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

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

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

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

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

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

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

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

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

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

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

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

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

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. 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

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

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

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

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

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.

148) “.... Income tax is a levy on income. No doubt, the Income Tax Act takes into account two points of time at which the liability to tax is attracted, viz., the accrual of the income or its receipt; but the substance of the matter is the income. If income does not result at all, there cannot be a tax, even

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

2) of Section 151A of the Act, CBDT issued a notification dated 29th March, 2022 [Notification No.18/2022/F. No.370142/16/2022-TPL and formulated a Scheme. The Scheme provides that - (a) the assessment, reassessment or recomputation under Section 147 of the Act, (b) and the issuance of notice under Section 148 of the Act, shall be through automated allocation, in accordance with risk management

MANICKAM CHETTIAR VELMURUGAN,CHENNAI vs. ITO, NCC-19(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

2) of Section 151A of the Act, CBDT issued a notification dated 29th March, 2022 [Notification No.18/2022/F. No.370142/16/2022-TPL and formulated a Scheme. The Scheme provides that - (a) the assessment, reassessment or recomputation under Section 147 of the Act, (b) and the issuance of notice under Section 148 of the Act, shall be through automated allocation, in accordance with risk management

SUPPAHIRE EDUCATIONAL AND CHARITABLE TRUST,THANJAVUR vs. ITO, EXEMPTIONS WARD,, TRICHY

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

2) of Section 151A of the Act, CBDT issued a notification dated 29th March, 2022 [Notification No.18/2022/F. No.370142/16/2022-TPL and formulated a Scheme. The Scheme provides that - (a) the assessment, reassessment or recomputation under Section 147 of the Act, (b) and the issuance of notice under Section 148 of the Act, shall be through automated allocation, in accordance with risk management