UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

section 263 of the Act to hold that the\nassessment order was erroneous and prejudicial to the interest of the\nRevenue on this issue. Thus, ground Nos. 2(b) along with 8 raised by the\nassessee are allowed.\n45. Ground Nos. 2(c) along with 9 are relating to income from\nunclaimed amount relating to policy holders.\n46. We note

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

section 263 of the Act to hold that the\nassessment order was erroneous and prejudicial to the interest of the\nRevenue on this issue. Thus, ground Nos. 2(b) along with 8 raised by the\nassessee are allowed.\n45.\nGround Nos. 2(c) along with 9 are relating to income from\nunclaimed amount relating to policy holders.\n46.\nWe note

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

section 263 of the Act to hold that the\nassessment order was erroneous and prejudicial to the interest of the\nRevenue on this issue. Thus, ground Nos. 2(b) along with 8 raised by the\nassessee are allowed.\n45.\nGround Nos. 2(c) along with 9 are relating to income from\nunclaimed amount relating to policy holders.\n46.\nWe note

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

section 263 of the Act to hold that the\nassessment order was erroneous and prejudicial to the interest of the\nRevenue on this issue. Thus, ground Nos. 2(b) along with 8 raised by the\nassessee are allowed.\n45.\nGround Nos. 2(c) along with 9 are relating to income from\nunclaimed amount relating to policy holders.\n46.\nWe note

FAIVELEY TRANSPORT TECHNOLOGIES INDIA PVT. LTD.,HOSUR vs. ACIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

263 of the Act cannot be exercised to substitute his view with that of the view taken by the Ld. AO after detailed inquiry and verification. III. Computation of the eligible business profits for deduction under section 80-IC of the Act ITA No.1598 /Chny/2024 3.1. The Ld. PCIT, in the facts and circumstances of the case

UCAL LIMITED,CHENNAI vs. PCIT, CHENNAI-3,, CHENNAI

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

TDS / TCS 467 18. - Details of acquisition and use of assets 479 19. - Certificate for grant of expenses under Section 481 35(2AB) of the Act 20. 05.03.2022 Notice under Section 142(1) of the Act 485 21. 20.03.2022 Reply to the Notice under Section dated 488 05.03.2022 22. - Details of creditors 491 23. - Legal notices issued by parties

SUNITHA,COIMBATORE vs. PCIT -1, COIM,BATORE

In the result, appeal filed by the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.2013/Chny/2024 (िनधा"रणवष" / Assessment Year: 2018-2019) Sunitha, Vs. The Principal Commissioner Of No.30, Sivaji Colony, Income Tax -1, Thadagam Road, Coimbatore Edayarpalayam, Coimbatore 641 025. [Pan: Bhqps 4789G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N.V. Balaji, Advocate ""यथ" क" ओर से /Respondent By : Shri R. Clement Ramesh Kumar, Irs, Cit. सुनवाई क" तार"ख/Date Of Hearing : 26.11.2024 घोषणा क" तार"ख /Date Of Pronouncement : 10.12.2024 आदेश / O R D E R Per Manu Kumar Giri ()

TDS on rent paid by them. If any communication had bought to my notice earlier i would have taken necessary steps to submit at that relevant point of time. 2. Non-disclosure of loan given in the Income Tax Return (ITR) In ITR-3 of AY 2018-19 the disclosure in Part ABS Sources of Funds 2. Loan funds

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LTD.,CHENNAI vs. ACIT, LARGE TAXPAYER UNIT-1, CHENNAI

Bench: Shri Mahavir Singh, Hon’Ble & Shrimanjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.269/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. M/S.Cognizant Technology- The Asst. Commissioner- Solutions India Pvt. Ltd., Of Income Tax, 5/535, Okkiam, Thoriapakkam, Large Taxpayer Unit-1, Old Mahabalipuram Road, Chennai. Chennai-600 096. [Pan:Aaacd 3312 M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Ajay Vohra, Sr.Counsel For Shri N.V. Balaji, Adv. ""यथ" क" ओर से /Respondent By : Shri R.Shankaranarayanan, Additional Solicitor – General Of India For Shri A.P.Srinivas, Sr. Standing Counsel : सुनवाईक"तारीख/Date Of Hearing 03.07.2023 घोषणाक"तारीख /Date Of Pronouncement : 13.09.2023

section 115-O of the Act and the consequent demand raised by the learned AO are in contravention to the provisions of the Double Taxation Avoidance Agreement ('DTAA') entered by India with USA and Mauritius and the principles laid down by the Hon'ble Supreme Court in UOI vs Azadi Bachao Andolan [2003] 263 ITR 706 (SC). 12. Without prejudice

M/S.MAHOGANY LOGISTICS SERVICES PVT. LTD.,MADURAI vs. PCIT, MADURAI-1

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.1631/Chny/2024 िनधा"रण वष"/Assessment Year: 2018-19 M/S. Mahogany Logistics Services Vs. The Principal Commissioner Of Private Limited, Income Tax-1, 10, Jawahar Road, Chokkikulam, Madurai. Madurai 625 002. [Pan:Aafcd8781R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri S. Senthil Kumaran, Cit सुनवाई की तारीख/ Date Of Hearing : 30.04.2025 घोषणा की तारीख /Date Of Pronouncement : 28.07.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 30.03.2024 Passed By The Ld. Principal Commissioner Of Income Tax 1, Madurai Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short] For The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Company [Earlier Known As M/S. Drsr Logistics Services Private Limited] Filed Its Return Of Income For The Ay 2018-19 Claiming Loss Of ₹.31,28,98,436/- Under 2

2 I.T.A. No.1631/Chny/24 section 139(9) of the Act. The case was selected for complete scrutiny under CASS for the reason to verify the low income in comparison to high loans/investments in shares, lower amount of disallowance under section 40(a)(ia) and demand raised under section 201 of the Act for non- deduction and short deduction of TDS

INDIAN OVERSEAS BANK,CHENNAI vs. DCIT, NON CORPORATE CIRCLE-8(1), CHENNAI

Bench: Ms Padmavathy S, Am & Shri Manu Kumar Giri, Jm

2) to section 263 in assessee's case. The ld. AR submitted that the PCIT has exercised the powers under section 263 in assessee's own case for earlier years on similar grounds and that the Co-ordinate Bench for AY 2019-20 (ITA No. 1569/Chny/2024 dated 18.12.2024) and for AY 2016-17 & 2017-18 (ITA No. 1570 & 1571/Chny/2024 dated

INDIAN OVERSEAS BANK,CHENNAI vs. DCIT, NON CORPORATE CIRCLE-8(1), CHENNAI

Bench: Ms Padmavathy S, Am & Shri Manu Kumar Giri, Jm

2) to section 263 in assessee's case. The ld. AR submitted that the PCIT has exercised the powers under section 263 in assessee's own case for earlier years on similar grounds and that the Co-ordinate Bench for AY 2019-20 (ITA No. 1569/Chny/2024 dated 18.12.2024) and for AY 2016-17 & 2017-18 (ITA No. 1570 & 1571/Chny/2024 dated

THE THANJAVUR DISTRICT CO OP MILK PRODUCERS UNION LIMITED,THANJAVUR vs. ACIT, CIRCLE2(1), TRICHY

In the result, appeal of the Assessee is Allowed

Bench: Shri Mahavir Singh, Vice- & Dr. Dipak P. Ripoteआयकरअपीलसं. / Ita No.404/Chny/2022 िनधा"रणवष" / Assessment Year : 2017-18 The Thanjavur District Co Op The Principal Milk Producers Union Limited, Vs Commissioner Of Income No.1, Nanjikottai Road, Tax-1, Madurai. Thanjavur – 613006. Pan: Aaaat 0224 E Appellant/ Assessee Respondent /Revenue Assessee By K.Meenakshisundaram - Itp Revenue By Shri M.Rajan – Cit(Dr) Date Of Hearing 23/08/2022 Date Of Pronouncement 21/11/2022 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Appellant Assessee Against The Order U/S 263 Of The Income Tax Act (Act) Of The Principal Commissioner Of Income Tax Madurai-1, Dated 26/03/2022 For A.Y. 2017-18. The Assessee Has Raised Following Grounds Of Appeal: “The Order Under Section 263 Of The Income Tax Act Dated 26/3/2022 Received By The Appellant On 1/4/2022 Is Objected To On The Following Grounds Of Appeal. 1. The Learned Principal Commissioner Madurai Erred In Setting Aside The Valid Order Passed By The Assisstant Commissioner Of Income Tax Circle-2(1) Trichy Dated 5/11/2019 For The Assessment Year 2017- 2018 Under Section 263 On Mere Assumptions & Presumptions That The Order Had Been Erroneous & Prejudicial To The Interest Of Revenue. 2. The Learned Principal Commissioner Misdirected Himself That The Valid Order Passed By The Assisstant Commissioner Was Erroneous & Prejudicial To The Interest Of Revenue Simply For The Reason That The

263 on mere assumptions and presumptions that the order had been erroneous and prejudicial to the interest of revenue. 2. The learned Principal Commissioner misdirected himself that the valid order passed by the Assisstant Commissioner was erroneous and prejudicial to the interest of revenue simply for the reason that the ITA No.404/RPR/2022 for A.Y. 2017-18 The Thanjavur District

M/S. CITY UNION BANK,KUMBAKONAM vs. PCIT,, MADURAI

In the result, both the appeals for A

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1478 & 1479/Chny/2025 धनिाारण वर्ा / Assessment Year: 2020-21 & 2021-22 M/S. City Union Bank, Pcit No. 148-149, T.S.R Big Street, Vs. Madurai – 1. Kumbakonam – 621 001. Tamil Nadu. [Pan: Aaacc-1287-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. S. Ananthan, Ca & Ms. R. Lalitha, Ca प्रत्यथी की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit. सुनवाई की तारीख/Date Of Hearing : 28.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 09.09.2025

Section 263 of the Income Tax Act, 1961 and setting aside the Assessment order. 2.1. The Learned Principal Commissioner failed to appreciate the fact that there is no error in the order relating to the issues covered by the notice u/s 263. 2.2. The Learned Principal Commissioner erred in holding that the assessing officer has failed to cause enquiry

M/S. CITY UNION BANK,KUMBAKONAM vs. PCIT,, MADURAI

In the result, both the appeals for A

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.: 1478 & 1479/Chny/2025 धनिाारण वर्ा / Assessment Year: 2020-21 & 2021-22 M/S. City Union Bank, Pcit No. 148-149, T.S.R Big Street, Vs. Madurai – 1. Kumbakonam – 621 001. Tamil Nadu. [Pan: Aaacc-1287-E] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Mr. S. Ananthan, Ca & Ms. R. Lalitha, Ca प्रत्यथी की ओर से/Respondent By : Ms. E. Pavuna Sundari, Cit. सुनवाई की तारीख/Date Of Hearing : 28.08.2025 घोर्णा की तारीख/Date Of Pronouncement : 09.09.2025

Section 263 of the Income Tax Act, 1961 and setting aside the Assessment order. 2.1. The Learned Principal Commissioner failed to appreciate the fact that there is no error in the order relating to the issues covered by the notice u/s 263. 2.2. The Learned Principal Commissioner erred in holding that the assessing officer has failed to cause enquiry

M/S. CITY UNION BANK LTD.,,KUMBAKONAM vs. PCIT,, MADURAI

In the result, the appeal for A

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

2. The Learned Principal Commissioner erred in invoking the provisions of Section 263 of the Income Tax Act, 1961 and partially setting aside the Assessment order. 2.1. The Learned Principal Commissioner erred in holding that the assessing officer has failed to cause enquiry in the assessment proceedings before completion of assessment. 2.2. The Learned Principal Commissioner failed to appreciate

GUARDIAN INDIA OPERATIONS PRIVATE LIMITED,CHENNAI vs. PCIT 1, CHENNAI

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

Bench: HON’BLE SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

TDS return acknowledgement for 106 Form 240, 26Q, and 27Q for all the 4 Quarters (Annexure 2) Show Cause Notice ("SCN") under 118 section 263

DCIT, CHENNAI vs. M/S. UNITED INDIA INSURANCE CO. LTD., CHENNAI

In the result, all the appeals filed by the Revenue for the assessment years 2003-04, 2004-05, 2005-06, 2006-07, 2008-09,

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.:1673, 1688, 1689, 1691/Chny/2011 िनधा"रण वष" / Assessment Years: 2003-04, 2004-05, 2005-06, 2006-07 Assistant Commissioner Of Income M/S. United India Insurance Co. Tax, V. Ltd., Large Tax Payer Unit, 24, Whites Road, Chennai – Chennai. 600 014. [Pan: Aaacu-5552-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos: 1693/Chny/2011, 36/Chny/2014 & 696/Chny/2014 िनधा"रण वष" / Assessment Years: 2008-09, 2009-10 & 2010-11 Deputy Commissioner Of Income M/S. United India Insurance Co. Tax, V. Ltd., Large Tax Payer Unit, 24, Whites Road, Chennai – Chennai. 600 014. [Pan: Aaacu-5552-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee Represented By : Shri. S. Sundararaman, Ca Department Represented By : Shri. M. Swaminathan, Sr.Standing Counsel & Ms. V. Pushpa, Jr. Standing Counsel सुनवाई क" तार"ख/Date Of Hearing : 10.08.2022 घोषणा क" तार"ख/Date Of Pronouncement : 26.08.2022 आदेश /O R D E R

section 195 and the same could not be considered as business expenditure. The CIT(A) held that the payment made to the NRRI was not taxable in India. On appeal by the Revenue, the Mumbai Tribunal, confirmed the order of the CIT(A) and held that the NRRI did not have any PE in India and, therefore, the reinsurance premium

DCIT, CHENNAI vs. M/S. UNITED INDIA INSURANCE CO. LTD., CHENNAI

In the result, all the appeals filed by the Revenue for the assessment years 2003-04, 2004-05, 2005-06, 2006-07, 2008-09,

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.:1673, 1688, 1689, 1691/Chny/2011 िनधा"रण वष" / Assessment Years: 2003-04, 2004-05, 2005-06, 2006-07 Assistant Commissioner Of Income M/S. United India Insurance Co. Tax, V. Ltd., Large Tax Payer Unit, 24, Whites Road, Chennai – Chennai. 600 014. [Pan: Aaacu-5552-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos: 1693/Chny/2011, 36/Chny/2014 & 696/Chny/2014 िनधा"रण वष" / Assessment Years: 2008-09, 2009-10 & 2010-11 Deputy Commissioner Of Income M/S. United India Insurance Co. Tax, V. Ltd., Large Tax Payer Unit, 24, Whites Road, Chennai – Chennai. 600 014. [Pan: Aaacu-5552-C] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee Represented By : Shri. S. Sundararaman, Ca Department Represented By : Shri. M. Swaminathan, Sr.Standing Counsel & Ms. V. Pushpa, Jr. Standing Counsel सुनवाई क" तार"ख/Date Of Hearing : 10.08.2022 घोषणा क" तार"ख/Date Of Pronouncement : 26.08.2022 आदेश /O R D E R

section 195 and the same could not be considered as business expenditure. The CIT(A) held that the payment made to the NRRI was not taxable in India. On appeal by the Revenue, the Mumbai Tribunal, confirmed the order of the CIT(A) and held that the NRRI did not have any PE in India and, therefore, the reinsurance premium