ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

gains on such reasonable basis as he may deem fit. [Explanation.—For the purposes of this sub-section, "market value", in relation to any goods or services, means— (i) the price that such goods or services would ordinarily fetch in the open market; or (ii) the arm's length price as defined in clause (ii) of section 92F, where

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

gains on such reasonable basis as he may deem fit. [Explanation.—For the purposes of this sub-section, "market value", in relation to any goods or services, means— (i) the price that such goods or services would ordinarily fetch in the open market; or (ii) the arm's length price as defined in clause (ii) of section 92F, where

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

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 01.11.2019 has suggested upward

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

In the result, appeal filed by the assessee ppeal filed by the assessee is partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

92F (v) of the Income-tax Act states as below: "transaction includes an arrangement, understanding or action in "transaction includes an arrangement, understanding or action in "transaction includes an arrangement, understanding or action in concert, whether or not such arrangem concert, whether or not such arrangement, understanding or action is ent, understanding or action is formal or in writing;" formal

THE INDIA CEMENTS LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

The appeal of the assessee is allowed

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2663/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

capital unit. Therefore, the ld. DR argued that the decision of the Hon'ble Supreme Court cannot be directly applied in assessee's case. The Ld. DR further submitted that the Hyderabad Bench of the Tribunal in the case of Sanghi Industries Ltd. vs. DCIT [ITA No.104/Hyd/2022 dated 23.01.2025] has considered an identical issue and held that the rate

LOTUS FOOTWEAR ENTERPRISES LIMITED-INDIA BRANCH,TIRUVANNAMALAI vs. DCIT, INTERNATIONAL TAX 1(2), CHENNAI

In the result all the four appeals of the assessee are allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

gains on such reasonable basis as he may deem fit. Explanation.— For the purposes of this sub-section, "market value", in relation to any goods or services, means— (i) the price that such goods or services would ordinarily fetch in the open market; or (ii) the arm's length price as defined in clause (ii) of section 92F, where

LOTUS FOOTWEAR ENTERPRISES LIMITED-INDIA BRANCH,TIRUVANNAMALAI vs. DCIT, INTERNATIONAL TAX 1(2), CHENNAI

In the result all the four appeals of the assessee are allowed

gains on such\nreasonable basis as he may deem fit.\nExplanation.— For the purposes of this sub-section, "market value", in\nrelation to any goods or services, means—\n(i) the price that such goods or services would ordinarily fetch in the\nopen market; or\n(ii) the arm's length price as defined in clause (ii) of section 92F

LOTUS FOOTWEAR ENTERPRISES LIMITED-INDIA BRANCH,TIRUVANNAMALAI vs. DCIT, INTERNATIONAL TAX 1(2), CHENNAI

In the result all the four appeals of the assessee are allowed

gains on such\nreasonable basis as he may deem fit.\n\nExplanation.— For the purposes of this sub-section, "market value", in\nrelation to any goods or services, means—\n(i) the price that such goods or services would ordinarily fetch in the\nopen market; or\n(ii) the arm's length price as defined in clause (ii) of section