ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nआयकर अपील सं./ITA No.1402/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nM/s. Ashok Leyland Ltd.,\nNo.1, Sardar Patel Road,\nGuindy, Chennai-600 032.\n[PAN: AAAСА 4651 L]\n(अपीलार्थी/Appellant)\nv.\nThe DCIT,\nNCC-8(1),\nLTU-II,\nChennai.\n(प्रत्यर्थी/Respondent)\nआयकर अपील सं./ITA No.1663/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nThe DCIT,\nNCC-8,\nChennai.\n(अपीलार्थी/Appellant)\nv.\nM/s. Ashok Leyl

Section 80-IA(8)\nof the Act. According to us, the sale price cannot further be segregated\nby imputing price attributable to marketing and R&D efforts for the\nsimple reason that there is no such provision contained in law. We agree\nwith the Ld. AR that, the method of computation to be adopted by the\nassessee, in line with

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

In the result, the appeal of the assessee is dismissed

80G of the Act. The Ld.Counsel\nfor the assessee fairly conceded that in its own case for AY 2013-14 a\nCoordinate Bench of this Tribunal passed an order against it. It was\ncontended that the Ld.CIT(E) while denying the benefit of exemption also\nrelied upon the order vide ITA No.164/Chny/2024 dated 10.07.2024 in\nassessee's own case

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

M/S AVM CHARITIES,CHENNAI vs. ITO,EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

M/S AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

M/S. A V M CHARITIES,CHENNAI vs. ITO, EXEMPTIONS WARD-1, CHENNAI, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

AVM CHARITIES,CHENNAI vs. ITO, EXEMPTION WARD, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

M/S AVM CHARITIES ,CHENNAI vs. ITO,EXEMPTIONS WARD-1, CHENNAI

In the result, appeals filed by the assessee for AYs 2012-13 to 2014-15 are allowed and appeals filed by the assessee for AYs 2015-16 to 2018-19 are partly allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Ble

5. Consequent to survey u/s.133A of the Act, the assessment for AYs 2012-13 to 2016-17, have been re-opened u/s.147 of the Act, for reasons ITA Nos.1632 to 1638/Chny/2023 :: 6 :: recorded, as per which, any income chargeable to tax had been escaped assessment on account of under assessment of rental income from letting out of property to M/s.CFD

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Capital/ Reserves/Loan/\nCurrent Liabilities\nLiabilities (Credit)\nImmoveable Property/ Loans &\nAdvances/ Shares/ Bank Balance\n21. The above view of ours get bolstered from reading of Explanation 2\nappended to the fourth proviso, which defines 'asset', for the purpose of\nfourth proviso to Section 153A, to include i) immovable property, ii)\nshares and securities iii) loans and advances & iv) Deposit in bank

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the appeals filed by the Revenue and the\nassessee are dismissed

Capital/ Reserves/Loan/\nCurrent Liabilities\nLiabilities (Credit)\nImmoveable Property/ Loans &\nAdvances/ Shares/ Bank Balance\n21. The above view of ours get bolstered from reading of Explanation 2\nappended to the fourth proviso, which defines 'asset', for the purpose of\nfourth proviso to Section 153A, to include i) immovable property, ii)\nshares and securities iii) loans and advances & iv) Deposit in bank

SOUTHERN AGRIFURANE INDUSTRIES PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(2),, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

80G / 80GGB, disallowance u/s 14A of the Act and disallowance of certain items of expenses. 14A of the Act and disallowance of certain items of expenses. 14A of the Act and disallowance of certain items of expenses. 3. Aggrieved by the ab Aggrieved by the above order(s) of the AO, the assessee preferred ove order

DCIT CC 2 2 , CHENNAI, CHENNAI vs. SOUTHERN AGRIFURANE INDUSTRIES PVT LTD, CHENNAI

In the result, both the both the appeals filed by the Revenue and the Revenue and the

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

80G / 80GGB, disallowance u/s 14A of the Act and disallowance of certain items of expenses. 14A of the Act and disallowance of certain items of expenses. 14A of the Act and disallowance of certain items of expenses. 3. Aggrieved by the ab Aggrieved by the above order(s) of the AO, the assessee preferred ove order