M/S. SRI BALAJI EDUCATIONAL AND CHARITABLE PUBLIC TRUST,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(4), CHENNAI

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

income of the appellant by considering the sustained addition of Rs.29,93,11,490/-alone and delete the balance additions. The AO is also directed to consider the TDS

SOUTHERN PETROCHEMICAL INDUSTRIES CORPORATION LTD.,CHENNAI vs. ITO, CHENNAI

Appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1.आयकरअपील सं./ Ita No.204/Chny/2023 (िनधा*रण वष* / Assessment Year: 2004-05) & 2.आयकरअपील सं./ Ita No.205/Chny/2023 (िनधा*रण वष* / Assessment Year: 2004-05) M/S. Southern Petrochemical Acit / Ito बनाम Industries Corporation Limited Corporate Circle-6(2) / 88, Spic House, Mount Road, Guindy, Corporate Ward-3(1) / Vs. Chennai-600 032. Chennai-600 034. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-4668-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan & Shri Saroj Kumar Parida (Advocates)-Ld. Ars " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) & Shri Ar V Sreenivasan (Addl. Cit)-Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 16-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 10-01-2024 आदेश / O R D E R

TDS certificates was added to the total income with an observation that if the assessee furnishes evidences to show that any of the said amount was admitted as income in any other year, the addition

SOUTHERN PETROCHEMICAL INDUSTRIES CORPORATION LTD.,CHENNAI vs. ITO, CHENNAI

Appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1.आयकरअपील सं./ Ita No.204/Chny/2023 (िनधा*रण वष* / Assessment Year: 2004-05) & 2.आयकरअपील सं./ Ita No.205/Chny/2023 (िनधा*रण वष* / Assessment Year: 2004-05) M/S. Southern Petrochemical Acit / Ito बनाम Industries Corporation Limited Corporate Circle-6(2) / 88, Spic House, Mount Road, Guindy, Corporate Ward-3(1) / Vs. Chennai-600 032. Chennai-600 034. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-4668-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan & Shri Saroj Kumar Parida (Advocates)-Ld. Ars " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) & Shri Ar V Sreenivasan (Addl. Cit)-Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 16-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 10-01-2024 आदेश / O R D E R

TDS certificates was added to the total income with an observation that if the assessee furnishes evidences to show that any of the said amount was admitted as income in any other year, the addition

GROOM INDIA SALON AND SPA PVT LTD.,CHENNAI vs. ACIT CENTRAL CIRCLE 2(1), CHENNAI

The appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

income of the assessee. The Ld. CIT(A) upheld the same on the ground that it was agreed addition. 5.2 The Ld. AR has filed a copy of Form 26AS and submitted that one of the party (M/s Wella India Hair Cosmetics Pvt. Ltd.) against whom major difference arises, has rectified the TDS

ABAN OFFSHORE LIMITED,CHENNAI vs. DCIT, INTL, TAX 1(1), CHENNAI

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

additions. Aggrieved by the impugned order of the\nLd.CIT(A), the assessee is in appeal before us.\n4.\nThe Ld.AR for the assessee submitted that, as per section 195\nof Income Tax act, payment made to non-resident shall not be liable\nto deduct TDS

K. VENKATESAN (HUF),SALEM vs. ACIT, CIRCLE 1(1) SALEM, SALEM

Appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Jagadish

addition. It is clear that if claim should be made in return of income and in absence of the same, the assessee is not entitled for any claim as such since there is no corresponding income in the return of income. The assessee’s claim for TDS

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP WARD 8, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

addition made towards disallowance of re-insurance premium ceded to NRRIs as not taxable in India under the Income Tax Act, 1961; or under DTAA between India & respective countries, where NRRs are tax residents; and thus, on impugned payments, the assessee was not liable to deduct TDS

DEPUTY COMMISSIONER OF INCOME TAX OFFICER , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

addition made towards disallowance of re-insurance premium ceded to NRRIs as not taxable in India under the Income Tax Act, 1961; or under DTAA between India & respective countries, where NRRs are tax residents; and thus, on impugned payments, the assessee was not liable to deduct TDS

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

addition made towards disallowance of re-insurance premium ceded to NRRIs as not taxable in India under the Income Tax Act, 1961; or under DTAA between India & respective countries, where NRRs are tax residents; and thus, on impugned payments, the assessee was not liable to deduct TDS

DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

addition made towards disallowance of re-insurance premium ceded to NRRIs as not taxable in India under the Income Tax Act, 1961; or under DTAA between India & respective countries, where NRRs are tax residents; and thus, on impugned payments, the assessee was not liable to deduct TDS

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP CIRCLE 8, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

addition made towards disallowance of re-insurance premium ceded to NRRIs as not taxable in India under the Income Tax Act, 1961; or under DTAA between India & respective countries, where NRRs are tax residents; and thus, on impugned payments, the assessee was not liable to deduct TDS

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

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

TDS effected by the respective companies on the accrual of dividend would clearly establish the intention of the assessee. 12. The Assessing Officer in the process had further held that the adjustment of the dividend income against the interest payable by the companies in which :-6-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 the Assessee had interest

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

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

TDS effected by the respective companies on the accrual of dividend would clearly establish the intention of the assessee. 12. The Assessing Officer in the process had further held that the adjustment of the dividend income against the interest payable by the companies in which :-6-: IT(SS)A Nos. 153 & 162/Chny/2003 & ITA. Nos:744 & 2197/Chny/2005 the Assessee had interest

SWAMINATHAN SUKUMAR,SALEM vs. ITO, WARD-1(6), SALEM

In the result, appeal filed by the assessee is allowed

TDS of\nRs.25,632/- from rental income. The assessee filed an updated\nreturn u/s.139(8A) of the Act on 31.10.2022 and claims that Form\nITR 3 was not enabled for filing before that date. The assessee\ncontends that the CPC has computed interest u/s.234A of the Act till\n31.10.2022 (date of filing the updated return) instead of till\n25.05.2022 (date

DEPUTY COMMISSIONER OF INCOMETAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

addition made\ntowards disallowance of re-insurance premium ceded to NRRIs as not\ntaxable in India under the Income Tax Act, 1961; or under DTAA between\nIndia & respective countries, where NRRs are tax residents; and thus, on\nimpugned payments, the assessee was not liable to deduct TDS

DCIT, CHENNAI vs. M/S. UNITED INDIA INSURANCE CO. LTD., CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.1692/Chny/2011 िनधा"रण वष" /Assessment Year: 2007-08 The Dy. Commissioner- V. M/S.United India- Of Income Tax, Insurance Co. Ltd., Large Taxpayer Unit, 24, Whites Road, Chennai. Chennai-600 014. [Pan: Aaacu 5552 C] (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Mr.M.Swaminathan, Sr. Standing Counsel Assessee By : Mr.S.Sundararaman, Ca सुनवाई की तारीख/Date Of Hearing : 19.06.2023 घोषणा की तारीख /Date Of Pronouncement : 28.06.2023

TDS u/s.195 of the Income Tax Act, 1961. Consequently, payments made to NRR cannot be disallowed u/s.40(a)(i) of the Act, :: 17 :: 1961. Hence, we direct the Assessing Officer to delete additions

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

addition was made with reference to ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 9 :: incriminating material viz., Annexure ANN/MS/JMG/LS/S-1 unearthed in course of search and according to him therefore, the reliance placed by the assessee on the decision of PCIT vs Abhisar Buildwell Pvt. Ltd. (supra) was distinguishable. Overall

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

addition was made with reference to ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 9 :: incriminating material viz., Annexure ANN/MS/JMG/LS/S-1 unearthed in course of search and according to him therefore, the reliance placed by the assessee on the decision of PCIT vs Abhisar Buildwell Pvt. Ltd. (supra) was distinguishable. Overall

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

addition was made with reference to ITA Nos.799 to 805/Chny/2024 (AYs 2013-14, 2014-15 & 2016-17 to 2020-21) M/s. Metal Impex :: 9 :: incriminating material viz., Annexure ANN/MS/JMG/LS/S-1 unearthed in course of search and according to him therefore, the reliance placed by the assessee on the decision of PCIT vs Abhisar Buildwell Pvt. Ltd. (supra) was distinguishable. Overall