COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 10A/ 10AA of the Act is infructuous and accordingly, dismissed. 23. Accordingly, the Grounds of appeal are partly allowed for A.Y. 2010-11 to A.Y.2012-13 and on the very same reasoning, similar grounds raised by the Assessee in other appeals as noted in the chart supra stands partly allowed. - 34 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

PATCHIRAJAN LAKSHMANAN,MADURAI vs. PCIT, MADURAI

In the result, appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 597/Chny/2020 िनधा"रणवष" / Assessment Year: 2015-16 The Principal Commissioner Of Patchirajan Lakshmanan, V. Income Tax, No. 102F,/16Z/3, Maduari -1, Dhanasekaran Nagar, Madurai – 625 002. Polepettai (West) – 628 002. [Pan:Aazpl-1396-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S. Sridhar, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nandakumar, Cit सुनवाई क" तारीख/Date Of Hearing : 01.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 28.06.2024 आदेश /O R D E R

section 263 would be justified in view of the decision of the Hon'ble Punjab & Haryana High Court in the case of CIT Vs Raja Industries (340 ITR 344).” 9. Aggrieved by the impugned action of the Ld.PCIT passing the impugned order on 24.03.2020, the assessee is in appeal before this Tribunal and has raised a legal issue, wherein

REVATHI SAMUEL,SALEM vs. THE INCOME TAX OFFICER, INTERNATIONAL TAXATION-2(1), CHENNAI

In the result, the appeal of the assessee in ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1285/Chny/2023 (िनधा"रणवष" / Assessment Year: 2020-21) Revathi Samuel, Vs. The Income Tax Officer, 10A, Ramakrishna Road, International Taxation 2(1) Sreerangapalayam, Chennai. Salem 636 007. [Pan: Acxps 8637C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. G. Baskar, Advocate ""यथ" क" ओर से /Respondent By : Shri. Arv Srinivasan, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 14.05.2024 घोषणा क" तार"ख /Date Of Pronouncement : 21.05.2024 आदेश / O R D E R Per Manu Kumar Giri ()

10A, Ramakrishna Road, International Taxation 2(1) Sreerangapalayam, Chennai. Salem 636 007. [PAN: ACXPS 8637C] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Shri. G. Baskar, Advocate ""यथ" क" ओर से /Respondent by : Shri. ARV Srinivasan, Addl. CIT. सुनवाई क" तार"ख/Date of Hearing : 14.05.2024 घोषणा क" तार"ख /Date of Pronouncement : 21.05.2024 आदेश

TITAN COMPANY LIMITED,HOSUR vs. ASSISTANT COMMISSIONER OF INCOME TAX - LTU 2 (IC), CHENNAI

In the result the appeal raised by the assessee is partly allowed

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1742/Chny/2024 निर्धारण वर्ा /Assessment Years: 2011-12 Titan Company Limited, Assistant Commissioner Of No.3, Sipcot Industrial Complex, Income Tax, Hosur, Krishnagiri, Ltu-2, Tamil Nadu-635126 Chennai [Pan: Aaact5131A] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Abhay Kumar, C.A अपीलार्थी की ओर से/ Assessee By : Ms.Komali Krishna, Cit प्रत्यर्थी की ओर से /Revenue By सुनवाई की तारीख/Date Of Hearing : 10.09.2024 घोषणा की तारीख /Date Of Pronouncement : 04.12.2024

10A, 10B etc. of the Act, the same shall be allowed in computing the total income of the assessee." On perusal of the said circular, it is noted that the said circular is in the context of Section 10A/10B of the Act. It does not discuss the implications of the deeming provisions laid down in the Section

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

gains on such reasonable basis as he may deem fit. [Explanation.—For the purposes of this sub-section, "market value", in relation to any goods or services, means— (i) the price that such goods or services would ordinarily fetch in the open market; or (ii) the arm's length price as defined in clause (ii) of section 92F, where

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

gains on such reasonable basis as he may deem fit. [Explanation.—For the purposes of this sub-section, "market value", in relation to any goods or services, means— (i) the price that such goods or services would ordinarily fetch in the open market; or (ii) the arm's length price as defined in clause (ii) of section 92F, where

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Jagadish

10A. The assessee's application for registration under section 12A was rejected by the CIT. The CIT had observed that the various clauses of the Memorandum of the company would clearly show that the assessee had a motive of profit also, along with the stated motive of service to the poor and needy people as claimed by the assessee

M/S. INNOVATIVE MICRFINANCE FOR POVERTY ALLEVIATION & COMMUNITY TRANSFORMATION,CHENNAI vs. CIT, EXEMPTIONS,, CHENNAI

In the result, the appeal of the assessee is dismissed

10A. The assessee's application for\nregistration under section 12A was rejected by the CIT. The CIT had observed that\nthe various clauses of the Memorandum of the company would clearly show that\nthe assessee had a motive of profit also, along with the stated motive of service to\nthe poor and needy people as claimed by the assessee

M/S. R R INDUSTRIES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

In the result, appeals filed by the assessee are allowed

capital gains in its return and attached a summary of total income\nadjusting profit on the LTCG & STCG; and even at that stage, didn't\nbother to file revised return. Considering the aforesaid facts, the Hon'ble\nHigh Court wondered as to how the assessee while responding to the\npenalty notice dated 12.03.2015, could have asserted that there

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeal of the assessee for AY 2017-18 is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1667, 1668, 1669 & 1670/Chny/2024 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2017-18 & 2018-19 D.A.V. Educational Trust, Vs. The Income Tax Officer, 5, S V Illam, Mohanapuri Lake View Exemption Ward 4, Street, Adambakkam, Chennai. Chennai 600 088. [Pan: Aaatc5967A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri A. Satyaseelan, Advocate ""थ" की ओर से/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाई की तारीख/ Date Of Hearing : 28.10.2025 घोषणा की तारीख /Date Of Pronouncement : 21.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Appeals Filed By The Assessee Are Directed Against The Orders All Dated 05.04.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Years 2014-15, 2015-16, 2017-18 & 2018-19. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

10A vide his order dated 30.11.2016 and referred to page 82 of the paper book. He vehemently argued that the Assessing Officer, considering all the details, accepted the returned income and formed an opinion that the assessee was eligible for claiming exemption under section 11 of the Act during scrutiny assessment. He further argued that after considering the assessee

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-4,, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

10A vide his order dated\n30.11.2016 and referred to page 82 of the paper book. He vehemently\nargued that the Assessing Officer, considering all the details, accepted\nthe returned income and formed an opinion that the assessee was eligible\nfor claiming exemption under section 11 of the Act during scrutiny\nassessment. He further argued that after considering the assessee

D.A.V. EDUCATIONAL TRUST,CHENNAI vs. ITO, EXEMPTION WARD-2, CHENNAI

In the result, the appeals filed by the assessee for AY 2014-15,\n2017-18 & 2018-19 are allowed and the appeal for AY 2015-16 is partly\nallowed

10A vide his order dated\n30.11.2016 and referred to page 82 of the paper book. He vehemently\nargued that the Assessing Officer, considering all the details, accepted\nthe returned income and formed an opinion that the assessee was eligible\nfor claiming exemption under section 11 of the Act during scrutiny\nassessment. He further argued that after considering the assessee