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

capital account or on revenue account\nirrespective of whether it results in more tax or not. Consequently, the\ntransaction entered by the assessee would fall in the nature of revenue\nreceipt. We are therefore of the considered view that there is no case\nfor any interference to the order of the Ld.CIT(A) at this stage.\nAccordingly, all the grounds

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

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

8D of the Act, amounting to\nRs.271,85283/- without appreciating that as clause (f) of Explanation (1)\nto Section 115JB, such a disallowance is required to be made.\n6. For these grounds and any other ground including amendment of grounds\nthat may be raised during the course of the appeal proceedings, the order\nof ld. CIT(A), with respect

UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

capital gains arising therefrom are exempt under specific provisions of section 10(38) of the Act. The Tribunal further placing reliance on the decision of Hon’ble High Court of Bombay in the case of New India assurance company Limited reported in 254 taxman 238 [Bombay] and letter dated 21.02.2006 issued by the CBDT to IRDA, further, taking into account

FL SMIDTH PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.3423/Chny/2019 िनधा"रण वष"/Assessment Year: 2012-13 M/S. Flsmidth Private Limited, The Assistant Commissioner Of No.34, Egatoor, Kelambakkam, Vs. Income Tax, Rajiv Gandhi Salai, Company Circle – 2 (1), Chennai – 603 103. Chennai – 600 034. [Pan: Aaacf4997N] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri S.P. Chidambaram, Advocate : ""थ" की ओर से/Respondent By Shri M. Rajan, Cit : सुनवाई की तारीख/ Date Of Hearing 01.03.2023 : घोषणा की तारीख /Date Of Pronouncement : 08.03.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-5, Chennai Dated 11.10.2019, Relevant To The Assessment Year 2012–13. The Grounds Raised By The Assessee Are As Under: “1. The Order Of The Commissioner Of Income Tax (Appeals) ['Cit (A)’] Is Contrary To Law, Facts & Circumstances Of The Case. 2. Disallowance Under Section 14A Of The Act Read With Rule 8D 2.1. On Facts & Circumstances Of The Case & In Law, The Learned Cit(A) Erred In Confirming The Action Of The Ao In Making Disallowance Of Rs. 75,94,632 Under Section 14A Read With Rule 8D.

section 14A is unwarranted. 2.5. Without prejudice to the above grounds, the CIT(A) erred in including investments not yielding dividend income while computing the disallowance under Rule 8D. 2.6. The CIT(A) ought to have appreciated that investments in wholly owned subsidiaries have not yielded any dividend income and these subsidiaries have since merged with the Company and hence

UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

capital gains arising therefrom are exempt under\nspecific provisions of section 10(38) of the Act. The Tribunal further\nplacing reliance on the decision of Hon'ble High Court of Bombay in the\ncase of New India assurance company Limited reported in 254 taxman\n238 [Bombay] and letter dated 21.02.2006 issued by the CBDT to IRDA,\nfurther, taking into account

SINDYA SECURITIES AND INVESTMENTS PRIVATE LIMITED,CHENNAI vs. ACIT,CORP.CIRCLE-6[2], CHENNAI

The appeal stand allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.438/Chny/2022 (िनधा*रण वष* / Assessment Year: 2017-18) M/S. Sindya Securities & Investments Pvt. Ltd. Acit बनाम/ No.609, Lakshi Bavan, V Floor Corporate Circle 6(2) Sundaram Avenue, Mount Road Chennai Vs. Nungambakkam, Chennai-600 006. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aalcs-3297-B (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri T. Banusekar (Ca) & Shri Vishwa Padmanabhan,(Ca) - Ld.Ars " थ"कीओरसे/Respondent By : Dr. S. Senthil Kumaran (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 03-08-2023 घोषणाकीतारीख /Date Of Pronouncement : 08-09-2023 आदेश / O R D E R

Section 2(47) exigible to tax u/s 45 of the Act. The cost of the acquisition of the right would be deemed to be ‘nil’ in terms of Sec. 55(2)(b). Therefore, the computations made by the assessee under the head ‘capital gains’ was correct. 4.7 The Ld. AR further submitted that that the provisions

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

capital gains arising therefrom are exempt under\nspecific provisions of section 10(38) of the Act. The Tribunal further\nplacing reliance on the decision of Hon'ble High Court of Bombay in the\ncase of New India assurance company Limited reported in 254 taxman\n238 [Bombay] and letter dated 21.02.2006 issued by the CBDT to IRDA,\nfurther, taking into account

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

capital gains arising therefrom are exempt under\nspecific provisions of section 10(38) of the Act. The Tribunal further\nplacing reliance on the decision of Hon'ble High Court of Bombay in the\ncase of New India assurance company Limited reported in 254 taxman\n238 [Bombay] and letter dated 21.02.2006 issued by the CBDT to IRDA,\nfurther, taking into account

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

capital gains arising therefrom are exempt under\nspecific provisions of section 10(38) of the Act. The Tribunal further\nplacing reliance on the decision of Hon'ble High Court of Bombay in the\ncase of New India assurance company Limited reported in 254 taxman\n238 [Bombay] and letter dated 21.02.2006 issued by the CBDT to IRDA,\nfurther, taking into account

IDFC LIMITED,CHENNAI vs. JCIT-RANGE-II, CHENNAI

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

8D(2)(iii), we note\nthat the AO has disallowed 0.5% of the total average investments of\nRs.2,484.45 crores i.e., Rs.12.42 crores and the Ld. CIT(A) has restricted\nthe same at 3% of the exempt income. We do not countenance such an\naction of the Ld.CIT(A) and is of the opinion that 0.5% of the dividend\nyielding

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)

capital gains, the condition,‘transfer’ of the asset has taken place. 5. The Id. CIT(A) has erred in deleting the disallowance made in the computation of ‘Book Profits’ made u/s.115JB of the Act of the amount of expenditure disallowed u/s.14A r.w.Rule 8D of the Act, amounting to Rs.2,71,85,283/- without appreciating that as clause (f) of Explanation

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)

capital gains, the condition,‘transfer’ of the asset has taken place. 5. The Id. CIT(A) has erred in deleting the disallowance made in the computation of ‘Book Profits’ made u/s.115JB of the Act of the amount of expenditure disallowed u/s.14A r.w.Rule 8D of the Act, amounting to Rs.2,71,85,283/- without appreciating that as clause (f) of Explanation