M/S. AMBATTUR DEVELOPERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(1), CHENNAI

In the result the appeal of the assessee is allowed

price.\n9. Applicability of section 56(2)(viib)\nAt the outset, it is important to determine the applicability of Section\n56(2)(viib) of the Act to the facts of the present case. The Ld.AR submitted that\n:-7-:\nITA. No: 2601/Chny/2024\nthe purpose of introduction of this section will be determinative factor and\nsubmitted as under:\n9.1 Purpose

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)

price (i.e., INR 275 per share) was wrongly assessed as income under Section 56(2)(viia) of the Act. The learned AO failed to note that the valuation of INR 607 determined under the DCF method is not in accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), 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)

price (i.e., INR 275 per share) was wrongly assessed as income under Section 56(2)(viia) of the Act. The learned AO failed to note that the valuation of INR 607 determined under the DCF method is not in accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back

ASIRVAD MICRO FINANCE LIMITED,ANNA SALAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1140/Chny/2025 Assessment Years: 2016-17 Asirvad Micro Finance Limited, Assistant Commissioner Of No.9, 9Th Floor, Club House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [Pan: Aagca5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.P.R.Prasanna Varma, Fca & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 25.09.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

price ought to have been Rs.56.36/share. The Ld.AO consequently made an addition of Rs.42,29,48,758/- invoking provisions of section 56(2)(viib) r.w. Rule 11UA. Aggrieved by the order, the assessee preferred appeal before the Ld.CIT(A) who confirmed the findings of the Ld.AO. The assessee is assailing the impugned order of Ld.CIT(A) dated

KARADI PATH EDUCATION COMPANY PRIVATE LIMITED,CHENNAI vs. COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

price or in the alternative provided a valuation under DCF method to\ncounter the contentions of your appellant. The DCF method postulates that the\nvalue of an asset is the sum of the cash flows expected to be generated by the\nasset during the life of the asset discounted to present value by the cost of\ncapital. This is done

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

2)\nFD Interest as 51,56,40,547 51,56,40,547\nIOS\nFor AY 2010-11, reassessment proceedings were initiated under Section 148 of the Act and order u/s.143(3) r.w.s.147 was passed on 24.03.2016 without any disallowance/addition.\n4.3 Search and seizure operations under Section 132 of the Act were carried out in the premises of the assessee

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

transfer pricing orders, which formed the basis of the revenue's appeal, had been deleted in prior proceedings. Therefore, the additions made by the Assessing Officer were deleted.", "result": "Dismissed", "sections": ["Section 56(1)", "Section 92CA", "Section 132", "Section 153C", "Section 2

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRIPROP PROPERTIES PRIVATE LIMITED, BANGALORE

Bench: Shri George George K & Ms Padmavathy S, Am

56(2)(x), the consideration in our view is the actual cost paid by the buyer towards acquisition of the property and there is no provision under said section for any adjustment towards stamp duty and registration charges born by the seller instead of the buyer. Accordingly, we see no infirmity in the decision of the CIT(A) in directing

SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

56(2)(x), the consideration in our view is the actual cost paid by the buyer towards acquisition of the property and there is no provision under said section for any adjustment towards stamp duty and registration charges born by the seller instead of the buyer. Accordingly, we see no infirmity in the decision of the CIT(A) in directing

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SPL SHELTERS PRIVATE LIMITED, CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

56(2)(x), the consideration in our view is the actual cost paid by the buyer towards acquisition of the property and there is no provision under said section for any adjustment towards stamp duty and registration charges born by the seller instead of the buyer. Accordingly, we see no infirmity in the decision of the CIT(A) in directing

GEENA GARMENTS,TIRUPPUR vs. ACIT, CIRCLE-1, TIRUPPUR, TIRUPPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

56 of the Act. On examination of the said provisions, we find the reasoning of the Assessing Officer in treating the sale of MLFPS as business income. In this regard, we shall examine as to whether the sale of scrips of MLFPS would fall under the provisions of section 2(24)(xviii) of the Act. We note that export from

ACIT, CIRCLE-1, , TIRUPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING (P) LTD., TIRUPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

56 of the Act. On examination of the said provisions, we find the reasoning of the Assessing Officer in treating the sale of MLFPS as business income. In this regard, we shall examine as to whether the sale of scrips of MLFPS would fall under the provisions of section 2(24)(xviii) of the Act. We note that export from

DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE-1, TIRUPPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING P LTD, TIRUPPUR,TAMILNADU

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

56 of the Act. On examination of the said provisions, we find the reasoning of the Assessing Officer in treating the sale of MLFPS as business income. In this regard, we shall examine as to whether the sale of scrips of MLFPS would fall under the provisions of section 2(24)(xviii) of the Act. We note that export from

SHRIPROP PROPERTIES PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Accordingly.\n15. In result, appeal of both the assessees in ITA No. 1172 & 1173/Chny/2025\nare allowed and the appeal of the revenue in ITA No

56(2)(x), the consideration in our view is the\nactual cost paid by the buyer towards acquisition of the property and there is no\nprovision under said section for any adjustment towards stamp duty and registration\ncharges born by the seller instead of the buyer. Accordingly, we see no infirmity in\nthe decision of the CIT(A) in directing

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)

transfer pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex- ITA No.672/Chny/201 /Chny/2017 (AY 2012-13) M/s.TVS Motor Co. Ltd. M/s.TVS Motor Co. Ltd. :: 16 :: factory sale at Rs.2,15,56,000/ factory

KM KNIT WEAR,TIRUPUR vs. ADIT,CPC, BANGALORE

In the result, ITA Nos. 3326/Chny/2019, 326/Chny/2024 &\n768/Chny/2022 are dismissed; ITA No

56 of the Act. On examination of the said provisions, we find\nthe reasoning of the Assessing Officer in treating the sale of MLFPS as\nbusiness income. In this regard, we shall examine as to whether the sale\nof scrips of MLFPS would fall under the provisions of section 2(24)(xviii)\nof the Act. We note that export from

GATES WEARS,TIRUPPUR vs. DCIT CIRCLE 1, TIRUPPUR

In the result, ITA Nos. 3326/Chny/2019, 326/Chny/2024 &\n768/Chny/2022 are dismissed; ITA No

56 of the Act. On examination of the said provisions, we find\nthe reasoning of the Assessing Officer in treating the sale of MLFPS as\nbusiness income. In this regard, we shall examine as to whether the sale\nof scrips of MLFPS would fall under the provisions of section 2(24)(xviii)\nof the Act. We note that export from

VICTUS DYEINGS ,TIRUPUR vs. ACIT , CIRCLE-1, TIRUPUR

56 of the Act. On examination of the said provisions, we find\nthe reasoning of the Assessing Officer in treating the sale of MLFPS as\nbusiness income. In this regard, we shall examine as to whether the sale\nof scrips of MLFPS would fall under the provisions of section 2(24)(xviii)\nof the Act. We note that export from

SAN TEX INC.,TIRUPUR vs. ACIT CIRCLE 1, TIRUPUR

56 of the Act. On examination of the said provisions, we find\nthe reasoning of the Assessing Officer in treating the sale of MLFPS as\nbusiness income. In this regard, we shall examine as to whether the sale\nof scrips of MLFPS would fall under the provisions of section 2(24)(xviii)\nof the Act. We note that export from