ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. IL AND FS TAMILNADU POWER COMPANY LIMITED, CHENNAI

In the result, the appeal of the revenue is partly allowed for\nstatistical purposes

35A; Or\n(iv) the amount of expenditure of a capital nature referred to in clause (ix) of\nsub-section (1) of section 36; or\n(v) the cost of acquisition of a capital asset (not being a capital asset referred\nto in section 50) for the purposes of section 48,\nand the amount arrived at after such addition

NATARAJ RAMAIAH,CHENNAI vs. ITO INTERNATIONAL TAX ATION WARD 2(1), CHENNAI

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 849/Chny/2024 िनधा"रणवष" / Assessment Year: 2015-16 Income Tax Officer, Nataraj Ramaiah, V. International Taxation No. 25, Kothari Road, Ward -2(1), Nungambakkam – 600 034. Chennai – 600 034. [Pan: Aaapr-5280-R] (अपीलाथ"/Assessee) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Assessee By : None ""यथ"क"ओरसे/Respondent By : Shri. G. Suresh, Jcit सुनवाई क" तारीख/Date Of Hearing : 09.07.2024 घोषणा क" तारीख/Date Of Pronouncement : 18.09.2024 आदेश /O R D E R Per S. R. Raghunatha:

gains arising there from to tax by invoking provisions of Section 50C.” 4. The facts as submitted to the Assessing Officer u/s.147 proceedings are as under: (i) During the financial year 2014-15, relevant to the AY 2015-16 i.e. on 25.02.15 the assessee sold 0.77 acres of agricultural land comprised in S.No.252/3 of Aryaperumbakkam Village to M/s. Indo

SELLA SYNERGY INDIA PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

capital gain as per the provisions of sec SOB of the act instead of 'Business Income' assessed by AO. 2.2. The DRP has not verified the facts of the case that of as per copy of business transfer agreement, it is found that what is being transferred by the assessee is the ITA Nos.398, 417, 557/Mds/15 :- 3 -: And C.O.No.45/Mds/2015

DCIT, CHENNAI vs. SELLA SYNERGY INDIA PVT LTD., CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

capital gain as per the provisions of sec SOB of the act instead of 'Business Income' assessed by AO. 2.2. The DRP has not verified the facts of the case that of as per copy of business transfer agreement, it is found that what is being transferred by the assessee is the ITA Nos.398, 417, 557/Mds/15 :- 3 -: And C.O.No.45/Mds/2015

BANCA SELLA S.P.A. CHENNAI BRANCH (IT DIVISION),CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

capital gain as per the provisions of sec SOB of the act instead of 'Business Income' assessed by AO. 2.2. The DRP has not verified the facts of the case that of as per copy of business transfer agreement, it is found that what is being transferred by the assessee is the ITA Nos.398, 417, 557/Mds/15 :- 3 -: And C.O.No.45/Mds/2015

DCIT, CHENNAI vs. EMERALD RESILIENT TYRE MANUFACTURES PVT LTD., CHENNAI

In the result, the Revenue appeal is allowed

Bench: Shri Chandra Poojari & Shri. G. Pavan Kumar

35A; or (iv) the amount of expenditure a/a capital nature referred to in clause (ix) ofsubsection (I) of section 36: or (v) the cost of acquisition of a capital asset (not being a capital asset referred to in section 50)for the pumposes of section 48, and the amount arrived at after such addition or deduction shall be takemz

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

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

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

35A; or (iv) the amount of expenditure of a capital nature referred to in clause (ix) of subsection (1) of section 36; or (v) the cost of acquisition of a capital asset (not being a capital asset referred to in section 50) for the purposes of section 48, and the amount arrived at after such addition or deduction shall

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

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

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

35A; or (iv) the amount of expenditure of a capital nature referred to in clause (ix) of subsection (1) of section 36; or (v) the cost of acquisition of a capital asset (not being a capital asset referred to in section 50) for the purposes of section 48, and the amount arrived at after such addition or deduction shall

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)

capitalized The brief facts as noted are that, the assessee had capitalized The brief facts as noted are that, the assessee had capitalized hedging cost of Rs.4,09,82,305/ hedging cost of Rs.4,09,82,305/- in the books of accounts, but claimed in the books of accounts, but claimed the same as expenditure in the computation of total

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench