DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

68,493/- u/s 4O(a)(a) of the IT Act holding that the transaction is a colourable device to reduce the taxable income and otherwise also in the nature of interest expense liable to TDS. The appellant has submitted that a. Factoring is akin to bill discounting, under a new nomenclature. Banks and a financial institutions have specialized division

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

68,493/- u/s 4O(a)(a) of the IT Act holding that the transaction is a colourable device to reduce the taxable income and otherwise also in the nature of interest expense liable to TDS. The appellant has submitted that a. Factoring is akin to bill discounting, under a new nomenclature. Banks and a financial institutions have specialized division

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

68,493/- u/s 4O(a)(a) of the IT Act holding that the transaction is a colourable device to reduce the taxable income and otherwise also in the nature of interest expense liable to TDS. The appellant has submitted that a. Factoring is akin to bill discounting, under a new nomenclature. Banks and a financial institutions have specialized division

SHRI. MOOLCHAND KIRAN KUMAR JAIN,CHENNAI vs. DCIT, CENTRAL CIRCLE 1(4), CHENNAI

In the result, appeal filed by the assessee for assessment years 2020-21 & 2021-22 are partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1417 & 1418/Chny/2023 िनधा"रण वष" / Assessment Years: 2020-21 & 2021-22 Shri. Moolchand Kiran Kumar Deputy Commissioner Of Jain, V. Income-Tax, No. 123, Usman Road, Central Circle 1(4), T. Nagar, Chennai – 600 017. Chennai – 600 034. [Pan: Achpm-2247-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. D. Anand, Advocate : Shri. V. Nandakumar, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 26.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

28A) means "interest payable in any manner in respect of any moneys borrowed or debt incurred". But, for Section 36(1)(iii), "interest" is restricted to that on money borrowed and not on debt incurred. In simple words, the essence of interest is that it is a payment which because the creditor has not had his money

SHRI. MOOLCHAND KIRAN KUMAR JAIN,CHENNAI vs. DCIT, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI

In the result, appeal filed by the assessee for assessment years 2020-21 & 2021-22 are partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1417 & 1418/Chny/2023 िनधा"रण वष" / Assessment Years: 2020-21 & 2021-22 Shri. Moolchand Kiran Kumar Deputy Commissioner Of Jain, V. Income-Tax, No. 123, Usman Road, Central Circle 1(4), T. Nagar, Chennai – 600 017. Chennai – 600 034. [Pan: Achpm-2247-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. D. Anand, Advocate : Shri. V. Nandakumar, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 26.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

28A) means "interest payable in any manner in respect of any moneys borrowed or debt incurred". But, for Section 36(1)(iii), "interest" is restricted to that on money borrowed and not on debt incurred. In simple words, the essence of interest is that it is a payment which because the creditor has not had his money

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

68,000/-\n(as in para 12.5)\nAdd: Disallowance of deduction u/s 24(a) Rs. 25,200/-\n(as in para 12.6)\nAdd: Further estimated addition in respect Rs.\nOf Nanganallur and Velacherry\nProperties towards low Fair rent\n(as in para 12.7)\nRs. 3,40,000/-\nC. Income from Business as returned

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

28A of the paper book for AYs 2002- 03 and 2003-04 respectively. Special audit report and reply filed by the assessee go to prove that the entire assessment made u/s 153A/143 (3) for AYs 2002-03 & 2003-04 hinges upon special tax audit report and not on any incriminating material. 11. Identical issue has come up before

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

28A of the paper book for AYs 2002- 03 and 2003-04 respectively. Special audit report and reply filed by the assessee go to prove that the entire assessment made u/s 153A/143 (3) for AYs 2002-03 & 2003-04 hinges upon special tax audit report and not on any incriminating material. 11. Identical issue has come up before

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

28A of the paper book for AYs 2002- 03 and 2003-04 respectively. Special audit report and reply filed by the assessee go to prove that the entire assessment made u/s 153A/143 (3) for AYs 2002-03 & 2003-04 hinges upon special tax audit report and not on any incriminating material. 11. Identical issue has come up before

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

28A of the paper book for AYs 2002- 03 and 2003-04 respectively. Special audit report and reply filed by the assessee go to prove that the entire assessment made u/s 153A/143 (3) for AYs 2002-03 & 2003-04 hinges upon special tax audit report and not on any incriminating material. 11. Identical issue has come up before

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

In the result, the appeals filed by the assessees in ITA Nos

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

28A of the paper book for AYs 2002- 03 and 2003-04 respectively. Special audit report and reply filed by the assessee go to prove that the entire assessment made u/s 153A/143 (3) for AYs 2002-03 & 2003-04 hinges upon special tax audit report and not on any incriminating material. 11. Identical issue has come up before

THANUSHKODI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-3(2), CHENNAI

68,000/-\n(as in para 12.5)\nAdd: Disallowance of deduction u/s 24(a) Rs. 25,200/-\n(as in para 12.6)\nAdd: Further estimated addition in respect Rs.\nOf Nanganallur and Velacherry\n:-6-:\nITA Nos: 2569, 2570, 2571,\n2573 to 2577/Chny/2025\nProperties towards low Fair rent Rs. 3,40,000/-\n(as in para 12.7)\nC. Income from

JOTHI NARAYANAN,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(2), CHENNAI

68,000/-\nAdd: Disallowance of deduction u/s 24(a)\n(as in para 12.6)\nRs. 25,200/-\nAdd: Further estimated addition in respect\nOf Nanganallur and Velacherry\nProperties towards low Fair rent\n(as in para 12.7)\nRs. 3,40,000/-\n(Rs. 21,79,744/-)\nC.\nIncome from Business as returned\nRs. 4,65,000/-\nD.\nIncome from Other

M/S. CHENNAI PETROLEUM CORPORATION LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri George Mathanआयकर अपील सं./Ita No.1858/Mds/2011 "नधा"रण वष" / Assessment Year : 2004-05 Chennai Petroleum Corporation Ltd., Asst. Commissioner Of Income Refinery House, Manali, Vs. Tax, Chennai – 600 068 Company Circle-I(3), [Pan: Aaacm 4392C] Chennai – 600 034 (अपीलाथ" /Appellant) (""यथ"/Respondent)

section 28- (i) to (ii)… 3 ITA Nos. 1858 & 1980/Mds/2011 (AY 2004-05) Chennai Petroleum Corporation Ltd. (iii) the amount of the interest paid in respect of capital borrowed for the purposes of the business or profession: Provided that any amount of the interest paid, in respect of capital borrowed for acquisition of an asset (whether capitalised