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

TDS on the sale of prepaid recharge coupons as required under section 194H of the Act and the details are as under: Name of the assessee Financial Asstt. Amount year Year Vodafone Cellular Limited 2010-11 2011-12 ₹. 62,99,76,316/- 2009-10 2010-11 ₹. 57,74,75,884/- 2012-13 2013-14 ₹. 70

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

TDS on the sale of prepaid recharge coupons as required under section 194H of the Act and the details are as under: Name of the assessee Financial Asstt. Amount year Year Vodafone Cellular Limited 2010-11 2011-12 ₹. 62,99,76,316/- 2009-10 2010-11 ₹. 57,74,75,884/- 2012-13 2013-14 ₹. 70

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

TDS on the sale of prepaid recharge coupons as required under section 194H of the Act and the details are as under: Name of the assessee Financial Asstt. Amount year Year Vodafone Cellular Limited 2010-11 2011-12 ₹. 62,99,76,316/- 2009-10 2010-11 ₹. 57,74,75,884/- 2012-13 2013-14 ₹. 70

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

TDS on the sale of prepaid recharge coupons as required under section 194H of the Act and the details are as under: Name of the assessee Financial Asstt. Amount year Year Vodafone Cellular Limited 2010-11 2011-12 ₹. 62,99,76,316/- 2009-10 2010-11 ₹. 57,74,75,884/- 2012-13 2013-14 ₹. 70

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

TDS on the sale of prepaid recharge coupons as required under section 194H of the Act and the details are as under: Name of the assessee Financial Asstt. Amount year Year Vodafone Cellular Limited 2010-11 2011-12 ₹. 62,99,76,316/- 2009-10 2010-11 ₹. 57,74,75,884/- 2012-13 2013-14 ₹. 70

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

TDS on the sale of prepaid recharge coupons as required under section 194H of the Act and the details are as under: Name of the assessee Financial Asstt. Amount year Year Vodafone Cellular Limited 2010-11 2011-12 ₹. 62,99,76,316/- 2009-10 2010-11 ₹. 57,74,75,884/- 2012-13 2013-14 ₹. 70

M/S. BINNY LIMITED,CHENNAI vs. DCIT, TDS,CIRCLE -1(1), CHENNAI

In the result the\norder of Ld

TDS survey was conducted upon its\npremise on 26.10.2021. During the course of the survey it was noted\nthat the assessee had entered into a transaction for purchase of land\nadmeasuring about 7.07 acres of land during financial year with one M/s.\nMohan Breweries and distilleries Limited(MBDL), a sister concern of the\nassessee. For the purpose the assessee

M/S. BINNY LIMITED,CHENNAI vs. DCIT,TDS, CIRCLE-1(1), CHENNAI

In the result the\norder of Ld

TDS survey was conducted upon its\npremise on 26.10.2021.\nDuring the course of the survey it was noted\nthat the assessee had entered into a transaction for purchase of land\nadmeasuring about 7.07 acres of land during financial year with one M/s.\nMohan Breweries and distilleries Limited(MBDL), a sister concern of the\nassessee. For the purpose the assessee

ITO CORPORATE WARD 4(1), CHENNAI vs. MALAR ENERGY & INFRASTRUCTURE PVT LTD., CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.1417/Chny/2019 िनधा"रण वष"/Assessment Year:2013-14 The Income Tax Officer, M/S. Malar Energy & Infrastructure Corporate Ward 4(1), Vs. Pvt. Ltd., No. 57, Pantheon Road, Chennai 600 034. Egmore, Chennai 600 008. [Pan:Aagcm5674F] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri A. Sundararajan, Addl. Cit ""थ" की ओर से/Respondent By : None सुनवाई की तारीख/ Date Of Hearing : 03.03.2020 घोषणा की तारीख /Date Of Pronouncement : 13.03.2020 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) 8, Chennai Dated 30.01.2019 Relevant To The Assessment Year 2013-14. The Effective Ground Raised By The Revenue Is That The Ld. Cit(A) Has Erred In Restricting The Addition/Disallowance Made Under Section 40(A)(Ia) Of The Income Tax Act, 1961 [“Act” In Short] With Respect To The Tds Default Under Section 194C & 194H Of The Act To ₹.7,29,898/- Instead Of ₹.3,03,28,445/- By Considering Fresh Evidence In Violation Of Rule 46A Of The It Rules.

70,755/- after making various additions. On appeal, after considering the submissions of the assessee, the ld. CIT(A) restricted the disallowance made under section 40(a)(ia) of the Act with respect to the TDS

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION 1(1), CHENNAI

In the result, all the appeals filed by the assessee are partly allowed\nand the Stay Applications filed by the assessee are dismissed

TDS liability also on the\nsaid amount actually paid and interest under section 201(1A) of the Act is\nliable to be paid on ₹.1,18,63,000/-. Therefore, the sum of ₹.14,23,560/-\ncalculated in para 11 of the order under section 201(1A) of the Act on\n₹.1,18,63,000/- is confirmed. Thus, the grounds

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 1(1), CHENNAI

In the result, all the appeals filed by the assessee are partly allowed\nand the Stay Applications filed by the assessee are dismissed

TDS liability also on the\nsaid amount actually paid and interest under section 201(1A) of the Act is\nliable to be paid on ₹.1,18,63,000/-. Therefore, the sum of ₹.14,23,560/-\ncalculated in para 11 of the order under section 201(1A) of the Act on\n₹.1,18,63,000/- is confirmed. Thus, the grounds

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

TDS certificate deducting tax u/s 194A treating it as an interest. Therefore, the A O taxed the proportionate interest of Rs.30,10,00,000/- as income of the assessee. 4. Before the ld CIT(A) , the assessee submitted that its intention was to derive value of a large project and M/s Sahara India Commercial Corporation Ltd. decided not to sell

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION 1(1), CHENNAI

In the result, all the appeals filed by the assessee are partly allowed and the Stay Applications filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.2201 & 2202, 2203 & 2204, 2205, 2209, 2211 & 2212, 2213 & 2214 & 2215/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2020-21, 2021-22, 2015- 16, 2018-19 & 2019-20 & S.A. Nos. 65, 66, 67, 68, 69, 70, 71, 72, 73, 74 & 75/Chny/2024 [In I.T.A. Nos.2201, 2202, 2203, 2204, 2205, 2209, 2211, 2212, 2213, 2214 & 2215/Chny/2024] Cognizant Technology Solutions India Vs. The Deputy Commissioner Of Private Limited, No. 5/535, Okkiyam Income Tax, Thoraipakkam, Old Mahabalipuram Circle 1(1), Road, Chennai 600 097. Chennai. [Pan:Aaacd3312M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri C. Murugesan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.11.2024 & 03.12.2024 घोषणा की तारीख /Date Of Pronouncement : 22.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Eleven Appeals Filed By The Assessee Are Directed Against Separate, But, Identical Orders Passed By The Ld. Commissioner Of Income Tax (Appeals)-18, Chennai For The Assessment Years Mentioned Hereinabove. Out Of The Above Appeals, The Appeals In Ita Nos. 2201/Chny/2024, 2203/Chny/2024, 2205/Chny/2024, 2209/Chny/2024

70, 71, 72, 73, 74 & 75/Chny/24 A survey was conducted on 21.02.2022 under section 133A(2A) of the Act at its office situated at Menon Eternity Building, Alwarpet, Chennai. A statement of Mr. V.N. Achutarama Gupta, AVP–Taxation of the assessee company was recorded and the Assessing Officer found non-deduction of TDS

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, TDS CIRCLE 1(1), CHENNAI

In the result, all the appeals filed by the assessee are partly allowed and the Stay Applications filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.2201 & 2202, 2203 & 2204, 2205, 2209, 2211 & 2212, 2213 & 2214 & 2215/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2020-21, 2021-22, 2015- 16, 2018-19 & 2019-20 & S.A. Nos. 65, 66, 67, 68, 69, 70, 71, 72, 73, 74 & 75/Chny/2024 [In I.T.A. Nos.2201, 2202, 2203, 2204, 2205, 2209, 2211, 2212, 2213, 2214 & 2215/Chny/2024] Cognizant Technology Solutions India Vs. The Deputy Commissioner Of Private Limited, No. 5/535, Okkiyam Income Tax, Thoraipakkam, Old Mahabalipuram Circle 1(1), Road, Chennai 600 097. Chennai. [Pan:Aaacd3312M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri C. Murugesan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.11.2024 & 03.12.2024 घोषणा की तारीख /Date Of Pronouncement : 22.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Eleven Appeals Filed By The Assessee Are Directed Against Separate, But, Identical Orders Passed By The Ld. Commissioner Of Income Tax (Appeals)-18, Chennai For The Assessment Years Mentioned Hereinabove. Out Of The Above Appeals, The Appeals In Ita Nos. 2201/Chny/2024, 2203/Chny/2024, 2205/Chny/2024, 2209/Chny/2024

70, 71, 72, 73, 74 & 75/Chny/24 A survey was conducted on 21.02.2022 under section 133A(2A) of the Act at its office situated at Menon Eternity Building, Alwarpet, Chennai. A statement of Mr. V.N. Achutarama Gupta, AVP–Taxation of the assessee company was recorded and the Assessing Officer found non-deduction of TDS

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION 1(1), CHENNAI

In the result, all the appeals filed by the assessee are partly allowed and the Stay Applications filed by the assessee are dismissed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.2201 & 2202, 2203 & 2204, 2205, 2209, 2211 & 2212, 2213 & 2214 & 2215/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2020-21, 2021-22, 2015- 16, 2018-19 & 2019-20 & S.A. Nos. 65, 66, 67, 68, 69, 70, 71, 72, 73, 74 & 75/Chny/2024 [In I.T.A. Nos.2201, 2202, 2203, 2204, 2205, 2209, 2211, 2212, 2213, 2214 & 2215/Chny/2024] Cognizant Technology Solutions India Vs. The Deputy Commissioner Of Private Limited, No. 5/535, Okkiyam Income Tax, Thoraipakkam, Old Mahabalipuram Circle 1(1), Road, Chennai 600 097. Chennai. [Pan:Aaacd3312M] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N.V. Balaji, Advocate ""थ" की ओर से/Respondent By : Shri C. Murugesan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 27.11.2024 & 03.12.2024 घोषणा की तारीख /Date Of Pronouncement : 22.01.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Eleven Appeals Filed By The Assessee Are Directed Against Separate, But, Identical Orders Passed By The Ld. Commissioner Of Income Tax (Appeals)-18, Chennai For The Assessment Years Mentioned Hereinabove. Out Of The Above Appeals, The Appeals In Ita Nos. 2201/Chny/2024, 2203/Chny/2024, 2205/Chny/2024, 2209/Chny/2024

70, 71, 72, 73, 74 & 75/Chny/24 A survey was conducted on 21.02.2022 under section 133A(2A) of the Act at its office situated at Menon Eternity Building, Alwarpet, Chennai. A statement of Mr. V.N. Achutarama Gupta, AVP–Taxation of the assessee company was recorded and the Assessing Officer found non-deduction of TDS