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

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

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

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

Capital\nIQ (India) (P.) Ltd. (supra) and the Bangalore Bench of the ITAT in the case of\nI & B Seeds (P.) Ltd. (supra) held that by way of amendment through Finance\nAct, 2021 clause (b) of Section 2(11) of the Act was amended and the goodwill\nof the business or profession is excluded from the block of assets comprised

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

Capital\nIQ (India) (P.) Ltd. (supra) and the Bangalore Bench of the ITAT in the case of\nI & B Seeds (P.) Ltd. (supra) held that by way of amendment through Finance\nAct, 2021 clause (b) of Section 2(11) of the Act was amended and the goodwill\nof the business or profession is excluded from the block of assets comprised

M/S T vs. MOTOR COMPANY LIMITED,CHENNAIVS.ACIT CORPORATE CIRCLE 3 (1), CHENNAI

In the result, the appeal of the Revenue and the assessee are\ndecided as under:-\n\n| ITA Nos\n| Assessment\nYear\nResult\n| IT(TP)A No

gains of business or profession within the\npurview of section 28 to 41 of the Act. The definitions contain therein\nare important since the same are not available in any other part of the\nAct.\nThus, section 43(3) supra provides that \"plant” includes \"books”.\nWe have also noted that Hon'ble Apex Court in its decision in the case

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

Capital\nIQ (India) (P.) Ltd. (supra) and the Bangalore Bench of the ITAT in the case of\nI & B Seeds (P.) Ltd. (supra) held that by way of amendment through Finance\nAct, 2021 clause (b) of Section 2(11) of the Act was amended and the goodwill\nof the business or profession is excluded from the block of assets comprised

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...

gain in increasing the value of the company. Thus, this support and loyalty becomes an intangible asset for the company which gets accumulated every year 8. The TPO then noted that the assessee had the brand value of Hyundai, as evident from the ‘Interbrand’ valuation- which is one off the most respected brand valuation worldwide, the Hyundai

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...

gain in increasing the value of the company. Thus, this support and loyalty becomes an intangible asset for the company which gets accumulated every year 8. The TPO then noted that the assessee had the brand value of Hyundai, as evident from the ‘Interbrand’ valuation- which is one off the most respected brand valuation worldwide, the Hyundai

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...

gain in increasing the value of the company. Thus, this support and loyalty becomes an intangible asset for the company which gets accumulated every year 8. The TPO then noted that the assessee had the brand value of Hyundai, as evident from the ‘Interbrand’ valuation- which is one off the most respected brand valuation worldwide, the Hyundai

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...

gain in increasing the value of the company. Thus, this support and loyalty becomes an intangible asset for the company which gets accumulated every year 8. The TPO then noted that the assessee had the brand value of Hyundai, as evident from the ‘Interbrand’ valuation- which is one off the most respected brand valuation worldwide, the Hyundai

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...

gain in increasing the value of the company. Thus, this support and loyalty becomes an intangible asset for the company which gets accumulated every year 8. The TPO then noted that the assessee had the brand value of Hyundai, as evident from the ‘Interbrand’ valuation- which is one off the most respected brand valuation worldwide, the Hyundai

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

92C at "2,57, 13,271/-. On the basis of the order of the TPO u/s 92CA(3), the Assessing Officer added the sum of "2,57,13,271/- to the total income of the assessee. While doing so, the tolerable limit of 5% variation was taken with regard to each transaction. Aggrieved by the order, the assessee filed

ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

92C at "2,57, 13,271/-. On the basis of the order of the TPO u/s 92CA(3), the Assessing Officer added the sum of "2,57,13,271/- to the total income of the assessee. While doing so, the tolerable limit of 5% variation was taken with regard to each transaction. Aggrieved by the order, the assessee filed

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

92C at "2,57, 13,271/-. On the basis of the order of the TPO u/s 92CA(3), the Assessing Officer added the sum of "2,57,13,271/- to the total income of the assessee. While doing so, the tolerable limit of 5% variation was taken with regard to each transaction. Aggrieved by the order, the assessee filed

RENAULT INDIA PRIVATE LIMITED,SRIPERAMBUDUR vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.361/Mds/2014 "नधा"रण वष" / Assessment Year : 2009-10 M/S Renault India Pvt. Ltd., The Deputy Commissioner Of No.37 & 38, Fourth Floor, V. Income Tax, Asv Ramana Towers, Company Circle V(3), Venkatanarayana Road, Chennai - 600 034. T.Nagar, Chennai - 600 017. Pan : Aadcr 2042 M (अपीलाथ"/Appellant) (""यथ"/Respondent)

2. The first issue arises for consideration is treatment of foreign exchange gains earned on cancellation of forward contracts. 3. Shri Sriram Seshadri, the Ld. representative for the assessee, submitted that the assessee-company set up an automobile manufacturing plant in the State of Tamil Nadu. In the course of setting up of plant, the assessee imported plant and machinery

BAHWAN CYBERTEK PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeal is partly allowed

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./Ita No.290/Mds/2017 "नधा"रण वष" / Assessment Year : 2012-13

2 and para 7.6/pg. 29 of the TPO’s order). Similarly, under risk analysis, the entire business and financial risk of the business/enterprise is to be regarded as that of the assessee. In view of the foregoing, in our clear view, given the distribution of economic functions, the AEs should be regarded as the tested party and their profits

ABAN OFFSHORE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 1(1), CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./It(Tp)A Nos.: 21/Chny/2022 & 40/Chny/2022 िनधा"रण वष" / Assessment Years: 2017-18 & 2018-19 M/S. Aban Offshore Limited, Deputy Commissioner Of 113, Janpriya Crestpantheon V. Income Tax, Road, Egmore, Tpo Circle -1(1), Chennai – 600 008. Chennai. [Pan: Aaaca-3012-H] आयकर अपील सं./Ita Nos.: 797 & 798/Chny/2020 िनधा"रण वष" / Assessment Years: 2011-12 & आयकर अपील सं./Ita No.: 2757/Chny/2017 िनधा"रण वष" / Assessment Year: 2013-14 M/S. Aban Offshore Limited, Deputy Commissioner Of 113, Janpriya Crestpantheon V. Income Tax, Road, Egmore, Corporate Circle -1(1), Chennai – 600 008. Chennai. [Pan: Aaaca-3012-H] आयकर अपील सं./Ita No.: 1672/Chny/2019 िनधा"रण वष" / Assessment Year: 2013-14 M/S. Aban Offshore Limited, Deputy Commissioner Of V. 113, Janpriya Crestpantheon Income Tax, Road, Egmore, Corporate Circle -1(1), Chennai – 600 008. Chennai. [Pan: Aaaca-3012-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. P. Murali Mohana Rao, Ca Assessee By Department By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 27.09.2023 घोषणा क" तारीख/Date Of Pronouncement : 08.11.2023

gains due to fluctuation in exchange rates are to be treated as per the applicable GAAP principles. :-4-: ITA. Nos: 2757/Chny/2017, 1672/Chny/2019, 797 & 798/Chny/2020, IT(TP)A Nos: 21/Chny/2021& 40/Chny/2022 13. The Ld. CIT (A) ought to have appreciated the fact Rs. that as per the GAAP principles read along with 16,61,77,507/- Revised AS-11 the transactions