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

38) of the Act as well as section 14A of the\nAct vide question No. 12(1) and dealt the issue extensively. The reasons\nrecorded by us in the aforementioned paragraphs are equally applicable\nto the present issue for AY 2017-18. Thus, ground Nos. 2 (a) along with 3\nto 7 are allowed.\n42.\nGround Nos. 2(b) along

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

38) of the Act as well as section 14A of the\nAct vide question No. 12(1) and dealt the issue extensively. The reasons\nrecorded by us in the aforementioned paragraphs are equally applicable\nto the present issue for AY 2017-18. Thus, ground Nos. 2 (a) along with 3\nto 7 are allowed.\n42.\nGround Nos. 2(b) along

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

38) of the Act as well as section 14A of the\nAct vide question No. 12(1) and dealt the issue extensively. The reasons\nrecorded by us in the aforementioned paragraphs are equally applicable\nto the present issue for AY 2017-18. Thus, ground Nos. 2 (a) along with 3\nto 7 are allowed.\n42.\nGround Nos. 2(b) along

SIBICHAKRAVATHI TENZINGH,NAMAKKAL vs. ITO, TDS, SALEM

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

38-A, AS Pettai Main Road, TDS, Namakkal District-637 001. Salem. [PAN: APRPC 0189 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.T. S. Lakshmi Venkataraman, CA (by virtual) ""यथ" क" ओर से /Respondent by : Mr.Veeramany.K., IRS : सुनवाईक"तारीख/Date of Hearing 26.08.2025 घोषणाक"तारीख /Date of Pronouncement : 26.08.2025 आदेश

SIBICHAKRAVATHI TENZINGH,NAMAKKAL vs. ITO,TDS,, SALEM

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

38-A, AS Pettai Main Road, TDS, Namakkal District-637 001. Salem. [PAN: APRPC 0189 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.T. S. Lakshmi Venkataraman, CA (by virtual) ""यथ" क" ओर से /Respondent by : Mr.Veeramany.K., IRS : सुनवाईक"तारीख/Date of Hearing 26.08.2025 घोषणाक"तारीख /Date of Pronouncement : 26.08.2025 आदेश

SIBICHAKRAVATHI TENZINGH,NAMAKKAL vs. ITO,TDS,, SALEM

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

38-A, AS Pettai Main Road, TDS, Namakkal District-637 001. Salem. [PAN: APRPC 0189 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.T. S. Lakshmi Venkataraman, CA (by virtual) ""यथ" क" ओर से /Respondent by : Mr.Veeramany.K., IRS : सुनवाईक"तारीख/Date of Hearing 26.08.2025 घोषणाक"तारीख /Date of Pronouncement : 26.08.2025 आदेश

SIBICHAKRAVATHI TENZINGH,NAMAKKAL vs. ITO,TDS,, SALEM

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

38-A, AS Pettai Main Road, TDS, Namakkal District-637 001. Salem. [PAN: APRPC 0189 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.T. S. Lakshmi Venkataraman, CA (by virtual) ""यथ" क" ओर से /Respondent by : Mr.Veeramany.K., IRS : सुनवाईक"तारीख/Date of Hearing 26.08.2025 घोषणाक"तारीख /Date of Pronouncement : 26.08.2025 आदेश

SIBICHAKRAVATHI TENZINGH,NAMAKKAL vs. ITO,TDS, SALEM

In the result, all the appeals filed by the assessee are allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

38-A, AS Pettai Main Road, TDS, Namakkal District-637 001. Salem. [PAN: APRPC 0189 G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.T. S. Lakshmi Venkataraman, CA (by virtual) ""यथ" क" ओर से /Respondent by : Mr.Veeramany.K., IRS : सुनवाईक"तारीख/Date of Hearing 26.08.2025 घोषणाक"तारीख /Date of Pronouncement : 26.08.2025 आदेश

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE CELLULAR LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section 201(1) r.w.s. 194H of the Act, since the assessee has not deducted TDS

BIMETAL BEARINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee for the assessment year

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 668, 669, 670 & 671/Chny/2015 िनधा"रण वष"/Assessment Years:2007-08 To 2010-11 M/S. Bimetal Bearings Limited, The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Large Taxpayer Unit, Coimbatore 641 018. 1775, Jawaharlal Nehru Inner Ring Road, Anna Nagar Western Extension, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.07.2019 घोषणा की तारीख /Date Of Pronouncement : 29.08.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Four Appeals Filed By The Same Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai All Dated 30.01.2015 Relevant To The Assessment Years 2007-08, 2008-09, 2009-10 & 2010-11. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

38,75,992/- respectively. On appeal, the ld. CIT(A) confirmed the disallowances. 2.2.1 We have heard the rival contentions, perused the materials available on record and gone through the orders of authorities below including paper book along with case law filed by the assessee. By referring to the grounds of appeal, where the assessee has relied upon the decisions

BIMETAL BEARINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee for the assessment year

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 668, 669, 670 & 671/Chny/2015 िनधा"रण वष"/Assessment Years:2007-08 To 2010-11 M/S. Bimetal Bearings Limited, The Deputy Commissioner Of 18, Race Course Road, Vs. Income Tax, Large Taxpayer Unit, Coimbatore 641 018. 1775, Jawaharlal Nehru Inner Ring Road, Anna Nagar Western Extension, [Pan:Aaacb2036Q] Chennai 600 101. (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri Ar.V. Sreenivasan, Jcit सुनवाई की तारीख/ Date Of Hearing : 02.07.2019 घोषणा की तारीख /Date Of Pronouncement : 29.08.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Four Appeals Filed By The Same Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 17, Chennai All Dated 30.01.2015 Relevant To The Assessment Years 2007-08, 2008-09, 2009-10 & 2010-11. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

38,75,992/- respectively. On appeal, the ld. CIT(A) confirmed the disallowances. 2.2.1 We have heard the rival contentions, perused the materials available on record and gone through the orders of authorities below including paper book along with case law filed by the assessee. By referring to the grounds of appeal, where the assessee has relied upon the decisions