RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made. Hence this issue of assessee’s appeal is allowed. ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 5.6 Since the facts are identical in other four assessment years i.e., 2012-13 to 2015-16 also, taking a consistent view, no disallowance can be made

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made. Hence this issue of assessee’s appeal is allowed. ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 5.6 Since the facts are identical in other four assessment years i.e., 2012-13 to 2015-16 also, taking a consistent view, no disallowance can be made

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made. Hence this issue of assessee’s appeal is allowed. ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 5.6 Since the facts are identical in other four assessment years i.e., 2012-13 to 2015-16 also, taking a consistent view, no disallowance can be made

DCIT , TDS CIRCLE , COIMBATORE vs. M/S KOVAI MEDICAL CENTRE AND HOSPITAL LIMITED , COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1004/Chny/2022 िनधा"रण वष" / Assessment Year: 2015-16 Deputy Commissioner Of M/S. Kovai Medical Centre & Income Tax, V. Hospital Limited, Tds Circle, 99 Avinashi Road, Coimbatore. Coimbatore - 641 014. [Pan: Aaack-9192-L] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. M. Rajan, Cit -Dr ""यथ" क" ओर से/Respondent By : Shri. Vikram Vijayaraghavan, Advocate

section 192 of the Act should have been deducted. Since, the appellant has deducted TDS u/s. 194J of the Act, the AO has computed short deduction of TDS u/s. 201(1) and interest thereon u/s. 201(1A) of the Act, on payment made to consultant doctors and worked out short deduction of TDS at Rs. 7,02

TEMENOS INDIA PVT. LTD.,CHENNAI vs. DCIT INTERNATIONAL TAXATION 2(2), CHENNAI

The appeal stands allowed in terms of our above order

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

02-2016. The assessee has filed concise grounds which read as under: 1. The Commissioner of Income Tax (Appeals) failed to appreciate that the Appellant is engaged in the business of banking software solutions and the share of cost of software paid to foreign group company cannot be considered as royalty and hence there is no requirement to deduct

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

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

02,59,960/-. Subsequently, the assessee filed\nits revised return u/s.139(5) of the Act on 16.10.2015 & 26.11.2015\nadmitting `Nil' income. Later, the assessee's case was selected for\nscrutiny and assessment was completed u/s.143(3) of the Act.\nSubsequently, the case was flagged for verification of foreign\nremittances made during the relevant financial year 2013-14 as per\nthe

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

TDS by invoking the provisions of Section 40(a)(ia) if the Act. In view of the second proviso to this Section, we are in full agreement with the arguments of the :: 8 :: I.T.A Nos.:1654 to 1658/CHNY/2019 learned Counsel for the Assessee, as well as the learned Senior Departmental Representative that, in case the recipients have disclosed the remunerations

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

TDS by invoking the provisions of Section 40(a)(ia) if the Act. In view of the second proviso to this Section, we are in full agreement with the arguments of the :: 8 :: I.T.A Nos.:1654 to 1658/CHNY/2019 learned Counsel for the Assessee, as well as the learned Senior Departmental Representative that, in case the recipients have disclosed the remunerations

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

TDS by invoking the provisions of Section 40(a)(ia) if the Act. In view of the second proviso to this Section, we are in full agreement with the arguments of the :: 8 :: I.T.A Nos.:1654 to 1658/CHNY/2019 learned Counsel for the Assessee, as well as the learned Senior Departmental Representative that, in case the recipients have disclosed the remunerations

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

TDS by invoking the provisions of Section 40(a)(ia) if the Act. In view of the second proviso to this Section, we are in full agreement with the arguments of the :: 8 :: I.T.A Nos.:1654 to 1658/CHNY/2019 learned Counsel for the Assessee, as well as the learned Senior Departmental Representative that, in case the recipients have disclosed the remunerations

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

TDS by invoking the provisions of Section 40(a)(ia) if the Act. In view of the second proviso to this Section, we are in full agreement with the arguments of the :: 8 :: I.T.A Nos.:1654 to 1658/CHNY/2019 learned Counsel for the Assessee, as well as the learned Senior Departmental Representative that, in case the recipients have disclosed the remunerations

ACIT VILLUUPRAM CIRCLE, VILLUUPRAM vs. S.RADAKRISHNAN, TINDIVANAM

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

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकर अपील सं./Ita No.: 3049/Chny/2018 िनधा"रण वष" /Assessment Year: 2009-10 The Acit, Shri S. Radakrishnan, Villupuram Circle, V. 33/3, A1 Mallam Road, Villupuram – 605 602. Indira Nagar, Tindivanam – 604 202. Panl Aidpr 4858G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri R. Bhoopathy, Addl. Cit ""यथ" क" ओर से/Respondent By : Shri Philip George, Advocate सुनवाई क" तार"ख/Date Of Hearing : 03.02.2022 घोषणा क" तार"ख/Date Of Pronouncement : 15.02.2022

TDS u/s.194C of the Act, thereby violated the provisions of section 40(a)(ia) of the Act. The assessee replied to the AO vide letter dated 20.03.2015 that he has obtained Form No.15I from the transport contractors and the same are filed with the CIT, Puducherry. The AO asked the assessee to produce Form No.15I & 15J in support

M/S. DATALOG TECHNOLOGIES LIMITED,COIMBATORE vs. DCIT, INTERNATIONAL TAXATION, COIMBATORE

In the result, appeals filed by the assessee for all the three assessment years are allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 935, 936 & 937/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Deputy Commissioner Of M/S. Datalog Technologies V. Income-Tax, Private Limited, International Taxation, Flat No. 6, 3Rd Street, Coimbatore. Narayandas Layout, Tatabad, Coimbatore – 641 012. [Pan: Aabcd-5720-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.05.2024 आदेश /O R D E R

Section 201(1) and 201(1A) of the Income Tax Act, 1961 for the aforesaid Assessment years. However, the facts as well as :-2-: ITA. Nos: 935, 936 & 937/Chny/2023 issues are identical for all the years, these appeals are heard together and are being disposed off by way of this common order. 2. The sole ground in these appeals

M/S. DATALOG TECHNOLOGIES PRIVATE LIMITED,COIMBATORE vs. DCIT, INERNATIONAL TAXATION, , COIMBATORE

In the result, appeals filed by the assessee for all the three assessment years are allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 935, 936 & 937/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Deputy Commissioner Of M/S. Datalog Technologies V. Income-Tax, Private Limited, International Taxation, Flat No. 6, 3Rd Street, Coimbatore. Narayandas Layout, Tatabad, Coimbatore – 641 012. [Pan: Aabcd-5720-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.05.2024 आदेश /O R D E R

Section 201(1) and 201(1A) of the Income Tax Act, 1961 for the aforesaid Assessment years. However, the facts as well as :-2-: ITA. Nos: 935, 936 & 937/Chny/2023 issues are identical for all the years, these appeals are heard together and are being disposed off by way of this common order. 2. The sole ground in these appeals

M/S. DATALOG TECHNOLOGIES PRIVATE LIMITED,COIMBATOREE vs. DCIT, INTERNATIONAL TAXATION,, COIMBATORE

In the result, appeals filed by the assessee for all the three assessment years are allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.: 935, 936 & 937/Chny/2023 िनधा"रण वष" / Assessment Years: 2012-13, 2013-14 & 2014-15 Deputy Commissioner Of M/S. Datalog Technologies V. Income-Tax, Private Limited, International Taxation, Flat No. 6, 3Rd Street, Coimbatore. Narayandas Layout, Tatabad, Coimbatore – 641 012. [Pan: Aabcd-5720-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri. D. Hema Bhupal, Jcit सुनवाई क" तारीख/Date Of Hearing : 08.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 31.05.2024 आदेश /O R D E R

Section 201(1) and 201(1A) of the Income Tax Act, 1961 for the aforesaid Assessment years. However, the facts as well as :-2-: ITA. Nos: 935, 936 & 937/Chny/2023 issues are identical for all the years, these appeals are heard together and are being disposed off by way of this common order. 2. The sole ground in these appeals

M.ARUNACHALAM AND COMPANY,CHENNAI vs. JCIT, CHENNAI

In the result, both the appeals of the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1352 & 1353/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11 M/S M. Arunachalam & Company, The Joint / Assistant No.117/79, Lloyds Road, V. Commissioner Of Income Tax, Royapettah, Chennai - 600 014. Business Range Viii, Chennai - 600 006. Pan : Aaafm 6851 F (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS was made. The payment 11 I.T.A. Nos.1352 & 1353/Mds/15 made for centring work is nothing but sub-contract. Therefore, the assessee is liable to deduct tax under Section 194C of the Act. In view of the above, this Tribunal is of the considered opinion that the assessee is liable to deduct tax in respect of all the payments made. Therefore

M.ARUNACHALAM AND COMPANY,CHENNAI vs. JCIT, CHENNAI

In the result, both the appeals of the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.1352 & 1353/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11 M/S M. Arunachalam & Company, The Joint / Assistant No.117/79, Lloyds Road, V. Commissioner Of Income Tax, Royapettah, Chennai - 600 014. Business Range Viii, Chennai - 600 006. Pan : Aaafm 6851 F (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS was made. The payment 11 I.T.A. Nos.1352 & 1353/Mds/15 made for centring work is nothing but sub-contract. Therefore, the assessee is liable to deduct tax under Section 194C of the Act. In view of the above, this Tribunal is of the considered opinion that the assessee is liable to deduct tax in respect of all the payments made. Therefore

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS”) credit of Rs. 77,93,486 and accordingly claimed a refund of Rs. 4,31,593. A survey was conducted in the premises of the assessee on July 02, 2010. During the survey, original agreements relating to a financial transaction with (“SICCL”) viz, Facility agreement dated December 29, 2006, Re-stated agreement dated February 15, 2007 and two correspondences