Toyota Kirloskar Motor (P) Ltd. v. Union of India

422 ITR 138Reported decision#15842 most cited
6

judgments rely on this decision, according to BharatTax’s citation analysis of 348,607 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 271(1)(c)Section 143(3)Section 144CSection 148Section 28(v)Section 14ASection 147Section 260A

Issues it is cited on

section 28(v)dependent agent peagency pefixed place peroyalty incomesection 260section 260apermanent establishmentmiscellaneous applicationfurnishing inaccurate particularspenalty u/s 271(1)(c)change of opinion

Judgments citing Toyota Kirloskar Motor (P) Ltd. v. Union of India

M/S.Redington Distributions Pte Ltd., Singapore vs. ACIT, Intltaxation Circle-2(1), Chennai

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

ITA 894/CHNY/2025[2016-17]Status: DisposedITAT Chennai29 Jul 2025AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

…ution did not reduce the adjustment to NIL which shows that, the assessee had furnished inaccurate particulars of income in India. Relying upon the decision of the Hon’ble Karnataka High Court in the case of Toyota Kirloskar Motor (P) Ltd vs. Union of India (422 ITR 138), the AO levied penalty of 100% of the tax arising on the income added pursuant to the MAP resolution being Rs.92,14,154/-. 10. Being aggrieved by the above penalty order of the AO, the assessee carried the matter in appeal before the Ld. CIT(A) who confirmed the penalty by observing as follows: ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2…

M/S.Redington Distributions Pte Ltd., Singapore vs. ACIT, Intltaxation Circle-2(1), Chennai

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

ITA 893/CHNY/2025[2015-16]Status: DisposedITAT Chennai29 Jul 2025AY 2015-16

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

…ution did not reduce the adjustment to NIL which shows that, the assessee had furnished inaccurate particulars of income in India. Relying upon the decision of the Hon’ble Karnataka High Court in the case of Toyota Kirloskar Motor (P) Ltd vs. Union of India (422 ITR 138), the AO levied penalty of 100% of the tax arising on the income added pursuant to the MAP resolution being Rs.92,14,154/-. 10. Being aggrieved by the above penalty order of the AO, the assessee carried the matter in appeal before the Ld. CIT(A) who confirmed the penalty by observing as follows: ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2…

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

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

ITA 892/CHNY/2025[2014-15]Status: DisposedITAT Chennai29 Jul 2025AY 2014-15

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

…ution did not reduce the adjustment to NIL which shows that, the assessee had furnished inaccurate particulars of income in India. Relying upon the decision of the Hon’ble Karnataka High Court in the case of Toyota Kirloskar Motor (P) Ltd vs. Union of India (422 ITR 138), the AO levied penalty of 100% of the tax arising on the income added pursuant to the MAP resolution being Rs.92,14,154/-. 10. Being aggrieved by the above penalty order of the AO, the assessee carried the matter in appeal before the Ld. CIT(A) who confirmed the penalty by observing as follows: ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2…

M/S. Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

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

ITA 891/CHNY/2025[2013-14]Status: DisposedITAT Chennai29 Jul 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

…ution did not reduce the adjustment to NIL which shows that, the assessee had furnished inaccurate particulars of income in India. Relying upon the decision of the Hon’ble Karnataka High Court in the case of Toyota Kirloskar Motor (P) Ltd vs. Union of India (422 ITR 138), the AO levied penalty of 100% of the tax arising on the income added pursuant to the MAP resolution being Rs.92,14,154/-. 10. Being aggrieved by the above penalty order of the AO, the assessee carried the matter in appeal before the Ld. CIT(A) who confirmed the penalty by observing as follows: ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2…

M/S.Redington Distributors Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

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

ITA 890/CHNY/2025[2012-13]Status: DisposedITAT Chennai29 Jul 2025AY 2012-13

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

…ution did not reduce the adjustment to NIL which shows that, the assessee had furnished inaccurate particulars of income in India. Relying upon the decision of the Hon’ble Karnataka High Court in the case of Toyota Kirloskar Motor (P) Ltd vs. Union of India (422 ITR 138), the AO levied penalty of 100% of the tax arising on the income added pursuant to the MAP resolution being Rs.92,14,154/-. 10. Being aggrieved by the above penalty order of the AO, the assessee carried the matter in appeal before the Ld. CIT(A) who confirmed the penalty by observing as follows: ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2…

M/S.Redington Distribution Pte Ltd., Singapore vs. ACIT, Intl Taxation Circle-2(1), Chennai

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

ITA 889/CHNY/2025[2011-12]Status: DisposedITAT Chennai29 Jul 2025AY 2011-12

Bench: Shri Aby T. Varkey & Shri Jagadish

For Appellant: Mr. Percy PardiwalaFor Respondent: Mr. Shiva Srinivas, CIT
Section 144CSection 148Section 271(1)(c)

…ution did not reduce the adjustment to NIL which shows that, the assessee had furnished inaccurate particulars of income in India. Relying upon the decision of the Hon’ble Karnataka High Court in the case of Toyota Kirloskar Motor (P) Ltd vs. Union of India (422 ITR 138), the AO levied penalty of 100% of the tax arising on the income added pursuant to the MAP resolution being Rs.92,14,154/-. 10. Being aggrieved by the above penalty order of the AO, the assessee carried the matter in appeal before the Ld. CIT(A) who confirmed the penalty by observing as follows: ITA Nos.889 to 894/Chny/2025 (AYs 2011-12 to 2…

Toyota Kirloskar Motor (P) Ltd. v. Union of India (422 ITR 138) — Cited in 6 Judgments | BharatTax