PRAKASHCHAND,CHENNAI vs. ITO, TDS WARD 1,, CHENNAI

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

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

10. The Learned CIT(A) erred in sustaining the levy of interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an invalid demand under. section 234E, is equally unsus invalid demand under. section 234E, is equally unsustainable. tainable. The Appellant

PRAKASHCHAND,CHENNAI vs. ITO, TDS WARD-1, CHENNAI

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

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

10. The Learned CIT(A) erred in sustaining the levy of interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an invalid demand under. section 234E, is equally unsus invalid demand under. section 234E, is equally unsustainable. tainable. The Appellant

PRAKASHCHAND,CHENNAI vs. ITO, TDS WARD-1,, CHENNAI

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

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

10. The Learned CIT(A) erred in sustaining the levy of interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an invalid demand under. section 234E, is equally unsus invalid demand under. section 234E, is equally unsustainable. tainable. The Appellant

PRAKASHCHAND,CHENNAI vs. ITO, TDS WARD-1,, CHENNAI

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

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

10. The Learned CIT(A) erred in sustaining the levy of interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an interest under section 220(2), which being consequential to an invalid demand under. section 234E, is equally unsus invalid demand under. section 234E, is equally unsustainable. tainable. The Appellant

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

14 ITR 249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

14 ITR 249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

14 ITR 249 placed\nat pages 60 to 70 of paper book and the decision of the Hon'ble High\nCourt of Delhi in the case of Escorts reported in 338 ITR 435 placed at\npages 71 to 84 of paper book for the proposition that if similar claims\nhave been allowed in the earlier assessment years, revisionary\nproceedings cannot

DCIT, CIRCLE - 2 (1), INTERNATIONAL TAXATION,, CHENNAI vs. M/S. PETROFAC ENGINEERING SERVICES INDIA PVT. LTD.,, CHENNAI

In the result, appeals filed by the revenue for both

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.656 & 657/Chny/2020 ("नधा"रणवष" / Assessment Years: 2011-12 & 2012-13) Vs M/S. Petrofac Engineering The Deputy Commissioner Of Income Tax, Services Pvt.Ltd. 7Th Floor, Block 9A Circle-2(1), International Taxation, Chennai. Dlf Infocity Sez 1/124 Shivaji Gardens, Nandambakkam Post Manapakkam, Chennai-600089. Pan: Aaecp 1211H (अपीलाथ"/Appellant) (""यथ"/Respondent)

14(b)(ii) of the Copyright Act is of’ any copy of a computer programme’, making it clear that the section would only apply to the making of copies of the computer programme and then selling them, i.e., reproduction of the same for sale or commercial rental. [Para 142] Conclusion Given the definition of royalties contained in article

DCIT, CIRCLE - 2 (1), INTERNTIONAL TAXATION, CHENNAI vs. M/S. PETROFAC ENGINEERING SERVICES INDIA PVT. LTD,,, CHENNAI

In the result, appeals filed by the revenue for both

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.Nos.656 & 657/Chny/2020 ("नधा"रणवष" / Assessment Years: 2011-12 & 2012-13) Vs M/S. Petrofac Engineering The Deputy Commissioner Of Income Tax, Services Pvt.Ltd. 7Th Floor, Block 9A Circle-2(1), International Taxation, Chennai. Dlf Infocity Sez 1/124 Shivaji Gardens, Nandambakkam Post Manapakkam, Chennai-600089. Pan: Aaecp 1211H (अपीलाथ"/Appellant) (""यथ"/Respondent)

14(b)(ii) of the Copyright Act is of’ any copy of a computer programme’, making it clear that the section would only apply to the making of copies of the computer programme and then selling them, i.e., reproduction of the same for sale or commercial rental. [Para 142] Conclusion Given the definition of royalties contained in article

ALFHA COACH BUILDERS,KARUR vs. ITO, WARD-1,, KARUR

In the result, all six these appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 32 & 33/Chny/2025 िनधा"रण वष" / Assessment Years: 2014-15 & 2015-16 Alfha Coach Builders, The Income Tax Officer, Sf No.596’3, Andan Kovil East, Vs. Ward -1, Pudhur, Covai Road, Karur. Karur – 639 002. [Pan: Aaofa-8970-D] (अपीलाथ"/Appellant) (""थ"/Respondent)

10. There is no dispute on the aspect of validity of the Section 234E of the Act. The only issue that has to be decided in the present case is as to whether the late fee can be imposed under Section 234E of the Act, while processing the statement of TDS under Section 200A of the Act for the subject

ALFHA COACH BUILDERS,KARUR vs. ITO, WARD-1,, KARUR

In the result, all six these appeals filed by the assessee are allowed

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.: 32 & 33/Chny/2025 िनधा"रण वष" / Assessment Years: 2014-15 & 2015-16 Alfha Coach Builders, The Income Tax Officer, Sf No.596’3, Andan Kovil East, Vs. Ward -1, Pudhur, Covai Road, Karur. Karur – 639 002. [Pan: Aaofa-8970-D] (अपीलाथ"/Appellant) (""थ"/Respondent)

10. There is no dispute on the aspect of validity of the Section 234E of the Act. The only issue that has to be decided in the present case is as to whether the late fee can be imposed under Section 234E of the Act, while processing the statement of TDS under Section 200A of the Act for the subject

DOLLARS & POUNDS,CHENNAI vs. ACIT CPC TDS, GHAZIABAD

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

14 & 2014-15 and prayed for similar decision in the present appeal. 3 I.T.A. No.2015 to 2030/Chny/18 Moreover, the ld. Counsel for the assessee has relied on the following decisions: 1. Smt. G. Indhirani v. DCIT [2015] 60 taxmann.com 312 (Chennai- Trib) 2. Sibia Healthcare (P) Ltd. v. DCIT [2015] 63 taxmann.com 333 (Amritsar-Trib)(TM) 3. Maharashtra Cricket Association

DOLLARS & POUNDS,CHENNAI vs. ACIT CPC TDS, GHAZIABAD

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

14 & 2014-15 and prayed for similar decision in the present appeal. 3 I.T.A. No.2015 to 2030/Chny/18 Moreover, the ld. Counsel for the assessee has relied on the following decisions: 1. Smt. G. Indhirani v. DCIT [2015] 60 taxmann.com 312 (Chennai- Trib) 2. Sibia Healthcare (P) Ltd. v. DCIT [2015] 63 taxmann.com 333 (Amritsar-Trib)(TM) 3. Maharashtra Cricket Association

DOLLARS & POUNDS,CHENNAI vs. ACIT CPC TDS, GHAZIABAD

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

14 & 2014-15 and prayed for similar decision in the present appeal. 3 I.T.A. No.2015 to 2030/Chny/18 Moreover, the ld. Counsel for the assessee has relied on the following decisions: 1. Smt. G. Indhirani v. DCIT [2015] 60 taxmann.com 312 (Chennai- Trib) 2. Sibia Healthcare (P) Ltd. v. DCIT [2015] 63 taxmann.com 333 (Amritsar-Trib)(TM) 3. Maharashtra Cricket Association

DOLLARS & POUNDS,CHENNAI vs. ACIT CPC TDS, GHAZIABAD

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

14 & 2014-15 and prayed for similar decision in the present appeal. 3 I.T.A. No.2015 to 2030/Chny/18 Moreover, the ld. Counsel for the assessee has relied on the following decisions: 1. Smt. G. Indhirani v. DCIT [2015] 60 taxmann.com 312 (Chennai- Trib) 2. Sibia Healthcare (P) Ltd. v. DCIT [2015] 63 taxmann.com 333 (Amritsar-Trib)(TM) 3. Maharashtra Cricket Association

DOLLARS & POUNDS,CHENNAI vs. ACIT CPC TDS, GHAZIABAD

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

14 & 2014-15 and prayed for similar decision in the present appeal. 3 I.T.A. No.2015 to 2030/Chny/18 Moreover, the ld. Counsel for the assessee has relied on the following decisions: 1. Smt. G. Indhirani v. DCIT [2015] 60 taxmann.com 312 (Chennai- Trib) 2. Sibia Healthcare (P) Ltd. v. DCIT [2015] 63 taxmann.com 333 (Amritsar-Trib)(TM) 3. Maharashtra Cricket Association

DOLLARS & POUNDS,CHENNAI vs. ACIT CPC TDS, GHAZIABAD

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

14 & 2014-15 and prayed for similar decision in the present appeal. 3 I.T.A. No.2015 to 2030/Chny/18 Moreover, the ld. Counsel for the assessee has relied on the following decisions: 1. Smt. G. Indhirani v. DCIT [2015] 60 taxmann.com 312 (Chennai- Trib) 2. Sibia Healthcare (P) Ltd. v. DCIT [2015] 63 taxmann.com 333 (Amritsar-Trib)(TM) 3. Maharashtra Cricket Association

M/S GOPURAM ENTERPRISES PVT LTD ,CHENNAI vs. ITO , TDS CPC , GHAZIABAD

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

Bench: Shri Aby T. Varkey & Shri Jagadish

10. There is no dispute on the aspect of validity of the Section 234E of the Act. The only issue that has to be decided in the present case is as to whether the late fee can be imposed under Section 234E of the Act, while processing the statement of TDS under Section 200A of the Act for the subject