ACIT v. Shriram Transport Finance Co. Ltd.

9 ITR (Trib) 543Income Tax Appellate Tribunal2011#21564 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 348,631 Indian tax judgments — from 2022 to 2025.

Sections most often in play

Section 40A(2)(b)Section 80IASection 80IA(8)Section 92CA(3)Section 40A(2)Section 40A(2)(a)Section 92CA

Issues it is cited on

section 80ia(8)section 40a(2)(a)transferee companysection 43asection 40a(2)(b)deduction under section 80iasection 40a(2)corporate guaranteededuction u/s 80iacup methodamalgamationprofits and gains of business or profession

Judgments citing ACIT v. Shriram Transport Finance Co. Ltd.

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 267/CHNY/2025[2016]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

…ase of the assessee does not come under the purview of any person referred to in clause (b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for nonexclusive user of logo based on turnover and not lump sum payment should be treated as revenue expenditure. In the present case, the assessee paid the royalty for exclusively using the trade mark “CRI” based on monthly turnover at the rate of 0.50%, which wa…

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 266/CHNY/2025[2015]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

…ase of the assessee does not come under the purview of any person referred to in clause (b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for nonexclusive user of logo based on turnover and not lump sum payment should be treated as revenue expenditure. In the present case, the assessee paid the royalty for exclusively using the trade mark “CRI” based on monthly turnover at the rate of 0.50%, which wa…

Joint Commissioner of Income Tax (OSD), Corporate Circle-1, Coimbatore vs. M/S C R I Pumps Private Limited, Coimbatore

In the result, all the three appeals filed by the Revenue are dismissed…

ITA 265/CHNY/2025[2014]Status: DisposedITAT Chennai07 May 2025

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri Saujanya Ranjan, IRS
Section 40A(2)(a)

…ase of the assessee does not come under the purview of any person referred to in clause (b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for nonexclusive user of logo based on turnover and not lump sum payment should be treated as revenue expenditure. In the present case, the assessee paid the royalty for exclusively using the trade mark “CRI” based on monthly turnover at the rate of 0.50%, which wa…

Assistant Commissioner of Income Tax Corporate Circle -2, Coimbatore vs. M/S Cri Pumps Pvt Ltd, Coimbatore

In the result, the appeal filed by the Revenue is dismissed

ITA 430/CHNY/2018[2013-14]Status: DisposedITAT Chennai18 Nov 2022AY 2013-14

Bench: Shri Mahavir Singh & Shri G. Manjunathaआयकर अपील सं./Ita No.: 430/Chny/2018 िनधा"रण वष" / Assessment Year: 2013-14

For Appellant: Shri. AR V Sreenivasan, Addl. CITFor Respondent: Shri. S. Sridhar, Advocate
Section 40A(2)(b)

…ase of the assessee does not come under the purview of any person referred to in clause (b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for non- exclusive user of logo based on turnover and not lump sum payment should be treated as revenue expenditure. In the present case, the assessee paid the royalty for exclusively using the trade mark “CRI” based on monthly turnover at the rate of 0.50%, which…

ACIT v. Shriram Transport Finance Co. Ltd. (9 ITR (Trib) 543) — Cited in 4 Judgments | BharatTax