SHRI RAMESH ALLADA,USA vs. ITO,INTNL. TAXN.1(1), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.781/Chny/2022 िनधा"रण वष" /Assessment Years: 2019-20 Shri Suresh Allada, The Income Tax Officer, 2, Wildcherry Street, Vs. International Taxation Ward-1(1), Maribyrnong, Chennai. Victoria -3032. Australia. [Pan: Bqppa-1954-B] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.782/Chny/2022 िनधा"रण वष" /Assessment Years: 2019-20 Shri Ramesh Allada, The Income Tax Officer, 502, Roling Brook Ln Vs. International Taxation Ward-1(1), Cedar Park, Texas, Chennai. United States Of America. [Pan: Bxwpa-5420-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N. Arjunraj, C.A ""यथ" क" ओर से /Respondent By : Shri R. Mohan Reddy, Cit & Shri Ar. V. Sreenivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 25.04.2023 : 25.04.2023 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R Per Mahavir Singh: These Two Appeals By, Two Different Assessees, Are Arising Out Of Assessments Framed By Income Tax Officer, International Taxation

68 Lakhs and after indexing the same computed the indexed value as on the date of sale at Rs. 1,84,96,000/-. The assessee also indexed the cost of construction/cost of improvement year wise and thereby index cost as on the date of sale at Rs. 27,20,000/-. The assessee then ITA Nos.781 & 782/Chny/2022 :- 5 -: computed the long

SHRI SURESH ALLADA,AUSTRALIA vs. ITO, INTNL TAXATION WARD -I(I), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.781/Chny/2022 िनधा"रण वष" /Assessment Years: 2019-20 Shri Suresh Allada, The Income Tax Officer, 2, Wildcherry Street, Vs. International Taxation Ward-1(1), Maribyrnong, Chennai. Victoria -3032. Australia. [Pan: Bqppa-1954-B] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.782/Chny/2022 िनधा"रण वष" /Assessment Years: 2019-20 Shri Ramesh Allada, The Income Tax Officer, 502, Roling Brook Ln Vs. International Taxation Ward-1(1), Cedar Park, Texas, Chennai. United States Of America. [Pan: Bxwpa-5420-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N. Arjunraj, C.A ""यथ" क" ओर से /Respondent By : Shri R. Mohan Reddy, Cit & Shri Ar. V. Sreenivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 25.04.2023 : 25.04.2023 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R Per Mahavir Singh: These Two Appeals By, Two Different Assessees, Are Arising Out Of Assessments Framed By Income Tax Officer, International Taxation

68 Lakhs and after indexing the same computed the indexed value as on the date of sale at Rs. 1,84,96,000/-. The assessee also indexed the cost of construction/cost of improvement year wise and thereby index cost as on the date of sale at Rs. 27,20,000/-. The assessee then ITA Nos.781 & 782/Chny/2022 :- 5 -: computed the long

SHRI V. NATARAJAN (INDIVIDUAL),RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

AC happened to not make disallowance during some of previous years, same disallowance can't be made for current year does not sound reasonable. Therefore, am of considered view that AO has correctly made disallowance of interest Re 8,93,642/- which has no nexus with earning of Professional income as provisions c section 37 Allow only expenditure incurred

VARADAPPAN NATARAJAN,RASIPURAM vs. ACIT, CENTRAL CIRCLE,, SALEM

In the result, both the appeals of assessee in ITA No

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita Nos.1535 & 1801/Chny/2024 ननिाारण वर्ा/Assessment Years: 2016-17 & 2015-16 V. Varadappan Natarajan/ The Acit, V. Natarajan (Individual), Central Circle, No.64-C, Rotary Nagar, Salem. Rasipuram Tamil Nadu-637 408. [Pan: Acgpn1477Q] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.T.S. Lakshmi Venkataraman, Fca (Virtual) प्रत्यर्थी की ओर से /Respondent By : Mr.Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing : 09.10.2025 घोर्णाकीतारीख /Date Of Pronouncement : 31.10.2025

AC happened to not make disallowance during some of previous years, same disallowance can't be made for current year does not sound reasonable. Therefore, am of considered view that AO has correctly made disallowance of interest Re 8,93,642/- which has no nexus with earning of Professional income as provisions c section 37 Allow only expenditure incurred

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

AC. 7-39 guntas of 3.19 hectares in Kammaguda, H/o, Turkayamjal village, Hayathnagar Revenue Mandal, Ranga Reddy District under Kammaguda gram panchayat being pattedar vide pattedar pass book bearing No. 423331, title deed No. 427384 and patta No. 941 issued by the Mandal Revenue Officer, Hayathnagar, Ranga Reddy District, which clearly shows that the subjected land has been shown

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

AC. 7-39 guntas of 3.19 hectares in Kammaguda, H/o, Turkayamjal village, Hayathnagar Revenue Mandal, Ranga Reddy District under Kammaguda gram panchayat being pattedar vide pattedar pass book bearing No. 423331, title deed No. 427384 and patta No. 941 issued by the Mandal Revenue Officer, Hayathnagar, Ranga Reddy District, which clearly shows that the subjected land has been shown

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

AC. 7-39 guntas of 3.19 hectares in Kammaguda, H/o, Turkayamjal village, Hayathnagar Revenue Mandal, Ranga Reddy District under Kammaguda gram panchayat being pattedar vide pattedar pass book bearing No. 423331, title deed No. 427384 and patta No. 941 issued by the Mandal Revenue Officer, Hayathnagar, Ranga Reddy District, which clearly shows that the subjected land has been shown

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

AC. 7-39 guntas of 3.19 hectares in Kammaguda, H/o, Turkayamjal village, Hayathnagar Revenue Mandal, Ranga Reddy District under Kammaguda gram panchayat being pattedar vide pattedar pass book bearing No. 423331, title deed No. 427384 and patta No. 941 issued by the Mandal Revenue Officer, Hayathnagar, Ranga Reddy District, which clearly shows that the subjected land has been shown

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

68,031 Amount spent in excess as service provider Amount spent in excess as service provider 12,85,95,729 Mark-up @ 6.12% 78,70,058 The amount by which the assessee company should have been The amount by which the assessee company should have been 13,64,65,787 reimbursed by A.E, and for which the reimbursed

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

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

55 -: 1989, 1449 to 1455, 1485 to 1491/17. submitted that books relied on by the ld. Assessing Officer for making the additions were the very same which were produced by the assessee before the ld. Assessing Officer during the course of original assessment proceedings. According to him, there were no incriminating materials found at the time of search

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

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

55 -: 1989, 1449 to 1455, 1485 to 1491/17. submitted that books relied on by the ld. Assessing Officer for making the additions were the very same which were produced by the assessee before the ld. Assessing Officer during the course of original assessment proceedings. According to him, there were no incriminating materials found at the time of search

NARESH PRASAD AGARWAL,CHENNAI vs. DCIT, CHENNAI

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

55 -: 1989, 1449 to 1455, 1485 to 1491/17. submitted that books relied on by the ld. Assessing Officer for making the additions were the very same which were produced by the assessee before the ld. Assessing Officer during the course of original assessment proceedings. According to him, there were no incriminating materials found at the time of search

ACIT, CHENNAI vs. NARESH PRASAD AGARWAL, CHENNAI

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

55 -: 1989, 1449 to 1455, 1485 to 1491/17. submitted that books relied on by the ld. Assessing Officer for making the additions were the very same which were produced by the assessee before the ld. Assessing Officer during the course of original assessment proceedings. According to him, there were no incriminating materials found at the time of search

DCIT, CHENNAI vs. FORD INDIA PVT. LTD., KANCHEEPURAM

In the result, the appeal of the assessee for the assessment year 2012-13 is thus allowed

AC 459, 480 : (1960) 39 ITR 210, 219 (HL), which have described the language employed in these documents as the "international tax language". In view of the observations of Hon’ble Andhra Pradesh High Court, in Visakhapatnam Port Trust’s case (supra), these model conventions and commentaries thereon constitute international tax language and the meanings assigned by such literature

DCIT, CHENNAI vs. FORD INDIA PVT. LTD., KANCHEEPURAM

In the result, the appeal of the assessee for the assessment year 2012-13 is thus allowed

AC 459, 480 : (1960) 39 ITR 210, 219 (HL), which have described the language employed in these documents as the "international tax language". In view of the observations of Hon’ble Andhra Pradesh High Court, in Visakhapatnam Port Trust’s case (supra), these model conventions and commentaries thereon constitute international tax language and the meanings assigned by such literature

FORD INDIA PRIVATE LIMITED,KANCHEEPURAM vs. ITO, CHENNAI

In the result, the appeal of the assessee for the assessment year 2012-13 is thus allowed

AC 459, 480 : (1960) 39 ITR 210, 219 (HL), which have described the language employed in these documents as the "international tax language". In view of the observations of Hon’ble Andhra Pradesh High Court, in Visakhapatnam Port Trust’s case (supra), these model conventions and commentaries thereon constitute international tax language and the meanings assigned by such literature

FORD INDIA PRIVATE LIMITED,KANCHEEPURAM vs. ITO, CHENNAI

In the result, the appeal of the assessee for the assessment year 2012-13 is thus allowed

AC 459, 480 : (1960) 39 ITR 210, 219 (HL), which have described the language employed in these documents as the "international tax language". In view of the observations of Hon’ble Andhra Pradesh High Court, in Visakhapatnam Port Trust’s case (supra), these model conventions and commentaries thereon constitute international tax language and the meanings assigned by such literature

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

55 of the Act”. In this regard, it ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 14 -: ITA Nos.1417 & 1421/Chny/2016 was submitted that this plea being purely a legal ground which do not require investigation of additional facts , it may be admitted and decided on merits. 13. We have considered the assesseee

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

55 of the Act”. In this regard, it ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 14 -: ITA Nos.1417 & 1421/Chny/2016 was submitted that this plea being purely a legal ground which do not require investigation of additional facts , it may be admitted and decided on merits. 13. We have considered the assesseee