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 u/s.195 of the Act and thereby invoking the provisions of section 40(a)(i) of the Act. The ld.counsel for the assessee as well as the ld. Senior DR agreed that facts and circumstances are exactly identical in all the five years and grounds raised are also identical. Hence, we will take the facts and grounds from assessment year

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 u/s.195 of the Act and thereby invoking the provisions of section 40(a)(i) of the Act. The ld.counsel for the assessee as well as the ld. Senior DR agreed that facts and circumstances are exactly identical in all the five years and grounds raised are also identical. Hence, we will take the facts and grounds from assessment year

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 u/s.195 of the Act and thereby invoking the provisions of section 40(a)(i) of the Act. The ld.counsel for the assessee as well as the ld. Senior DR agreed that facts and circumstances are exactly identical in all the five years and grounds raised are also identical. Hence, we will take the facts and grounds from assessment year

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 u/s.195 of the Act and thereby invoking the provisions of section 40(a)(i) of the Act. The ld.counsel for the assessee as well as the ld. Senior DR agreed that facts and circumstances are exactly identical in all the five years and grounds raised are also identical. Hence, we will take the facts and grounds from assessment year

RANE ENGINE VALVE LTD,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 u/s.195 of the Act and thereby invoking the provisions of section 40(a)(i) of the Act. The ld.counsel for the assessee as well as the ld. Senior DR agreed that facts and circumstances are exactly identical in all the five years and grounds raised are also identical. Hence, we will take the facts and grounds from assessment year

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

4. The brief facts of the case insofar the cross appeals for the block period under consideration in IT(SS)A No.153 & 162/Mds/2003 are as follows: The assessee is a Managing Director of M/s.Pentafour Products Limited, receiving income under the head “Salary”, dividend income as well as the sitting fees during the block period. The Income Tax Department had conducted

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

4. The brief facts of the case insofar the cross appeals for the block period under consideration in IT(SS)A No.153 & 162/Mds/2003 are as follows: The assessee is a Managing Director of M/s.Pentafour Products Limited, receiving income under the head “Salary”, dividend income as well as the sitting fees during the block period. The Income Tax Department had conducted

SAME DEUTZ FAHR ITALIA SPA,ITALY vs. ASSISTANT COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

TDS obligation on the part of the assessee in view of the fact that the payees do not have any permanent establishment in India. Finally, Ld. AR has submitted that no services have been rendered to the assessee rather the technical services, if any, has been rendered to overseas customers by the non-resident distributors. .. . .. . .. . The services have been carried

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

4. The substantial questions of law raised for consideration were answered against the Revenue in the case of Marg Ltd. v. CIT [2020] 120 taxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the judgment reads as follows: "9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd. [TCA Nos.732

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

4. The substantial questions of law raised for consideration were answered against the Revenue in the case of Marg Ltd. v. CIT [2020] 120 taxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the judgment reads as follows: "9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd. [TCA Nos.732

ACIT CORPORATE CIRCLE-6(2), CHENNAI vs. S V GLOBAL MILL LTD, CHENNAI

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

Bench: Shri Mahavir Singhand Shri G. Manjunathaआयकर अपील सं./Ita No.: 2684/Chny/2019 िनधा"रण वष" / Assessment Year: 2016-17 The Acit, M/S. Sv Global Mill Ltd., Corporate Circle 6(2), V. New No.5/1, Old No.3/1, 6Th Cross Street, Cit Colony, Chennai. Mylapore, Chennai – 600 004. Pan: Aaocs2500E (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Suresh Periasamy,Jcit ""यथ" क" ओर से/Respondent By : Shri B. Ramakrishnan, Fca सुनवाई क" तार"ख/Date Of Hearing : 30.12.2020 घोषणा क" तार"ख/Date Of Pronouncement : 28.01.2021

120/-. 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the CIT(A). Before the CIT(A), the assessee has filed detailed written submissions which shall be reproduced at para 4.2 on page 4 to 14 of ld.CIT(A)’s order. The sum and substance of the arguments of the assessee before the ld.CIT

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n\n"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n\"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

4. The substantial questions of law raised for consideration were answered\nagainst the Revenue in the case of Marg Ltd. v. CIT [2020] 120\ntaxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the\njudgment reads as follows:\n\n"9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd.\n[TCA Nos.732