ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

2(b) to section\n43(6) of the Act, as per which, since the Goodwill was never recorded in the books and\ntherefore, the assessee was not eligible for depreciation.\nix. For these and other grounds that may be adduced at the time of hearing, it is prayed\nthat the order of the learned CIT(A) may be set aside

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

2(b) to section\n43(6) of the Act, as per which, since the Goodwill was never recorded in the books and\ntherefore, the assessee was not eligible for depreciation.\nix. For these and other grounds that may be adduced at the time of hearing, it is prayed\nthat the order of the learned CIT(A) may be set aside

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

2(b) to section\n43(6) of the Act, as per which, since the Goodwill was never recorded in the books and\ntherefore, the assessee was not eligible for depreciation.\nix. For these and other grounds that may be adduced at the time of hearing, it is prayed\nthat the order of the learned CIT(A) may be set aside

COASTAL ENERGY PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2305/Chny/2012 िनधा"रण वष"/Assessment Year: 2008-09 Coastal Energy Private Limited, Vs. The Assistant Commissioner Of 5, Buhari Buildings, Moores Road, Income Tax, Thousand Lights, Chennai 600 006. Company Circle I(3), Chennai. [Pan: Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 06.02.2026 आदेश /O R D E R

92C(2) of the Act. 29. The DRP in its direction to Assessing Officer dated 31.08.2012, allowed the benefit of the credit notes except in one case where the credit note was erroneously dated before the date of invoice. In this regard, the ld. AR submits that the DRP/Assessing Officer has erred both in law and on facts by disregarding

DCIT, CENTRAL CIRCLE-1 (3), CHENNAI vs. TRIMEX INDUSTRIES PRIVATE LIMITED, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

2) of section 92C of the Act. Once this is a fact, we find no infirmity in the order of CIT(A) and hence, we confirm the same. This issue of Revenue’s appeal is dismissed. 19. The next issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the disallowance of expenses made

TRIMEX INDUSTRIES PRIVATE LIMITED,CHENNAI vs. ACIT, CENTRAL CIRCLE-IV(3), CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

2) of section 92C of the Act. Once this is a fact, we find no infirmity in the order of CIT(A) and hence, we confirm the same. This issue of Revenue’s appeal is dismissed. 19. The next issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the disallowance of expenses made

DCIT, CENTRAL CIRCLE-1 (3), CHENNAI vs. TRIMEX INDUSTRIES PRIVATE LIMITED, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

2) of section 92C of the Act. Once this is a fact, we find no infirmity in the order of CIT(A) and hence, we confirm the same. This issue of Revenue’s appeal is dismissed. 19. The next issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the disallowance of expenses made

LITE-ON MOBILE INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, appeal filed by the assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.3194 & 478/Chny/2017 ("नधा"रणवष" / Assessment Years: (2013-14 & 2012-13) M/S. Lite-On Mobile India Pvt.Ltd. Vs The Deputy Commissioner Of Nokia Telecom Special Economic Zone, Income Tax, Plot No.1A, Sipcot Industrial Park, Corporate Circle-4(1) Phase-Iii Chennai-Bangalore Highway, Chennai-600 034. Sriperumbudur, Kancheepuram Dist. Pin- 602 105. Pan: Aadcp 9246K (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 92C of the Act read with Rule 10B of the Rules; • without considering several judicial precedents which have held that the Ld. TPO cannot determine the ALP of a said transaction to be at NIL. Without prejudice to the above grounds, the Ld. DRP, the Ld. TPO and the Ld. AO erred in making a downward adjustment amounting

LITE-ON MOBILE INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT CORPORATE CIRCLE 4(1), CHENNAI

In the result, appeal filed by the assessee for assessment

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.3194 & 478/Chny/2017 ("नधा"रणवष" / Assessment Years: (2013-14 & 2012-13) M/S. Lite-On Mobile India Pvt.Ltd. Vs The Deputy Commissioner Of Nokia Telecom Special Economic Zone, Income Tax, Plot No.1A, Sipcot Industrial Park, Corporate Circle-4(1) Phase-Iii Chennai-Bangalore Highway, Chennai-600 034. Sriperumbudur, Kancheepuram Dist. Pin- 602 105. Pan: Aadcp 9246K (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 92C of the Act read with Rule 10B of the Rules; • without considering several judicial precedents which have held that the Ld. TPO cannot determine the ALP of a said transaction to be at NIL. Without prejudice to the above grounds, the Ld. DRP, the Ld. TPO and the Ld. AO erred in making a downward adjustment amounting

ORCHID PHARMA LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.73/Chny/2017 निर्ाारण वर्ा /Assessment Years: 2012-13

2)(i) of the US regulation the combined effect of two or more separate transactions may be considered if such transactions taken as a whole are interrelated. It thus postulates that transactions are to be aggregated when they involve related product / services. We have also noted that the Hon’ble Coordinate Bench of this tribunal in the case of Mainetti

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

92C of the Act. In response to the same, the TPO passed order vide C.R.No.A-103/TPO-I/A.Y.2007-08 dated 16.09.2010 stating that there was an adjustment of "7,95,069/- for the current year. Accordingly, the AO issued show cause notice to the assessee why the above adjustment on the international transaction with the associated enterprises should not be added

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

92C of the Act. In response to the same, the TPO passed order vide C.R.No.A-103/TPO-I/A.Y.2007-08 dated 16.09.2010 stating that there was an adjustment of "7,95,069/- for the current year. Accordingly, the AO issued show cause notice to the assessee why the above adjustment on the international transaction with the associated enterprises should not be added

ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

92C of the Act. In response to the same, the TPO passed order vide C.R.No.A-103/TPO-I/A.Y.2007-08 dated 16.09.2010 stating that there was an adjustment of "7,95,069/- for the current year. Accordingly, the AO issued show cause notice to the assessee why the above adjustment on the international transaction with the associated enterprises should not be added

HSI AUTOMOTIVES PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपील सं./I.T.A No.:276/Chny/2017 िनधा"रण वष"/Assessment Year: 2012 - 2013 & आयकर अपील सं./I.T.A No.:3011/Chny/2017 िनधा"रण वष"/Assessment Year: 2013 - 2014

Section 92C(2) of the Act, the standard deduction of +/- 5% should be allowed. 3. In Corporate Tax, the following issues were added, such as payment of Provident Fund and Employees State Insurance, Guarantee Fee payment and applicability of TDS

H S I AUTOMOTIVES PRIVATE LIMITED,KANCHEEPURAM vs. DCIT CORPORATE CIRCLE 2(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपील सं./I.T.A No.:276/Chny/2017 िनधा"रण वष"/Assessment Year: 2012 - 2013 & आयकर अपील सं./I.T.A No.:3011/Chny/2017 िनधा"रण वष"/Assessment Year: 2013 - 2014

Section 92C(2) of the Act, the standard deduction of +/- 5% should be allowed. 3. In Corporate Tax, the following issues were added, such as payment of Provident Fund and Employees State Insurance, Guarantee Fee payment and applicability of TDS

EVERSENDAI CONSTRUCTION PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1), CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2084/Chny/2017 िनधा"रण वष" /Assessment Year: 2013-14 M/S.Eversendai Construction- V. The Dy. Commissioner- Pvt. Ltd., Of Income Tax, Plot No.1 & 2, The Lords, Corporate Circle-2(1), Block-1, 5Th Floor, Chennai. Thiru-Vi-Ka Industrial Estate, Jawaharlal Nehru Road, Ekkaduthangal, Guindy, Chennai.

sections (1) and (2) of 92C. Hence an adjustment amounting to Rs.85,15,716 is to be made to the sales of the international transactions. 5. Pursuant to the TPO order u/s.92CA(3) of the Act, dated 28.10.2016, the AO has passed draft assessment order u/s.143(3) r.w.s.144C(1) of the Act, on 30.06.2017 and proposed TP adjustment as suggested

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

2 is held in favour of the assessee. Hence, the appeal of the Revenue ITA.No.1040/Hyd/2011 is dismissed and Assessee’s appeal in ITA.No.1159/Hyd/2011 is allowed.” 20.5.2 (Jaipur) ITA No. 376/JP/2012] wherein held that:- “2.9 We have heard the rival contentions and perused the material available on record. In our considered view, there is no infirmity in the order

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

2 is held in favour of the assessee. Hence, the appeal of the Revenue ITA.No.1040/Hyd/2011 is dismissed and Assessee’s appeal in ITA.No.1159/Hyd/2011 is allowed.” 20.5.2 (Jaipur) ITA No. 376/JP/2012] wherein held that:- “2.9 We have heard the rival contentions and perused the material available on record. In our considered view, there is no infirmity in the order