KELLER GROUND ENGINEERING INDIA PRIVATE LTD,CHENNAI vs. ACIT, CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

section 144C of the Act is invalid in law and should be struck down as much. 2. The draft assessment order, which is in essence the final assessment order, given that the notice of demand had also been issued and penalty has also been initiated, is a patent violation of the provisions of the Act and therefore, the assessment deserved

PANASONIC CORPORATION,HARYANA vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

TDS credit by Panasonic Carbon India and royalty of ₹1,15,84,022/- is remitted back to the file of the Assessing Officer for reconsideration. The Assessing Officer shall re-examine the matter in the light of the material that may be filed by the assessee and thereafter decide the issue afresh in accordance with law, after giving a reasonable

M/S. CASTLEWICK FZE,DUBAI vs. ACIT,INTERNATIONAL TAXATION, CIRCLE-1(1), CHENNAI

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

144C(13) of the Income Tax Act, 1961 (hereinafter\ncalled 'the Act'). The relevant Assessment Year is 2018-19.\n2.\nBrief facts of the case are as follows: The assessee is a\ncompany incorporated in UAE. During the assessment year 2018-19,\nthe assessee was in receipt of income of Rs.90 lakhs from an Indian\ncustomer named M/s. Gannon Dunkerley

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)

144C of the Act dated 31.03.2015. However, the Assessing Officer reopened the assessment by issuing notice under section 148 of the Act. The Assessing Officer recorded the following reasons for reopening of assessment: “On scrutiny of records, it is revealed that the assessee company had claimed a sum of ₹.22,26,10,622/- to M/s. Vasco Luxembourg and ₹.5

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

144C of the Income Tax Act, 1961 (hereinafter the 'Act') for the\n assessment years 2014-15, 2015-16 and 2017-18 dated 29.03.2024,\n29.03.2024 and 29.03.2024 respectively. The CO has been raised by the\nassessee for the A.Y.2015-16 only. Since the facts are common/identical and\nthe issue of assessee's claim of depreciation on goodwill arising on\namalgamation

INTEGRA SOFTWARE SERVICES P. LTD.,CHENNAI vs. DCIT, PONDICHERRY

The appeal stands partly allowed in terms of our above order

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

144C(5) of the Act for the above assessment year is contrary to law, facts, and in the circumstances of the case. 2. The DCIT erred in mechanically adopting the directions of the DRP vide order dated 30.12.2016 in computing the taxable total income for the Assessment Year under consideration without assigning proper reasons and justification. 3. The DCIT failed

DASSAULT SYSTEMES SIMULIA CORP,CHENNAI vs. DCIT (INTERNATIONAL TAX)-1 (1), CHENNAI

The appeal stands allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.349/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Dassault Systemes Simulia Corp, Vs. The Deputy Commissioner Of C/O. Deloitte Haskins & Sells Llp, Income Tax, 7Th Floor, Asv Ramana Towers, International Taxation 1(1) 52,Venkatnarayana Road, Chennai. Chennai 600 017. [Pan: Aadcd 3705D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit. सुनवाई क" तार"ख/Date Of Hearing : 27.08.2024 घोषणा क" तार"ख /Date Of Pronouncement : 28.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

section 144C of the Act. The ld.DRP, vide its directions confirmed the draft assessment order dated 12.12.2023. Aggrieved, assessee preferred an appeal before us. 4. At the outset, the ld.Counsel for the assessee submitted that the issue of denial of Tax Deducted at Source (TDS) credit by the authorities below is covered in favour of assessee by the order

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

5. The assessee filed its return of income for the assessment year 2011-12 on 04.11.2011 admitting a loss of ₹.47,17,77,686/- and the same was processed under section 143(1) of the Act dated 16.08.2012. Subsequently, the case of the assessee was selected for scrutiny under CASS and notice under section 143(2) of the Act dated

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

5. The assessee filed its return of income for the assessment year 2011-12 on 04.11.2011 admitting a loss of ₹.47,17,77,686/- and the same was processed under section 143(1) of the Act dated 16.08.2012. Subsequently, the case of the assessee was selected for scrutiny under CASS and notice under section 143(2) of the Act dated

COASTAL ENERGY PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2305/Chny/2012 िनधा"रण वष"/Assessment Year: 2008-09 Coastal Energy Private Limited, Vs. The Assistant Commissioner Of 5, Buhari Buildings, Moores Road, Income Tax, Thousand Lights, Chennai 600 006. Company Circle I(3), Chennai. [Pan: Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 06.02.2026 आदेश /O R D E R

144C(13) and 92CA(3) of the Act dated 19.10.2012, made an addition of ₹6,05,31,118/- on account of transfer pricing adjustment for international transactions. 28. The ld. AR submits that the assessee had entered into international transactions involving the purchase of coal from its Associated Enterprise (AE). In the course of the transfer pricing assessment

FORD INDIA (P) LTD,CHENNAI vs. DY CIT LTU, CHENNAI

In the result, the assessee’s appeal is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.2344 & 2345/Mds/2012 "नधा*रण वष* /Assessment Year: 2005-06 & 2008-09

144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward3a a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation

FORD INDIA (P) LTD,CHENNAI vs. DY CIT LTU, CHENNAI

In the result, the assessee’s appeal is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.2344 & 2345/Mds/2012 "नधा*रण वष* /Assessment Year: 2005-06 & 2008-09

144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward3a a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation

PRODAPT SOLUTIONS PVT LTD.,CHENNAI vs. DCIT, CHENNAI

In the result the appeal of the assessee is allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./Ita Nos.: 1015/Mds/2015 िनधा"रण वष" / Assessment Years : 2010-11 M/S. Prodapt Solutions Pvt Ltd., The Deputy Commissioner Of No.9, Seshadri Road, V. Income Tax, Alwarpet, Corporate Circle –5(2), Chennai – 600 018. Chennai – 600 034. Pan : Aaacz0985G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri Vivekanandan, Cit सुनवाई क" तार"ख/Date Of Hearing : 24.10.2016 घोषणा क" तार"ख/Date Of Pronouncement : 16.01.2017

144C(13) of the Act passed in pursuance to the directions of the DRP, Chennai in F.No.DRP/CHE/81/2014-15 dated 15.12.2014. 2. The assessee has raised the grounds on CIT(Appeals), 2.1 The Ld. Assessing Officer erred is not considering the fact that the assessee is eligible for deduction under Section 10A of the Income Tax Act, 1961 (in short

VODAFONE MOBILE SERVICES LIMITED,NEW DELHI vs. DCIT, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.587/Chny/2017 िनधा:रण वष: /Assessment Year: 2010-11

144C of the Act. Each of the ground is referred to separately, which may kindly be considered independent of each other. 1. Ground No. 1 Assessment order is bad in law and hence, void-ab- initio. 1.1 On the facts and circumstances of the case and in law, the learned CIT(A) has failed to adjudicate the following ground taken

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 certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

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

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

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

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

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

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell