SUNDARAM CLAYTON LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, appeals filed by Revenue and the assessee

Bench: Shri V.Durga Rao & Shri G.Manjunatha

32(1)(iia) of the Act where the asset is acquired and put to use by the assessee for the purpose of business for a period of less one hundred and eighty days in that previous year deduction under this subsection shall be restricted to fifty per cent of such asset. 3.8) The Ld CIT(A) ought to have appreciated

SUNDARAM CLAYTON LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, appeals filed by Revenue and the assessee

Bench: Shri V.Durga Rao & Shri G.Manjunatha

32(1)(iia) of the Act where the asset is acquired and put to use by the assessee for the purpose of business for a period of less one hundred and eighty days in that previous year deduction under this subsection shall be restricted to fifty per cent of such asset. 3.8) The Ld CIT(A) ought to have appreciated

TURBO ENERGY LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

DCIT, CHENNAI vs. TURBO ENERGY LIMITED, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

DCIT, CHENNAI vs. M/S. TURBO ENERGEY LIMITED, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

DCIT, CHENNAI vs. M/S. TURBO ENERGEY LIMITED, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

TURBO ENERGY LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

TURBO ENERGY LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

DCIT, CHENNAI vs. M/S. TURBO ENERGEY LIMITED, CHENNAI

In the result, the appeals of the assessee are partly allowed and the

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.351/Mds/2013 & Ita Nos.316 & 317/Mds/2014 िनधा"रण वष" /Assessment Year: 2007-08 & Ays 2008-09 & 2009-10

section 32(1)(iia) which allows additional depreciation as a onetime measure only in the year. 10.2 We heard the rival submissions and perused the material placed on record. 10.3 The issue is squarely covered in favour of the assesse by the following judicial pronouncements: • Devi Polymers (ITA No.165/Mds/2014) (Chennai) • SIL Investments (26 Taxmann.com 78) (Del) • MITC Rolling (ITA No.2789/Mum/2012

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS has to be deducted or not when the commission payment made to the overseas or not when the commission payment made to the overseas or not when the commission payment made to the overseas agents, the isuse is squarely covered in favour of the assessee by the isuse is squarely covered in favour of the assessee by the isuse

M/S. BRAKES INDIA LTD.,CHENNAI vs. DCIT LARGE TAX PAYER UNIT-2, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.Ita Nos. 1543, 1544 & 1545/Chny/2019 "नधा"रणवष" / Assessment Years : 2012-13, 2013-14 & 2014-15

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which

M/S. BRAKES INDIA LTD.,CHENNAI vs. DCIT LARGE TAX PAYER UNIT-2, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.Ita Nos. 1543, 1544 & 1545/Chny/2019 "नधा"रणवष" / Assessment Years : 2012-13, 2013-14 & 2014-15

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which

JCIT LARGE TAXPAYER UNIT-2, CHENNAI vs. M/S. BRAKES INDIA LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.Ita Nos. 1543, 1544 & 1545/Chny/2019 "नधा"रणवष" / Assessment Years : 2012-13, 2013-14 & 2014-15

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which

JCIT LARGE TAXPAYER UNIT-2, CHENNAI vs. M/S. BRAKES INDIA LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.Ita Nos. 1543, 1544 & 1545/Chny/2019 "नधा"रणवष" / Assessment Years : 2012-13, 2013-14 & 2014-15

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which

JCIT LARGE TAXPAYER UNIT-2, CHENNAI vs. M/S. BRAKES INDIA LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.Ita Nos. 1543, 1544 & 1545/Chny/2019 "नधा"रणवष" / Assessment Years : 2012-13, 2013-14 & 2014-15

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which

M/S. BRAKES INDIA LTD.,CHENNAI vs. DCIT LARGE TAX PAYER UNIT-2, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.Ita Nos. 1543, 1544 & 1545/Chny/2019 "नधा"रणवष" / Assessment Years : 2012-13, 2013-14 & 2014-15

Section 32 (1) (iia). The said clause (iia), admittedly, was inserted by virtue of the Finance (No.2) Act, 2002, with effect from 01.04.2003. 8.2.In so far as the second Circular is concerned, i.e, Circular no.8 of 2002 dated 27.08.2002, in our view, in no way, helps the case of the Revenue. The Circular does not dwell on the point which

CRAFTSMAN AUTOMATION LTD.,COIMBATORE vs. ACIT,CC-2, COIMBATORE

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.177/Chny/2021 िनधा"रण वष"/Assessment Year: 2015-16 Craftsman Automation Ltd., Vs. The Assistant Commissioner Of ‘Senthel Towers’, 4Th Floor, Income Tax, 1078, Avinashi Road, Corporate Circle 2, Coimbatore 641 018. Coimbatore 641 018. [Pan:Aabcc2461K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaragahavan, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.03.2023 घोषणा की तारीख /Date Of Pronouncement : 24.03.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Principal Commissioner Of Income Tax-1, Coimbatore, Dated 30.03.2021 Relevant To The Assessment Year 2015-16 Passed Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

iia) to section 32(1) of the Act has retrospective application, we are of the considered opinion that the Assessing Officer has rightly allowed the claim of additional depreciation to the assessee. Therefore, the ld. PCIT was not correct in holding that the claim is only allowable prospectively and thus, the order passed under section

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TDS. 31. On appeal, the CIT(A) noted that out of the total disallowance of ₹.87,77,367/-, the assessee incurred an amount of ₹.55,97,827/- towards sales promotion and sales commission outside India, a sum of ₹.5,90,886/- was paid towards professional charges (legal and consultancy) and an amount of ₹.25,97,654/- was paid towards market