SHRIRAM FINANCE LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.173/Chny/2024 िनधा"रण वष"/Assessment Year: 2020-21 Shriram Finance Limited Vs. The Deputy Commissioner Of [Formerly Known As Shriram Transport Income Tax, Finance Company Limited), Corporate Circle 3(1), Sri Towers, Plot No. 14A, South Phase, Chennai. Industrial Estate, Guindy, Chennai 600 017. [Pan: Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.07.2024 घोषणा की तारीख /Date Of Pronouncement : 09.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. Ground No. 1 Is General In Nature & Requires No Adjudication.

section 143(3) of the Act, since no adjudication and in the impugned order. Thus, we direct the ld. CIT(A) to adjudicate the issues relating to addition made towards disallowance of PF, Bonus and interest on cash credit, on merits, by affording an opportunity of being heard to the assessee. Thus, the ground Nos. 13 to 20 raised

CLASSIC LINEN INTERNATIONAL PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, the appeal filed by assessee in iTA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा$रण वष$ /Assessment Year: 2011-12

section 32, the written down value of any asset used for the purposes of the business of the undertaking shall be computed as if the assessee had claimed and been actually allowed the deduction in respect of depreciation for each of the relevant assessment year. (7) The provisions of sub-section (8) and sub-section (10) of section

DCIT,CC-2(1), CHENNAI vs. M/S, JAN DE NUL DREDGING (I)(P)LTD, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.870/Chny/2020 िनधा"रण वष"/Assessment Year: 2011-12 The Deputy Commissioner Of Vs. M/S. Jan De Nul Dredging (I)(P) Ltd., “Capital”, 10Th Floor, No. 554/555, Income Tax, Corporate Circle 2(1), Room No. 511, 5Th Floor, Wanaparthy Mount Road, Chennai 600 018. Block, No. 121, M.G. Road, Chennai 600 034. [Pan:Aaacj6482G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Hema Bhupal, Jcit ""थ" की ओर से/Respondent By : Shri Ashik Shah, C.A. & Ms. C. Sowndarya, C.A. सुनवाई की तारीख/ Date Of Hearing : 02.02.2023 घोषणा की तारीख /Date Of Pronouncement : 08.02.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai, Dated 26.08.2020 Relevant To The Assessment Year 2011-12. 2. Facts Are, In Brief, That The Assessee Is Engaged In The Business Of Dredging Services & Filed Its Return Of Income For The Assessment Year 2011-12 On 30.11.2011 Admitting Total Income Of ₹.3,86,20,850/-. The Return Filed By The Assessee Was Initially Processed Under Section 143(1)

TDS compliance, it means, the details are already filed before the Assessing Officer and the Assessing Officer, by considering the same, the assessment order was 7 I.T.A. No. 870/Chny/20 passed under section 143(3

UCAL LIMITED,CHENNAI vs. PCIT, CHENNAI-3,, CHENNAI

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

3) OF THE ACT :-6-: ITA. No.:1018/Chny/2025 4. 29.06.2021 Notice under Section 143(2) of the Act 163 5. 19.09.2021 Reply to Notice under Section 143(2) of the Act 171 dated 29.06.2021 6. - Details of creditors 179 7. - Details of depreciation 180 8. - Detail of default statement 181 9. - Details of donation for scientific research

DCIT, CIRCLE-1(1),, TRICHY vs. M/S. RAJA TRANSPORTS,, ARIYALUR

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.722/Chny/2020 िनधा"रण वष"/Assessment Years: 2014-15 The Deputy Commissioner Of Vs. M/S. Raja Transports, Income Tax, Circle 1(1), No. 34, Trichy Main Road, No. 44, Williams Road, Cantonment, Ariyalur 621 704. Trichy 620 001. [Pan:Aaefr4385H] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.619/Chny/2020 िनधा"रण वष"/Assessment Years: 2014-15 M/S. Raja Transports, Vs. The Deputy Commissioner Of No. 34, Trichy Main Road, Income Tax, Circle 1(1), Ariyalur 621 704. Trichy 620 001. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By Shri S. Sridhar, Advocate &’ : Shri N. Arjunraj, Ca सुनवाई की तारीख/ Date Of Hearing : 07.12.2022 घोषणा की तारीख /Date Of Pronouncement : 22.02.2023 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Trichy, Dated 19.03.2020 Relevant To The Assessment Year 2014-15. 2

TDS. Hence, as per section 194C of the Act, 30% of ₹.14,78,95,505/- i.e., ₹.4,43,68,652/- was disallowed under section 40(a)(ia) of the Act and added to the total income of the assessee. Accordingly, the assessment was completed under section 143(3

M/S. RAJA TRANSPORTS,,ARIYALUR vs. DCIT, CIRCLE - 1 (1),, TRICHY

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.722/Chny/2020 िनधा"रण वष"/Assessment Years: 2014-15 The Deputy Commissioner Of Vs. M/S. Raja Transports, Income Tax, Circle 1(1), No. 34, Trichy Main Road, No. 44, Williams Road, Cantonment, Ariyalur 621 704. Trichy 620 001. [Pan:Aaefr4385H] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.619/Chny/2020 िनधा"रण वष"/Assessment Years: 2014-15 M/S. Raja Transports, Vs. The Deputy Commissioner Of No. 34, Trichy Main Road, Income Tax, Circle 1(1), Ariyalur 621 704. Trichy 620 001. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Shri Ar V Sreenivasan, Addl. Cit Assessee By Shri S. Sridhar, Advocate &’ : Shri N. Arjunraj, Ca सुनवाई की तारीख/ Date Of Hearing : 07.12.2022 घोषणा की तारीख /Date Of Pronouncement : 22.02.2023 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Trichy, Dated 19.03.2020 Relevant To The Assessment Year 2014-15. 2

TDS. Hence, as per section 194C of the Act, 30% of ₹.14,78,95,505/- i.e., ₹.4,43,68,652/- was disallowed under section 40(a)(ia) of the Act and added to the total income of the assessee. Accordingly, the assessment was completed under section 143(3

MAHAVEER BABULAL JAIN ,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE -5, CHENNAI

In the result, I.T.A. No. 2274/Chny/2017 for AY 2008-09 is dismissed and I

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy

TDS on the application of section 40(a)(ia) of the Act, 2 I.T.A. Nos.2274 & 2275/Chny/17 the assessee also challenged confirmation of disallowance towards loss on account of mutilated notes claimed as expenditure under section 37(1) of the Act for both the assessment years. 2. It was the submissions of the ld. Counsel that the assessee is engaged

MAHAVEER BABULAL JAIN ,CHENNAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE -5, CHENNAI

In the result, I.T.A. No. 2274/Chny/2017 for AY 2008-09 is dismissed and I

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy

TDS on the application of section 40(a)(ia) of the Act, 2 I.T.A. Nos.2274 & 2275/Chny/17 the assessee also challenged confirmation of disallowance towards loss on account of mutilated notes claimed as expenditure under section 37(1) of the Act for both the assessment years. 2. It was the submissions of the ld. Counsel that the assessee is engaged

DCIT, OOTY vs. N.PURUSHOTHAMAN, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

143(3) is not valid.” In view of the above, the CIT(A) agreed with the arguments of the assessee and statement made by the Assessing Officer in remand report that only Rs.16.67 lakhs, out of total disallowance of Rs.1,91,09,889/- made by the Assessing Officer is in cash payment and disallowance can be restricted to this extent

N.PURUSHOTHAMAN,COIMBATORE vs. DCIT, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

143(3) is not valid.” In view of the above, the CIT(A) agreed with the arguments of the assessee and statement made by the Assessing Officer in remand report that only Rs.16.67 lakhs, out of total disallowance of Rs.1,91,09,889/- made by the Assessing Officer is in cash payment and disallowance can be restricted to this extent

SHI vs. U CANADIAN CLEAR WATERS LTD.,CHENNAIVS.DCIT CORPORATE CIRCLE 6(1) , CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं./Ita No.2347/Mds/2017 "नधा"रण वष" / Assessment Year : 2009-10

3 I.T.A. No.2347/Mds/17 period of four years, unless the conditions were complied with for reopening assessment under Section 147 of the Act, the Assessing Officer cannot reopen the assessment. Placing reliance on the judgement of Madras High Court in Tanmac India v. DCIT (2016) 97 CCH 189, the Ld. counsel submitted that on identical circumstances, the Madras High Court found

SMT, RAMU ANNAMALAI UMAIYAL RADHAI,CHENNAI vs. PCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 922/Chny/2020 िनधा"रण वष"/Assessment Year:2015-16 Smt. Ramu Annamalai Umaiyal Radhai, The Principal Commissioner Of Flat No. Iii, 3Rd Floor, Poojapura Vs. Income Tax- Chennai I, Apartments, St. Mary’S Road, Chennai. Alwarpet, Chennai 600 028. [Pan:Aakpu6790M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri V.P. Kuriachan, F.C.A. ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 26.09.2022 घोषणा की तारीख /Date Of Pronouncement : 12.10.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax, Chennai - I, Chennai, Dated 20.05.2020 Relevant To The Assessment Year 2015-16 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

TDS amount 3,50,000 Total 3,50,00,000 5. I have incurred stamp duty, registration charge and other expenses of Rs.32,00,000/- for the flat. Accordingly, the total cost of the flat came to Rs. 3,82,00,000/- . 6. Out of the total purchase consideration of Rs. 3,82,00,000/-, an amount

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

TDS, TCS and advance tax claimed by the Appellant in its return of income.\nThe Appellant craves leave to add, amend, alter, delete, rescind, forgo or withdraw any\nof the above grounds of objection either before or during the course of the CIT (Appeal)\nproceedings in the interest of natural justice.\nITA No.: 1763/CHNY/2024 AY 2017-18\n1. The order

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

143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would be applicable to the transaction of extending guarantee by the appellant to its AE. 23. The Honorable

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would be applicable to the transaction of extending guarantee by the appellant to its AE. 23. The Honorable

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would be applicable to the transaction of extending guarantee by the appellant to its AE. 23. The Honorable

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would be applicable to the transaction of extending guarantee by the appellant to its AE. 23. The Honorable

ELECTRONICS CORPORATION OF TAMILNADU LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1), CHENNAI

In the result, both the appeals filed by the assessee are dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2429 & 2430/Chny/2017 िनधा"रण वष"/Assessment Years: 2001-02 & 2003-04 M/S. Electronics Corporation Of Vs. The Deputy Commissioner Of Tamilnadu Ltd., No. 692, Mhu Income Tax, Complex, Anna Salai, Nandanam, Corporate Circle 2(1), Chennai 600 035. Chennai. [Pan:Aaace1670K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 21.02.2023 घोषणा की तारीख /Date Of Pronouncement : 28.02.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai, Dated 23.06.2017 Relevant To The Assessment Years 2001-02 & 2003-04. The Assessee Has Raised The Following Grounds For The Assessment Year 2001-02: 1. The Order Of The Commissioner Of Income Tax (Appeals) 9, Chennai Dated 23.06.2017 In I.T.A.No.19/Cit(A)-9/2009-10) For The Above Mentioned Assessment Year Is Contrary To Law, Facts & In The Circumstances Of The Case.

section 143(3) of the Act. Further, we find that the case law relied on by the assessee has no application to the facts of the present case as the facts are entirely different. In view of the above, the issue raised by the assessee in ground Nos. 2 & 3 are dismissed. 7. So far as merits of the case

ELECTRONICS CORPORATION OF TAMILNADU LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1), CHENNAI

In the result, both the appeals filed by the assessee are dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.2429 & 2430/Chny/2017 िनधा"रण वष"/Assessment Years: 2001-02 & 2003-04 M/S. Electronics Corporation Of Vs. The Deputy Commissioner Of Tamilnadu Ltd., No. 692, Mhu Income Tax, Complex, Anna Salai, Nandanam, Corporate Circle 2(1), Chennai 600 035. Chennai. [Pan:Aaace1670K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, C.A. ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 21.02.2023 घोषणा की तारीख /Date Of Pronouncement : 28.02.2023 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 9, Chennai, Dated 23.06.2017 Relevant To The Assessment Years 2001-02 & 2003-04. The Assessee Has Raised The Following Grounds For The Assessment Year 2001-02: 1. The Order Of The Commissioner Of Income Tax (Appeals) 9, Chennai Dated 23.06.2017 In I.T.A.No.19/Cit(A)-9/2009-10) For The Above Mentioned Assessment Year Is Contrary To Law, Facts & In The Circumstances Of The Case.

section 143(3) of the Act. Further, we find that the case law relied on by the assessee has no application to the facts of the present case as the facts are entirely different. In view of the above, the issue raised by the assessee in ground Nos. 2 & 3 are dismissed. 7. So far as merits of the case