DCIT CORPORATE CIRCLE 6(1) (I/C) , CHENNAI vs. SHRIRAM CREDIT COMPANY LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeal filed by the assessee is partly allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1199/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Credit Company Income Tax, Corporate Circle 6(1) I/C, Limited, Shriram House, No. 4, Aayakar Bhavan, Wanaparthy Burkit Road, T. Nagar, Block, 7Th Floor, 121, M.G. Road, Chennai 600 042. Chennai 600 034. [Pan:Aagcs4497N] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1307/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Shriram Credit Company Vs. The Deputy Commissioner Of Limited, Mookambika Complex, Income Tax, No. 4, Lady Desika Road, Corporate Circle 6(1), Mylapore, Chennai 600 004. Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Shri P. Sajit Kumar, Jcit Assessee By : Shri R.Sivaraman, Advocate सुनवाई की तारीख/ Date Of Hearing : 30.03.2022 घोषणा की तारीख /Date Of Pronouncement : 13.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 26.12.2017 Relevant To The Assessment

charitable activity or other activity as per the object of the Trust. This Tribunal is of the considered opinion that a Trust cannot be construed as a group concern of a business concern. The Trust has to be always treated independently and it is an independent statutory body. The assessee now claims that the logo belongs to Shriram Ownership Trust

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

14A of the Act. This ground of appeal of the assessee is allowed. 7. Ground Nos.4 & 5 raised by the assessee relates to the disallowance of deduction claimed in respect of both revenue & capital expenditure incurred towards scientific research u/s 35(2AB) of the act. 7.1 Briefly stated, the facts are that, the assessee had reported to have incurred expenditure

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable purpose. 22. What we find is that ld. Commissioner of Income Tax (Appeals) had confirmed the addition u/s. 2(24)(xv) of the Act r.w.s. 56(2)(vii) of the Act. Both these Sections are reproduced hereunder:- Sec. 2(24) ‘’income includes--- (i)................ (ii).......................... (xv) any sum of money or value of property referred to in clause

SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

charitable purpose. 22. What we find is that ld. Commissioner of Income Tax (Appeals) had confirmed the addition u/s. 2(24)(xv) of the Act r.w.s. 56(2)(vii) of the Act. Both these Sections are reproduced hereunder:- Sec. 2(24) ‘’income includes--- (i)................ (ii).......................... (xv) any sum of money or value of property referred to in clause

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nआयकर अपील सं./ITA No.1402/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nM/s. Ashok Leyland Ltd.,\nNo.1, Sardar Patel Road,\nGuindy, Chennai-600 032.\n[PAN: AAAСА 4651 L]\n(अपीलार्थी/Appellant)\nv.\nThe DCIT,\nNCC-8(1),\nLTU-II,\nChennai.\n(प्रत्यर्थी/Respondent)\nआयकर अपील सं./ITA No.1663/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nThe DCIT,\nNCC-8,\nChennai.\n(अपीलार्थी/Appellant)\nv.\nM/s. Ashok Leyl

Section 80-IA(8)\nof the Act. According to us, the sale price cannot further be segregated\nby imputing price attributable to marketing and R&D efforts for the\nsimple reason that there is no such provision contained in law. We agree\nwith the Ld. AR that, the method of computation to be adopted by the\nassessee, in line with

N. VIJAY KUMAR, ACIT, CHENNAI vs. RAJAH MUTHIAH CHETTIAR CHARITABLE AND EDUCATIONAL TRUST, CHENNAI

In the result, appeals filed by the Revenue & CO of assessee are

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

14A of the Act. This by no stretch of imagination can be held to be ‘misreporting’. 8. This Court also finds that there is not even a whisper as to which limb of Section 270A of the Act is attracted and how the ingredient of sub-section (9) of Section 270A is satisfied. In the absence of such particulars

MANSI FINANCE CHENNAI LIMITED,CHENNAI vs. THE ACIT, CC 4(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 108 & 109/Chny/2021 िनधा"रण वष"/Assessment Years: 2012-13 & 2013-14

Charitable Trust v. DCIT 280 ITR 357 (Mad) held that no hard and fast rule can be laid down in the matter of condonation of delay and the Court should adopt a pragmatic approach and the Court should exercise their discretion on the facts of each case keeping in mind that in construing the expression "sufficient cause" the principle

MANSI FINANCE CHENNAI LIMITED,CHENNAI vs. THE ACIT, CC-4(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 108 & 109/Chny/2021 िनधा"रण वष"/Assessment Years: 2012-13 & 2013-14

Charitable Trust v. DCIT 280 ITR 357 (Mad) held that no hard and fast rule can be laid down in the matter of condonation of delay and the Court should adopt a pragmatic approach and the Court should exercise their discretion on the facts of each case keeping in mind that in construing the expression "sufficient cause" the principle

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed\nfor statistical purposes

Charitable Medical Education & Cultural\nTrust has been issued in the name of Secretary to Managing Director\nof the company and in the name the company, therefore, the AO\ndenied deduction claimed u/s.80G of the Act. However, the learned\ncounsel for the assessee submitted that the Charity has clarified the\nmatter and acknowledged that payment was received by the Trust\nand

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

14A read with Rule 8D of the Income-tax Rules, 1962. …………………………….. ………………………………….. 11.16 Therefore, in our considered opinion, no contrary view can be taken under these circumstances. We, accordingly, hold that only those investments are to be considered for computing average value of investment which yielded exempt income during the year. 4.3Respectfully following decision of Special Bench of Tribunal

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

14A read with Rule 8D of the Income-tax Rules, 1962. …………………………….. ………………………………….. 11.16 Therefore, in our considered opinion, no contrary view can be taken under these circumstances. We, accordingly, hold that only those investments are to be considered for computing average value of investment which yielded exempt income during the year. 4.3Respectfully following decision of Special Bench of Tribunal

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

14A read with Rule 8D of the Income-tax Rules, 1962. …………………………….. ………………………………….. 11.16 Therefore, in our considered opinion, no contrary view can be taken under these circumstances. We, accordingly, hold that only those investments are to be considered for computing average value of investment which yielded exempt income during the year. 4.3Respectfully following decision of Special Bench of Tribunal

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...

charitable purpose of the holding company in allowing the assessee company to use the existing popular brand? No business entity will enter into an agreement for charity with another entity. It is for certain hidden benefits, the holding company has made the assessee company use the brand name and logo in all the vehicles manufactured. Had it been for charity

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...

charitable purpose of the holding company in allowing the assessee company to use the existing popular brand? No business entity will enter into an agreement for charity with another entity. It is for certain hidden benefits, the holding company has made the assessee company use the brand name and logo in all the vehicles manufactured. Had it been for charity

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...

charitable purpose of the holding company in allowing the assessee company to use the existing popular brand? No business entity will enter into an agreement for charity with another entity. It is for certain hidden benefits, the holding company has made the assessee company use the brand name and logo in all the vehicles manufactured. Had it been for charity

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...

charitable purpose of the holding company in allowing the assessee company to use the existing popular brand? No business entity will enter into an agreement for charity with another entity. It is for certain hidden benefits, the holding company has made the assessee company use the brand name and logo in all the vehicles manufactured. Had it been for charity

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...

charitable purpose of the holding company in allowing the assessee company to use the existing popular brand? No business entity will enter into an agreement for charity with another entity. It is for certain hidden benefits, the holding company has made the assessee company use the brand name and logo in all the vehicles manufactured. Had it been for charity