a substantial difference between the figures of liabilities towards sundry creditors in the party ledgers of the assessee-firm and the figures of liabilities towards sundry creditors in the balance-sheet of the assessee-firm for the previous year relevant to the assessment year 1989-90. These materials had a direct link and nexus

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 1, PUDUCHERRY vs. MUTHU GOLD HOUSE, PUDUCHERRY

In the result, appeal filed by the revenue is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 593/Chny/2024 िनधा"रणवष" / Assessment Year: 2017-18 Muthu Gold House, Assistant Commissioner Of V. 222, Jawaharlal Nehru Street, Income Tax, Puducherry – 605 001. Circle -1, [Pan: Aaafm-8022-M] Puducherry. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. N. Arjunraj, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R. Vikneswaran, Jcit सुनवाई क" तारीख/Date Of Hearing : 05.06.2024 घोषणा क" तारीख/Date Of Pronouncement : 04.09.2024 आदेश /O R D E R

68,78,024/- out of total sales of the assessee for the year of Rs.116,17,12,741/- is treated as unexplained cash credit, the :-3-: ITA. No:593/Chny/2024 assessee is eligible for reduction in gross profit declared on such amount and reworked the excess gross profit and the same has been reduced by Rs.32,62,728/- (Rs.8

CENTRAL EXCISE STAFF COOP THRIFT AND CREDIT SOCIETY LIMITED NOX-397,CHENNAI vs. ITO, NON CORPORATE WARD-3(5), CHENNAI

In the result, both these appeals of the assessee are

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.111 & 112/Chny/2023 ("नधा"रणवष" / Assessment Years:2017-18 & 2018-19) The Central Excise Staff Co-Op Thrift Vs The Income Tax Officer & Credit Society Ltd. Nox-397, Non-Corporate Ward-3(5) 26/1, Uthamar Gandhi Salai, Chennai. Nungambakkam, Chennai. -600 034. Pan:Aaeat 9030G (अपीलाथ"/Appellant) (""यथ"/Respondent)

276 Total Rs. 29,68,672 4. The facts are being taken from assessment year 2017- 18. The Assessing Officer noted that the assessee has claimed deduction u/s.80P(2)(d) for an amount of Rs.29,68,672/-, but the Assessing Officer disallowed the same by following decision of the Hon'ble Supreme Court in the case of Civil Appeal No.1622/2010

CENTRAL EXCISE STAFF COOP THRIFT AND CREDIT SOCIETY LIMITED NOX-397,CHENNAI vs. ITO, NON CORPORATE WARD-3(5), CHENNAI

In the result, both these appeals of the assessee are

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.111 & 112/Chny/2023 ("नधा"रणवष" / Assessment Years:2017-18 & 2018-19) The Central Excise Staff Co-Op Thrift Vs The Income Tax Officer & Credit Society Ltd. Nox-397, Non-Corporate Ward-3(5) 26/1, Uthamar Gandhi Salai, Chennai. Nungambakkam, Chennai. -600 034. Pan:Aaeat 9030G (अपीलाथ"/Appellant) (""यथ"/Respondent)

276 Total Rs. 29,68,672 4. The facts are being taken from assessment year 2017- 18. The Assessing Officer noted that the assessee has claimed deduction u/s.80P(2)(d) for an amount of Rs.29,68,672/-, but the Assessing Officer disallowed the same by following decision of the Hon'ble Supreme Court in the case of Civil Appeal No.1622/2010

CHITRA RAMANATHAN,CHENNAI vs. ITO, NON CORP WARD-17(6), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.374/Chny/2023 िनधा"रण वष"/Assessment Year: 2018-19 Chitra Ramanathan, Vs. The Income Tax Officer, 4/139,G2 Cozee Waves Apt., Non Corporate Ward 17(6), 7Th Street Swaminathan Nagar, Chennai. Kottivakkam, Chennai 600 041. [Pan:Aigpr5643A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 22.11.2023 घोषणा की तारीख /Date Of Pronouncement : 29.11.2023 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), National Faceless Appeal Centre [Nfac], Delhi, Dated 01.03.2023 Relevant To The Assessment Year 2018-19 Passed Under Section 270A Of The Income Tax Act, 1961 [“Act” In Short].

276/- respectively have been made. It was found that the assessee had not disclosed the income received from Aitken Spence Hotel Management Pvt. Ltd. and HDFC totalling to ₹.2,72,769/-. Accordingly, the Assessing Officer issued show- cause notice and immediately, the assessee has paid the taxes. 3 I.T.A. No. 374/Chny/23 4. Subsequently, the Assessing Officer issued notice under section

ACIT NON CORPORATE CIRCLE 10(1), CHENNAI vs. S.VINODH KUMAR, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.2527/Chny/2017 & C.O.No.9/Chny/2018 (Ita No.2527/Chny/2017) "नधा"रण वष" /Assessment Year : 2011-2012. The Assistant Commissioner Of Vs. Shri. S. Vinodh Kumar, Income Tax, No.25, Ranganathan Avenue, Non Corporate Circle 10 (1) Kilpauk, Chennai. Chennai 600 010. [Pan Aaipv 5798G] (अपीलाथ"/Appellant) (Respondent/Cross Objector)

276 The following items were considered separately :- Rent Received 53,44,193 PPF Interest 1,99,853 Salary received 3,96,00,000 Profit on sale of shares – LTCG 69,900 Profit on sale of shares foreign company 1,18,259 Miscellaneous Income 1,670 Dividend received. 7,07,421 In our opinion non charging of interest from few persons

MOHAMED IBRAHIM,CHENNAI vs. ITO INTERNATIONAL TAXATION 1(2), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.794/Chny/2019 िनधा"रण वष"/Assessment Year: 2015-16 Shri Mohamed Ibrahim, Vs. The Income Tax Officer, New No. 22, Old No. 141, (International Taxation), Ward 1(2), 3Rd Floor, Vepery High Road, Chennai. Periamet, Chennai 600 003. [Pan:Allpm9641F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Vasudevan, Advocate ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.02.2023 घोषणा की तारीख /Date Of Pronouncement : 15.02.2023 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) 16, Chennai, Dated 31.01.2019 Relevant To The Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is Non-Resident & Filed His Return Of Income For The Assessment Year 2015-16 Admitting Total Income Of ₹.51,93,980/-. The Case Was Selected For Limited Scrutiny Under Cass & Notice Under Section 143(2) Of The Income Tax Act, 1961 [“Act”

276/- was disallowed and 4 I.T.A. No.794/Chny/19 brought to tax. 2.2 So far as claim of cost of improvement and indexation, the assessee has not furnished any supporting documents in response to notice under section 142(1) of the Act dated 30.05.2017. The assessee was show-caused as to why the cost of improvement should not be disallowed

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

276 CTR 1) wherein it was explained that, the "matching concept" has no application with respect to claim of interest expenditure under Section 36(1)(iii) of the IT Act. The relevant portion of the judgment is as follows: "While examining the allowability of deduction of this nature, the AO is to consider the genuineness of business borrowing

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

276 CTR 1) wherein it was explained that, the "matching concept" has no application with respect to claim of interest expenditure under Section 36(1)(iii) of the IT Act. The relevant portion of the judgment is as follows: "While examining the allowability of deduction of this nature, the AO is to consider the genuineness of business borrowing

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

276 of paper book. We note that the assessee pleaded before the Assessing Officer that the assessee received cheque deposits from his wife to an extent of Rs.60,19,000/-. Before the ld. CIT(A), it was contended that his wife issued 15 cheques on various dates totalling into Rs.87,62,000/-. The ld. AR contended that in making addition

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

276 of paper book. We note that the assessee pleaded before the Assessing Officer that the assessee received cheque deposits from his wife to an extent of Rs.60,19,000/-. Before the ld. CIT(A), it was contended that his wife issued 15 cheques on various dates totalling into Rs.87,62,000/-. The ld. AR contended that in making addition

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

276 of paper book. We note that the assessee pleaded before the Assessing Officer that the assessee received cheque deposits from his wife to an extent of Rs.60,19,000/-. Before the ld. CIT(A), it was contended that his wife issued 15 cheques on various dates totalling into Rs.87,62,000/-. The ld. AR contended that in making addition

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

276 of paper book. We note that the assessee pleaded before the Assessing Officer that the assessee received cheque deposits from his wife to an extent of Rs.60,19,000/-. Before the ld. CIT(A), it was contended that his wife issued 15 cheques on various dates totalling into Rs.87,62,000/-. The ld. AR contended that in making addition

RAMSAMY PONGIANNA GOUNDER DESAMANI,PALLIPALAYAM vs. ITD, WARD 2, , TIRUCHENGODE

In the result, appeal filed by the assessee is allowed

68,370/- by making an addition of Rs.1,79,52,270/- on account of share\nof loan given u/s.2(22)(e) of the Act by holding as under:\n“The provisions as laid down by section 2(22)(e) of the Act are\nvery well applicable to the assessee in spirit as it is clearly\nobserved that

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

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

276), to justify that the regular books of accounts of M/s Binny Limited can be treated as incriminating material which related / pertained to the assessee, to be factually distinguishable. The decided case involved a short question of application of Section 2(22)(e) of the Act in the hands of the shareholder of a closely held company, which

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1), CHENNAI

In the result, all appeals filed by the assessee are allowed

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

276), to justify that the regular books of accounts of M/s Binny Limited can be treated as incriminating material which related / pertained to the assessee, to be factually distinguishable. The decided case involved a short question of application of Section 2(22)(e) of the Act in the hands of the shareholder of a closely held company, which

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

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

276), to justify that the regular books of accounts of M/s Binny Limited can be treated as incriminating material which related / pertained to the assessee, to be factually distinguishable. The decided case involved a short question of application of Section 2(22)(e) of the Act in the hands of the shareholder of a closely held company, which

ARVIND NANDAGOPAL,CHENNAI vs. ACIT, CC-3(1),, CHENNAI

In the result, all appeals filed by the assessee are allowed

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

276), to justify that the regular books of accounts of M/s Binny Limited can be treated as incriminating material which related / pertained to the assessee, to be factually distinguishable. The decided case involved a short question of application of Section 2(22)(e) of the Act in the hands of the shareholder of a closely held company, which