BIMETAL BEARINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee for the assessment year

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 668, 669, 670 & 671/Chny/2015 िनधा"रण वष"/Assessment Years:2007-08 To 2010-11 M/S. Bimetal Bearings Limited, The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Large Taxpayer Unit, Coimbatore 641 018. 1775, Jawaharlal Nehru Inner Ring Road, Anna Nagar Western Extension, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.07.2019 घोषणा की तारीख /Date Of Pronouncement : 29.08.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Four Appeals Filed By The Same Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai All Dated 30.01.2015 Relevant To The Assessment Years 2007-08, 2008-09, 2009-10 & 2010-11. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

TDS under section 194H of the Act in view of the decision of various Benches of the Tribunal as well as the decision in the case of CIT v. United Breweries Ltd. (supra). Accordingly, the addition made under section 40(a)(ia) of the Act stands deleted for all the assessment years under appeal. 9. The next ground raised

BIMETAL BEARINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee for the assessment year

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 668, 669, 670 & 671/Chny/2015 िनधा"रण वष"/Assessment Years:2007-08 To 2010-11 M/S. Bimetal Bearings Limited, The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Large Taxpayer Unit, Coimbatore 641 018. 1775, Jawaharlal Nehru Inner Ring Road, Anna Nagar Western Extension, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.07.2019 घोषणा की तारीख /Date Of Pronouncement : 29.08.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Four Appeals Filed By The Same Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai All Dated 30.01.2015 Relevant To The Assessment Years 2007-08, 2008-09, 2009-10 & 2010-11. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

TDS under section 194H of the Act in view of the decision of various Benches of the Tribunal as well as the decision in the case of CIT v. United Breweries Ltd. (supra). Accordingly, the addition made under section 40(a)(ia) of the Act stands deleted for all the assessment years under appeal. 9. The next ground raised

BIMETAL BEARINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee for the assessment year

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 668, 669, 670 & 671/Chny/2015 िनधा"रण वष"/Assessment Years:2007-08 To 2010-11 M/S. Bimetal Bearings Limited, The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Large Taxpayer Unit, Coimbatore 641 018. 1775, Jawaharlal Nehru Inner Ring Road, Anna Nagar Western Extension, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.07.2019 घोषणा की तारीख /Date Of Pronouncement : 29.08.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Four Appeals Filed By The Same Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai All Dated 30.01.2015 Relevant To The Assessment Years 2007-08, 2008-09, 2009-10 & 2010-11. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

TDS under section 194H of the Act in view of the decision of various Benches of the Tribunal as well as the decision in the case of CIT v. United Breweries Ltd. (supra). Accordingly, the addition made under section 40(a)(ia) of the Act stands deleted for all the assessment years under appeal. 9. The next ground raised

FUJI ELECTRIC INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI

In the result the appeal of the Assessee is partly allowed for statistical purposes

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

TDS are not allowable. Against the final assessment order, now the Assessee is agitating both the aforesaid issues before us and the Ld.AR submitted as under: “Background of Business Operations • The Appellant is engaged in the manufacture, sale, and trading of power backup and power conditioning products, including Stabilizers, Transformers, UPS (Single and Three Phase), Inverters, Solar Power Generating Systems

P.S.JAGDISH,CHENNAI vs. DCIT CORPORATE CIRCLE 2(2), CHENNAI

In the result, both the appeals of the assessees are allowed

TDS was claimed at Rs.42,75,145/-. This return of income was processed u/s.143(1) of the Act by CPC, Bengaluru vide intimation dated 05.03.2012. The assessee moved rectification application vide petition dated 13.08.2014 and reminder to the letter on 25.04.2016. The AO carried out rectification vide order dated 20.06.2016. Now, the ld.counsel stated that as per the provisions

P.S.SHEKAR,CHENNAI vs. DCIT CORPORATE CIRCLE 2(2), CHENNAI

In the result, both the appeals of the assessees are allowed

TDS was claimed at Rs.42,75,145/-. This return of income was processed u/s.143(1) of the Act by CPC, Bengaluru vide intimation dated 05.03.2012. The assessee moved rectification application vide petition dated 13.08.2014 and reminder to the letter on 25.04.2016. The AO carried out rectification vide order dated 20.06.2016. Now, the ld.counsel stated that as per the provisions

DY. COMMISSIONER OF INCOME TAX , CHENNAI vs. NAPC PVT. LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Section 145 of the Act and allegations made in\nthe AO's order is dehors the facts.\n9.6 Further, it is noted that the Assessee has furnished the\ndetails of all the projects giving true picture of turnover and the\ncorresponding loss / profit earned in the respective projects in\nthe consolidated statement showing the percentage of\ncompletion method by offering

MAYAJAAL ENTERTAINMENT LIMITED,CHENNAI vs. DCIT CPC, BANGALORE

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

145 whereby provisions of that section are made applicable to block assessments is made clarificatory and would take effect retrospectively from 1st day of July, 1995. When it comes to amendment to Section 113 of the Act, this very circular provides that the said amendment along with amendments in Section 158BE, would be prospective i.e. it will take effect from

SHRI. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

TDS u/s194C. The details of said transactions are summarized in the following table. Date of Nature of Name of the Amount Date of Mode of transaction Expenditure Party Payment Payment 02.08.2018 Electrical NR Projects 2,64,67,334 04.08.2018 Through Utility shifting Bank charges 28.02.2019 Electrical NSS 2,05,85,080 01.03.2019 Through Utility shifting Infrastructure Bank charges

SHIR. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

TDS u/s194C. The details of said transactions are summarized in the following table. Date of Nature of Name of the Amount Date of Mode of transaction Expenditure Party Payment Payment 02.08.2018 Electrical NR Projects 2,64,67,334 04.08.2018 Through Utility shifting Bank charges 28.02.2019 Electrical NSS 2,05,85,080 01.03.2019 Through Utility shifting Infrastructure Bank charges

SHRI. IRULANDI THEVAR VETRIVEL ,MADURAI vs. ACIT, CENTRAL CIRCLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

TDS u/s194C. The details of said transactions are summarized in the following table. Date of Nature of Name of the Amount Date of Mode of transaction Expenditure Party Payment Payment 02.08.2018 Electrical NR Projects 2,64,67,334 04.08.2018 Through Utility shifting Bank charges 28.02.2019 Electrical NSS 2,05,85,080 01.03.2019 Through Utility shifting Infrastructure Bank charges

SHRI. IRULANDI THEVAR VETRIVEL,MADURAI vs. ACIT, CENTRAL CRICLE 2, MADURAI, MADURAI

In the result, all the appeals of the Revenue are dismissed and the appeals of the assessee are partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

TDS u/s194C. The details of said transactions are summarized in the following table. Date of Nature of Name of the Amount Date of Mode of transaction Expenditure Party Payment Payment 02.08.2018 Electrical NR Projects 2,64,67,334 04.08.2018 Through Utility shifting Bank charges 28.02.2019 Electrical NSS 2,05,85,080 01.03.2019 Through Utility shifting Infrastructure Bank charges

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

145\n(SC) in terms of which, expenditure incurred by an assessee carrying on a\ncomposite business giving rise to both taxable as well as non-taxable\nincome, was allowable in entirety without apportionment. It was thus that\ns.14A was inserted providing that no deduction shall be allowable in respect\nof expenditure incurred in relation to the earning of income

DCIT, CHENNAI vs. BSR BUILDERS ENGINEERS CONTRACTORS, CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS was deducted thereon under the provisions of section 194A of the ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 27 :: Act, due to which the AO disallowed 30% of the expenditure i.e. Rs.11,49,997/- u/s 40(a)(ia) of the Act. Aggrieved, assessee preferred an appeal

ACIT, CHENNAI vs. M/S. BSR BUILDERS ENGINEERS CONTRACTORS , CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS was deducted thereon under the provisions of section 194A of the ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 27 :: Act, due to which the AO disallowed 30% of the expenditure i.e. Rs.11,49,997/- u/s 40(a)(ia) of the Act. Aggrieved, assessee preferred an appeal

BSR BUILDERS ENGINEERS CONTRACTORS,,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS was deducted thereon under the provisions of section 194A of the ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 27 :: Act, due to which the AO disallowed 30% of the expenditure i.e. Rs.11,49,997/- u/s 40(a)(ia) of the Act. Aggrieved, assessee preferred an appeal

BSR BUILDERS ENGINEERS CONTRACTORS, ,CHENNAI vs. DCIT, CENT. CIRCLE-2(3), CHENNAI

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS was deducted thereon under the provisions of section 194A of the ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 27 :: Act, due to which the AO disallowed 30% of the expenditure i.e. Rs.11,49,997/- u/s 40(a)(ia) of the Act. Aggrieved, assessee preferred an appeal

M/S. BIMETEL BEARINGS LTD.,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 2111/Mds/2016 "नधा"रण वष"/Assessment Year:2011-12 M/S. Bimetal Bearings Ltd., The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Coimbatore 641 018. Large Taxpayer Unit Ii, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""यथ"/Respondent) आयकर अपील सं./I T.A. No. 2357/Mds/2016 "नधा"रण वष"/Assessment Year:2011-12 The Deputy Commissioner Of M/S. Bimetal Bearings Ltd., Income Tax, Large Taxpayer Unit 2, 18, Race Course Road, Vs. Chennai 600 101. Coimbatore 641 018. (अपीलाथ" /Appellant) (""यथ"/Respondent) Assessee By : Shri R. Vijayaraghavan, Advocate Department By : Shri A.V. Sreekanth, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 25.04.2017 घोषणा क" तार"ख /Date Of Pronouncement : 28.06.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: These Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals) 17

145(2) of the Act in respect of Accounting Standard to be followed by all assessees following mercantile system of accounting. Clause 4(i) of this notification states as under: “Prudence – Provisions should be made for all known liabilities and losses even though the amount cannot be determined with certainty and represents only a best estimate in the light

DCIT, CHENNAI vs. M/S. BIMETAL BEARINGS LTD., COIMBATORE

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 2111/Mds/2016 "नधा"रण वष"/Assessment Year:2011-12 M/S. Bimetal Bearings Ltd., The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Coimbatore 641 018. Large Taxpayer Unit Ii, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""यथ"/Respondent) आयकर अपील सं./I T.A. No. 2357/Mds/2016 "नधा"रण वष"/Assessment Year:2011-12 The Deputy Commissioner Of M/S. Bimetal Bearings Ltd., Income Tax, Large Taxpayer Unit 2, 18, Race Course Road, Vs. Chennai 600 101. Coimbatore 641 018. (अपीलाथ" /Appellant) (""यथ"/Respondent) Assessee By : Shri R. Vijayaraghavan, Advocate Department By : Shri A.V. Sreekanth, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 25.04.2017 घोषणा क" तार"ख /Date Of Pronouncement : 28.06.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: These Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Commissioner Of Income Tax (Appeals) 17

145(2) of the Act in respect of Accounting Standard to be followed by all assessees following mercantile system of accounting. Clause 4(i) of this notification states as under: “Prudence – Provisions should be made for all known liabilities and losses even though the amount cannot be determined with certainty and represents only a best estimate in the light