ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

capital gain or exempted income. The investment was made by the assessee in order to diversification in the non-ferrous metal sector. Therefore, the interest, if any, paid by the assessee has to be allowed under Section 36(1)(iii) of the Act. Since the investment was made in the ITA No.1020,1665 & 1386/Mds/10 course of business, there cannot

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

capital gain or exempted income. The investment was made by the assessee in order to diversification in the non-ferrous metal sector. Therefore, the interest, if any, paid by the assessee has to be allowed under Section 36(1)(iii) of the Act. Since the investment was made in the ITA No.1020,1665 & 1386/Mds/10 course of business, there cannot

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

capital gain or exempted income. The investment was made by the assessee in order to diversification in the non-ferrous metal sector. Therefore, the interest, if any, paid by the assessee has to be allowed under Section 36(1)(iii) of the Act. Since the investment was made in the ITA No.1020,1665 & 1386/Mds/10 course of business, there cannot

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

capital gain or exempted income. The investment was made by the assessee in order to diversification in the non-ferrous metal sector. Therefore, the interest, if any, paid by the assessee has to be allowed under Section 36(1)(iii) of the Act. Since the investment was made in the ITA No.1020,1665 & 1386/Mds/10 course of business, there cannot

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

capital gain or exempted income. The investment was made by the assessee in order to diversification in the non-ferrous metal sector. Therefore, the interest, if any, paid by the assessee has to be allowed under Section 36(1)(iii) of the Act. Since the investment was made in the ITA No.1020,1665 & 1386/Mds/10 course of business, there cannot

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

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 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

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

REGEN POWERTECH PRIVATE LMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Assessee and Department are allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

92D read with Rule 10D. The Assessee company had also submitted details of the technology knowhow it obtained from its AE and the details of the Royalty payments made.Furthermore, ITAT are of the opinion that once TNMM has been applied to the Assessee company's transaction, it covers under its ambit the Royalty transactions in question too and hence separate

DCIT, CHENNAI vs. REGEN POWERTECH (P) LTD., CHENNAI

In the result, the appeal of the Assessee and Department are allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

92D read with Rule 10D. The Assessee company had also submitted details of the technology knowhow it obtained from its AE and the details of the Royalty payments made.Furthermore, ITAT are of the opinion that once TNMM has been applied to the Assessee company's transaction, it covers under its ambit the Royalty transactions in question too and hence separate

RENAULT INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No. 1078/Mds/2017 "नधा"रण वष" /Assessment Year : 2012-2013. M/S. Renault India Private Vs. The Deputy Commissioner Of Limited, Income Tax, No.37 & 38, Asv Ramana Corporate Circle 5(1) Towers, Chennai. 4Th Floor, Venkatnarayana Road, T.N Agar, Chennai 600 017. [Pan Aadcr 2042M ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

capital. (viii) A harmonious reading of definition of international transaction u/s.92B of the Act alongwith definition of transaction u/s.92F of the Act, clearly show that transactions between assessee and M/s. RNAIPL were result of an arrangement and understanding with M/s. Renault S.A.S., France and thus it came within the preview of international transaction. :- 13 -: Ld. DRP thus approved the order

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 3(3), CHENNAI., CHENNAI vs. M/S. CATERPILLAR INDIA PVT. LTD , CHENNAI

Appeal is dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपीलसं./It(Tp)A No.: 42/Chny/2023 िनधा"रण वष" / Assessment Year: 2014-15 M/S.Caterpillar India Private Limited, The Deputy Commissioner Of 7Th Floor, International Tech Park, Income Tax, Taramani Road, Vs. Central Circle- 3(3), Chennai – 600 113. Chennai – 600 034. [Pan:Aabcc-4615-K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपीलसं./Ita No.: 717/Chny/2023 िनधा"रण वष" / Assessment Year: 2014-15 The Deputy Commissioner Of Income M/S.Caterpillar India Private Tax, Limited, 7Th Floor, International Tech Park, Central Circle- 3(3), V. Chennai – 600 034. Taramani Road, Chennai – 600 113. [Pan:Aabcc-4615-K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Assessee By : Shri Harish Ramanathan, C.A. By Virtual ""थ" की ओर से/Department By : Shri A. Sasikumar, C.I.T. सुनवाई की तारीख/Date Of Hearing : 12.03.2025 घोषणा की तारीख/Date Of Pronouncement : 06.06.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: These Cross Appeals Filed By The Assessee & The Revenue Are Arising Out Of Order Of Commissioner Of Income Tax (Appeals)-18, Chennai U/S. 143(3) R.W.S. 92Ca (3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) For The Assessment Year 2014-15 Dated 07.03.2023. Since, Facts Are Identical & Issues Are Common, For :-2-: It(Tp) A. No:42 /Chny/2023 & The Sake Of Convenience, The Appeal Filed By The Revenue & Assessee Are Being Heard Together & Disposed Off, By This Consolidated Order.

92D of the Act read with rule 10D of the Income-tax Rules, 1962 (‘the Rules). On the facts and in the circumstances of the case and in law, the Ld. CIT(A) / Ld. TPO / Ld. AO erred in the following grounds: Manufacturing of Earthmoving Equipment Segment 3. Erroneous Rejection of Economic Adjustments - Idle Capacity