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

Gains. 3.8 In the result, the appeal of the Revenue in ITA No.557/Mds/2015 of assessment 2010-2011 is dismissed. C.O.No.45/Mds/2015 in ITA No.557/Mds/2015:- The 4. assessee has filed the Cross objection and raised the following grounds:- 1 The learned AO/TPO/DRP ought to have appreciated that the customer of the assessee had decided to carry on business by itself through

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

Gains. 3.8 In the result, the appeal of the Revenue in ITA No.557/Mds/2015 of assessment 2010-2011 is dismissed. C.O.No.45/Mds/2015 in ITA No.557/Mds/2015:- The 4. assessee has filed the Cross objection and raised the following grounds:- 1 The learned AO/TPO/DRP ought to have appreciated that the customer of the assessee had decided to carry on business by itself through

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...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

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...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

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...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

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...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

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...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT NON CORP CIRCLE 8(1), , CHENNAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 609/Chny/2024 िनधा"रणवष" / Assessment Year: 2016-17 Deputy Commissioner Of Income M/S. Hyundai Motor India V. Tax, Limited, Non Corporate Circle – 8(1), Plot No. H-1, Sipcot Chennai – 600 034. Industrial Park, Irungatukottai, Sriperumbudurtaluk, Kancheepuram District, Tamil Nadu – 602 117. [Pan: Aaach-2364-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nanda Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 घोषणा क" तार"ख/Date Of Pronouncement : 21.08.2024 आदेश /O R D E R

92A to 92F of the Income :-3-: ITA. No:609/Chny/2024 Tax Act, 1961. The case was taken up for scrutiny and during the course of assessment proceedings; a reference was made to JCIT (Transfer Pricing) for determination of arm’s length price of international transactions of the assessee with its AEs. The learned TPO vide its order dated