DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year, unless any income chargeable

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

153\nreferred to as the relevant assessment year): Provided that where an assessment\nunder sub-section (3) of section 143 or this section has been made for the relevant\n assessment year, no action shall be taken under this section after the expiry of\nfour years from the end of the relevant assessment year, unless any income\nchargeable

RANE ENGINE VALVE LTD,CHENNAI vs. DCIT CORPORATE CIRCLE-5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS provisions are concerned especially in view of the amendment of Section 195, Explanation 2 of the Act. Therefore, he confirmed the disallowance. Aggrieved, assessee is in appeal before the Tribunal. 6.3 Before us, the ld.counsel for the assessee stated that the company is exporting their products, being automobile components, to the clients at Germany mostly to M/s. Volkswagen

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS provisions are concerned especially in view of the amendment of Section 195, Explanation 2 of the Act. Therefore, he confirmed the disallowance. Aggrieved, assessee is in appeal before the Tribunal. 6.3 Before us, the ld.counsel for the assessee stated that the company is exporting their products, being automobile components, to the clients at Germany mostly to M/s. Volkswagen

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS provisions are concerned especially in view of the amendment of Section 195, Explanation 2 of the Act. Therefore, he confirmed the disallowance. Aggrieved, assessee is in appeal before the Tribunal. 6.3 Before us, the ld.counsel for the assessee stated that the company is exporting their products, being automobile components, to the clients at Germany mostly to M/s. Volkswagen

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5 (1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS provisions are concerned especially in view of the amendment of Section 195, Explanation 2 of the Act. Therefore, he confirmed the disallowance. Aggrieved, assessee is in appeal before the Tribunal. 6.3 Before us, the ld.counsel for the assessee stated that the company is exporting their products, being automobile components, to the clients at Germany mostly to M/s. Volkswagen

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

TDS provisions are concerned especially in view of the amendment of Section 195, Explanation 2 of the Act. Therefore, he confirmed the disallowance. Aggrieved, assessee is in appeal before the Tribunal. 6.3 Before us, the ld.counsel for the assessee stated that the company is exporting their products, being automobile components, to the clients at Germany mostly to M/s. Volkswagen

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

TDS without any further delay. This ground is allowed for statistical purposes. 19. The next ground is related to levy of interest u/s 234D to the extent of 6,10,636. 20. The Assessing Officer is directed to examine the applicability of interest u/s 234D and levy correct amount of interest. 21. In the result, the appeal of the assessee

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

TDS without any further delay. This ground is allowed for statistical purposes. 19. The next ground is related to levy of interest u/s 234D to the extent of 6,10,636. 20. The Assessing Officer is directed to examine the applicability of interest u/s 234D and levy correct amount of interest. 21. In the result, the appeal of the assessee

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

TDS without any further delay. This ground is allowed for statistical purposes. 19. The next ground is related to levy of interest u/s 234D to the extent of 6,10,636. 20. The Assessing Officer is directed to examine the applicability of interest u/s 234D and levy correct amount of interest. 21. In the result, the appeal of the assessee

M/S METAL IMPEX,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(1), CHENNAI

In the result, all the appeals in ITA Nos

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.799 To 805/Chny/2024 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2016-17 To 2020-21 V. M/S. Metal Impex, The Acit, The Lattice, 4Th Floor, Central Circle-1(1), No.20 Waddles Road, Chennai. Kilpauk, Chennai-600 010. [Pan: Aamfm 4856 G] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 153-C of the Act, the High Court has rightly set aside the Assessment Order(s). Therefore, the impugned judgment and order(s) passed by the High Court do not require any interference by this Court. Hence, all these appeals deserve to the dismissed and are accordingly dismissed.” In light of the above judicial precedents, we hold that