CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

ACIT, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1674, 1675, 1759 & 1676/Chny/2011 "नधा"रण वष" / Assessment Years : 2003-04, 2004-05, 2006-07 & 2007-08 आयकर अपील सं./Ita No.40/Chny/2009 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No.1366/Chny/2013 "नधा"रण वष" / Assessment Year : 2008-09 & आयकर अपील सं./Ita No.2372/Chny/2014 "नधा"रण वष" / Assessment Year : 2009-10 The Deputy Commissioner Of M/S Cholamandalam Ms General Income Tax, V. Insurance Co. Ltd., Dare House, No.2, The Assistant Commissioner Of Nsc Bose Road, Income Tax. Chennai - 600 001. Large Taxpayer Unit, Chennai - 600 101. Pan : Aabcc 6633 K (अपीलाथ"/Appellant) (""यथ"/Respondent)

2(9) of Insurance Act, 1938 as it stood before amendment in 2014, is applicable to the payment of re-insurance premium to non-resident re-insurance company, the assessee is liable to deduct tax. Therefore, the above decisions of Mumbai Bench and Pune Bench of this Tribunal also may not be of any assistance to the assessee

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

ACIT, CHENNAI vs. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

DCIT, CHENNAI vs. M/S. ROYAL SUNDARAM ALLIANCE INSURANCE CO. LTD., CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

M/S. ROYAL SUNDARAM ALLIANCE INSURANCE COMPANY LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by both the Revenue and the assessee are partly allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

143(3) of the Act. Subsequently, notice was issued under Section 148 of the Act within four years for assessment years 2004- 05 and 2005-06. For the assessment year 2002-03, the assessment was reopened beyond four years. For the assessment year 2003-04, the Assessing Officer reopened the assessment for second time after four years. The Madras High

TAMIL NADU BRICK INDUSTRIES,CHENNAI vs. ITO, CHENNAI

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.744/Chny/2017 "नधा"रण वष"/Assessment Year:2013-14 M/S. Tamilnadu Brick Industries, The Income Tax Officer, No. 47, Mangali Nagar 1St Street, Vs. Non Corporate Circle 8(1), Arumbakkam, Chennai 600 106. Chennai. [Pan: Aafft3643P] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri S. Sridhar, Advocate ""यथ" क" ओर से/Respondent By : Shri Vijay Kumar Punna, Jr. Standing Counsel सुनवाई क" तार"ख/ Date Of Hearing : 13.02.2018 घोषणा क" तार"ख /Date Of Pronouncement : 11.05.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai, Dated 27.02.2017 Relevant To The Assessment Year 2013-14. The Assessee Has Raised The Following Grounds: “1. The Order Of The Commissioner Of Income Tax (Appeals) 9, Chennai Dated 27.02.2017 In I.T.A.No.07/Cit(A)-9/2016-17 For The Above Mentioned Assessment Year Is Contrary To Law, Facts & In The Circumstances Of The Case.

143(1) of the income tax act, 1961(herein after referred to as ‘the Act’). The case was selected for scrutiny and the notice u/s.143(2) dated 02.09.2014 was served on the appellant. Subsequently, a notice u/s.142(1) was issued on 25.06.2015 and duly served on the appellant. As per the provisions u/s.2(47)(v) of the Act, read with

VAIDYANATHAN KALAIVANI,CHENNAI vs. PCIT, CHENNAI

Appeal of the assessee stands dismissed

TDS deducted as refund. The Assessing Officer accepted the return. However, the PCIT initiated proceedings under Section 263, holding that the compensation was taxable as 'income from other sources' under Section 56(2)(xi) of the Income Tax Act, 1961, and directed the Assessing Officer to revise the assessment.", "held": "The Tribunal held that the Assessing Officer's original assessment

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

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

143(2), dated 26.08.2019 under section 142(1) and notice dated 19.12.2019 under section 142(1) of the Act, wherein, the Assessing Officer specifically sought information about the claim of exemption under section 10(38) of the Act as well as section 14A of the Act vide question No. 12(1) and dealt the issue extensively. The reasons recorded

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

143(2), dated 26.08.2019 under section 142(1)\nand notice dated 19.12.2019 under section 142(1) of the Act, wherein, the\nAssessing Officer specifically sought information about the claim of\nexemption under section 10(38) of the Act as well as section 14A of the\nAct vide question No. 12(1) and dealt the issue extensively. The reasons\nrecorded