COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

221 248 Taxman 55 wherein the\nDivision Bench of the Court followed another Division Bench judgment in\nthe case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257\n(Mad.) and held that the view of the Central Board of Direct Taxes in\nCircular No. 5 of 2014 dated 11-2-2014, which has been relied

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

221 248 Taxman 55 wherein the\nDivision Bench of the Court followed another Division Bench judgment in\nthe case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257\n(Mad.) and held that the view of the Central Board of Direct Taxes in\nCircular No. 5 of 2014 dated 11-2-2014, which has been relied

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

221 248 Taxman 55 wherein the\nDivision Bench of the Court followed another Division Bench judgment in\nthe case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257\n(Mad.) and held that the view of the Central Board of Direct Taxes in\nCircular No. 5 of 2014 dated 11-2-2014, which has been relied

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

221 248 Taxman 55 wherein the\nDivision Bench of the Court followed another Division Bench judgment in\nthe case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257\n(Mad.) and held that the view of the Central Board of Direct Taxes in\nCircular No. 5 of 2014 dated 11-2-2014, which has been relied

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

221 248 Taxman 55 wherein the\nDivision Bench of the Court followed another Division Bench judgment in\nthe case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257\n(Mad.) and held that the view of the Central Board of Direct Taxes in\nCircular No. 5 of 2014 dated 11-2-2014, which has been relied

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

221 248 Taxman 55 wherein the\nDivision Bench of the Court followed another Division Bench judgment in\nthe case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257\n(Mad.) and held that the view of the Central Board of Direct Taxes in\nCircular No. 5 of 2014 dated 11-2-2014, which has been relied

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

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

TDS was\nrequired to be deducted on the said payments to Castlewick FZE.\nAccordingly, the A.O. is not justified in holding the appellant as ‘assessee\nin default' u/s.201(1) of the Act. The A.O. is directed to delete the demand\nraised 201(1) of the Act.\n10.\nThe Ld.DR was unable to place on record any material to show\nthat

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

221 248 Taxman 55 wherein the Division Bench of the Court followed another Division Bench judgment in the case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257 (Mad.) and held that the view of the Central Board of Direct Taxes in Circular No. 5 of 2014 dated 11-2-2014, which has been relied by the Tribunal

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

221 248 Taxman 55 wherein the Division Bench of the Court followed another Division Bench judgment in the case of Redington (India) Ltd. v. Addl. CIT [2017] 77 taxmann.com 257 (Mad.) and held that the view of the Central Board of Direct Taxes in Circular No. 5 of 2014 dated 11-2-2014, which has been relied by the Tribunal

DCIT, CHENNAI vs. PARRYWARE ROCA PVT. LTD., CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

TDS under Section 194C of the Act instead of Section 194J of the Act, whether any disallowance can be made under Section 40(a)(ia) of the Act for short deduction of tax? An identical issue was considered by the Cochin Bench of this Tribunal in Apollo Tyres Ltd. v. DCIT in I.T.A. No.31 & 74/Coch/2010 dated 29th

ROCA BATHROOM PRODUCTS PRIVATE LIMITED,CHENNAI vs. JCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

TDS under Section 194C of the Act instead of Section 194J of the Act, whether any disallowance can be made under Section 40(a)(ia) of the Act for short deduction of tax? An identical issue was considered by the Cochin Bench of this Tribunal in Apollo Tyres Ltd. v. DCIT in I.T.A. No.31 & 74/Coch/2010 dated 29th

ACIT, CHENNAI vs. SHREE BALAJI COMMUNICATIONS, CHENNAI

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

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 36/Mds/2015 "नधा"रण वष"/Assessment Year:2010-11 The Assistant Commissioner Of M/S. Shree Balaji Communications, Income Tax, Vs. No. 18/126, Dhan Enclave, Non-Corporate Circle 20, Bhajani Kovil St., Choolaimedu, Chennai 34. Chennai 600 094. [Pan:Abifs0605A]] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Dr. M.M. Bhusari, Cit ""यथ" क" ओर से/Respondent By : Shri M.P. Senthil Kumar, Advocate सुनवाई क" तार"ख/ Date Of Hearing : 26.04.2016 घोषणा क" तार"ख /Date Of Pronouncement : 08.07.2016 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) Iv, Chennai, Dated 16.10.2014 Relevant To The Assessment Year 2010-11. In This Appeal, The Only Effective Ground Raised By The Revenue Is With Regard To Deletion Of Addition Made Under Section 40(A)(Ia) Of The Income Tax Act, 1961 [“Act” In Short] Towards

TDS under section 194J of the Act meant for professional/technical services/royalty. The Assessing Officer disallowed the sum of ₹.1,62,50,000/- by invoking the provisions of section 40(a)(ia) of the Act and added back to the total income of the assessee. The ld. CIT(A) allowed the claim of the assessee by relying on the decision

VNC STEEL DISTRIBUTORS,,KARUR vs. DCIT, CIRCLE-1(1), TRICHY

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1937/Chny/2024 & Stay Petition No: 40/Chny/2024 [In Ita No: 1937/Chny/2024)] िनधा"रणवष" / Assessment Year: 2017-18 Vnc Steel Distributors, Deputy Commissioner Of No.2, Industrial Estate, V. Income Tax, S. Vellalapatti, Circle -1(1), Karur – 639 004. Trichy. [Pan: Aadfv-9137-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Abhinov Vaidyanathan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 21.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 14.11.2024 आदेश /O R D E R

1). The appellant has also claimed that TDS under 194C was not attracted on such payments. The argument of the appellant is not found to be acceptable. It is seen that the payments were made to the contractor for providing manpower. Also, in the present case, the manpower are working in contractual capacity through the contractor. Further, it is seen

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

1,19,15,765 Net Agricultural Income as returned 62,73,280 The AO made addition of deemed dividend u/s.2(22)(e) of the Act amounting to Rs.97,70,661/- in respect of advance received by assessee for supply of raw material and transportation charges and declared as trade advances from the following parties:- (a) Senthil Papain Food Products

DCIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

1,19,15,765 Net Agricultural Income as returned 62,73,280 The AO made addition of deemed dividend u/s.2(22)(e) of the Act amounting to Rs.97,70,661/- in respect of advance received by assessee for supply of raw material and transportation charges and declared as trade advances from the following parties:- (a) Senthil Papain Food Products

ACIT, COIMBATORE vs. SRI M.PALANISAMY, COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

1,19,15,765 Net Agricultural Income as returned 62,73,280 The AO made addition of deemed dividend u/s.2(22)(e) of the Act amounting to Rs.97,70,661/- in respect of advance received by assessee for supply of raw material and transportation charges and declared as trade advances from the following parties:- (a) Senthil Papain Food Products

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

1,19,15,765 Net Agricultural Income as returned 62,73,280 The AO made addition of deemed dividend u/s.2(22)(e) of the Act amounting to Rs.97,70,661/- in respect of advance received by assessee for supply of raw material and transportation charges and declared as trade advances from the following parties:- (a) Senthil Papain Food Products

DCIT, COIMBATORE vs. M/S. SENTHIL PAPAIN & FOOD PRODUCTS PVT. LTD., COIMBATORE

Bench: Shri Mahavir Singh & Shri Manoj Kumar Aggarwalassessment

1,19,15,765 Net Agricultural Income as returned 62,73,280 The AO made addition of deemed dividend u/s.2(22)(e) of the Act amounting to Rs.97,70,661/- in respect of advance received by assessee for supply of raw material and transportation charges and declared as trade advances from the following parties:- (a) Senthil Papain Food Products