ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

115, 117 & 116/17-18 for the AYs 2002-03, 2003-04, 2004-05, 2005-06 & 2006-07 respectively. Since the issue and grounds in all these appeals are identical, for the sake of convenience, they are heard together and disposed off by this common order. ITA Nos.383 to 387/Chny/2018 :- 2 -: 2. The Revenue has raised four grounds in all these appeals

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

115, 117 & 116/17-18 for the AYs 2002-03, 2003-04, 2004-05, 2005-06 & 2006-07 respectively. Since the issue and grounds in all these appeals are identical, for the sake of convenience, they are heard together and disposed off by this common order. ITA Nos.383 to 387/Chny/2018 :- 2 -: 2. The Revenue has raised four grounds in all these appeals

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

115, 117 & 116/17-18 for the AYs 2002-03, 2003-04, 2004-05, 2005-06 & 2006-07 respectively. Since the issue and grounds in all these appeals are identical, for the sake of convenience, they are heard together and disposed off by this common order. ITA Nos.383 to 387/Chny/2018 :- 2 -: 2. The Revenue has raised four grounds in all these appeals

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

115, 117 & 116/17-18 for the AYs 2002-03, 2003-04, 2004-05, 2005-06 & 2006-07 respectively. Since the issue and grounds in all these appeals are identical, for the sake of convenience, they are heard together and disposed off by this common order. ITA Nos.383 to 387/Chny/2018 :- 2 -: 2. The Revenue has raised four grounds in all these appeals

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

115, 117 & 116/17-18 for the AYs 2002-03, 2003-04, 2004-05, 2005-06 & 2006-07 respectively. Since the issue and grounds in all these appeals are identical, for the sake of convenience, they are heard together and disposed off by this common order. ITA Nos.383 to 387/Chny/2018 :- 2 -: 2. The Revenue has raised four grounds in all these appeals

DCIT CORPORATE CIRCLE 2(1), CHENNAI vs. FIXIT PVT. LTD., CHENNAI

In the result, the appeal filed by the Revenue is allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P.George

depreciation is nil; or (iv) to (vi) [***] (vii) the amount of profits of sick industrial company for the assessment year commencing on and from the assessment year relevant to the previous year in which the said company has become a sick industrial company under sub-section (1) of section 17 of the Sick Industrial Companies (Special Provisions

THE INDIA CEMENTS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1) CHENNAI, CHENNAI

depreciation would be reduced. In all the other cases,\nirrespective of nomenclature or the manner in which the same are\ngiven, such concessions would always form part of income of the\nassessee notwithstanding the 'purpose' or objective of the scheme or\nwhether the same was in capital field or in revenue field. This\namendment has, thus, taken away the distinction

STANDARD CHARTERED GLOBAL BUSINESS SERVICES PRIVATE LIMITED,CHENNAI vs. DCIT, NFAC, DELHI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Mahavir Singhand Shri Jagadishआयकर अपील सं./Ita No.: 964/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 Standard Chartered Global The Deputy Commissioner Business Services Pvt. Ltd., Vs. Of Income Tax, No.1, Haddows Road, Corporate Circle 3(2), Chennai. Chennai – 600 006. Pan: Aaecs 9043E (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Sriram Seshadri, Ca राज"व क" ओर से /Revenue By : Shri R. Clement Ramesh Kumar, Cit & आयकर अपील सं./Ita No.: 124/Chny/2023 िनधा"रण वष"/Assessment Year:2018-19 The Assistant Standard Chartered Global Commissioner Of Income Vs. Business Services Pvt. Tax, Ltd., Corporate Circle 3(1), No.1, Haddows Road, Chennai. Chennai – 600 006. Pan: Aaecs 9043E (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Sriram Seshadri, Ca राज"व क" ओर से /Revenue By : Shri P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 28.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 30.05.2024

section 115-O of the Act, in respect of the dividends declared/paid by it during the Impugned AY to Standard Chartered Bank, PLC, a tax resident of the UK, shall be restricted to the applicable rate of tax on dividends prescribed under Article 11 of the India-UK DTAA.” 9. We have heard rival contentions and gone through facts

ACIT, CORPORATE CIRCLE-3(1), CHENNAI vs. M/S STANDARD CHARGERED GLOBAL BUSINESS SERVIES PVT. LIMITED, CHENNAI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Mahavir Singhand Shri Jagadishआयकर अपील सं./Ita No.: 964/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 Standard Chartered Global The Deputy Commissioner Business Services Pvt. Ltd., Vs. Of Income Tax, No.1, Haddows Road, Corporate Circle 3(2), Chennai. Chennai – 600 006. Pan: Aaecs 9043E (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Sriram Seshadri, Ca राज"व क" ओर से /Revenue By : Shri R. Clement Ramesh Kumar, Cit & आयकर अपील सं./Ita No.: 124/Chny/2023 िनधा"रण वष"/Assessment Year:2018-19 The Assistant Standard Chartered Global Commissioner Of Income Vs. Business Services Pvt. Tax, Ltd., Corporate Circle 3(1), No.1, Haddows Road, Chennai. Chennai – 600 006. Pan: Aaecs 9043E (अपीलाथ"/Appellant) (""यथ"/Respondent) िनधा"रती क" ओर से/Assessee By : Shri Sriram Seshadri, Ca राज"व क" ओर से /Revenue By : Shri P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 28.05.2024 घोषणा क" तारीख/Date Of Pronouncement : 30.05.2024

section 115-O of the Act, in respect of the dividends declared/paid by it during the Impugned AY to Standard Chartered Bank, PLC, a tax resident of the UK, shall be restricted to the applicable rate of tax on dividends prescribed under Article 11 of the India-UK DTAA.” 9. We have heard rival contentions and gone through facts

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP CIRCLE 8, CHENNAI

section 115JB of the Income-tax Act by the Finance Act, 2012\nwas with a specific purpose. The specific inclusion of companies to which the\nproviso to sub-section (2) of section 211 of the Companies Act, 1956 is\napplicable clearly indicates that prior to the subject amendment, the provisions\nof Section 115JB of the Act did not apply

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

In the result, both the appeals of the assessee and Revenue are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

115-JA consequent to splitting of Section 80-IA into Section 80-IA and 80-IB by Finance Act 1999 with effect from 01.04.2000. Therefore, the assessee is eligible for deduction under Section 80-IA or subsequently under Section 80-IB after amendment to the extent of 100% for the first five years and 30% for next five years

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

In the result, both the appeals of the assessee and Revenue are partly allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

115-JA consequent to splitting of Section 80-IA into Section 80-IA and 80-IB by Finance Act 1999 with effect from 01.04.2000. Therefore, the assessee is eligible for deduction under Section 80-IA or subsequently under Section 80-IB after amendment to the extent of 100% for the first five years and 30% for next five years

VERSATILE CARD TECHNOLOGY PRIVATE LIMITED ,SIDCO,CHROMEPET,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHENNAI-3, INCOME TAX OFFICE, MAIN BUILDING - IV FLOOR, NUNGAMBAKKAM, CHENNAI

Bench: Shri Aby T. Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1392/Chny/2024 िनधा"रणवष" / Assessment Year: 2016-17 Versatile Card Technology Private Principal Commissioner Of Limited, V. Income Tax, Chennai -3, Ac-21, 4Th Main Road, Sidco Income Tax Office, Main Industrial Estate, Building, Iv Floor, Thirumudivakkam, Nungambakkam, Chennai. Chrompet, Chennai – 600 044. [Pan:Aabcv-0567-B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Gopal Krishna Raju, Ca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 06.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 18.10.2024 आदेश /O R D E R

depreciation on straight line method as provided in Companies Act, 1956 and as charged for the Asst Year 2011-12, The Appellant was not required to pay MAT under section 115

ACIT LTU-2 , CHENNAI vs. CHEMPLAST SANMAR LIMITED, CHENNAI

In the result, the appeal of the assessee in I

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

115 BBG(1) as follows: “(1) Where the total income of an assessee includes any income by way of transfer of carbon credits, the income-tax payable shall be the aggregate of:- (a) The amount of income-tax calculated on the income by way of transfer of carbon credits, at the rate of ten percent; and (b) The amount

ACIT LTU-2 , CHENNAI vs. CHEMPLAST SANMAR LIMITED, CHENNAI

In the result, the appeal of the assessee in I

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

115 BBG(1) as follows: “(1) Where the total income of an assessee includes any income by way of transfer of carbon credits, the income-tax payable shall be the aggregate of:- (a) The amount of income-tax calculated on the income by way of transfer of carbon credits, at the rate of ten percent; and (b) The amount

CHEMPLAST SANMAR LIMITED,CHENNAI vs. DCIT LTU, CHENNAI

In the result, the appeal of the assessee in I

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

115 BBG(1) as follows: “(1) Where the total income of an assessee includes any income by way of transfer of carbon credits, the income-tax payable shall be the aggregate of:- (a) The amount of income-tax calculated on the income by way of transfer of carbon credits, at the rate of ten percent; and (b) The amount

ACIT LTU-2 , CHENNAI vs. CHEMPLAST SANMAR LIMITED, CHENNAI

In the result, the appeal of the assessee in I

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

115 BBG(1) as follows: “(1) Where the total income of an assessee includes any income by way of transfer of carbon credits, the income-tax payable shall be the aggregate of:- (a) The amount of income-tax calculated on the income by way of transfer of carbon credits, at the rate of ten percent; and (b) The amount

ACIT LTU-2 , CHENNAI vs. CHEMPLAST SANMAR LIMITED, CHENNAI

In the result, the appeal of the assessee in I

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita Nos.2807, 2808, 2809 & 2810/Chny/2017 धनिाजरण वर्ज /Assessment Years: 2010-11, 2011-12, 2012-13 & 2013-14 M/S. Chemplast Sanmar Limited, The Deputy Commissioner Of No.9, Cathedral Road, Income Tax, Chennai – 600 086. Vs. Large Tax Payer Unit, [Pan: Aaacc 3000F] 1775, 21 Mahatma Gandhi High Road, Chennai – 600 034 (अपीलार्थी/Appellant) (प्रत्यथी/Respondent)

115 BBG(1) as follows: “(1) Where the total income of an assessee includes any income by way of transfer of carbon credits, the income-tax payable shall be the aggregate of:- (a) The amount of income-tax calculated on the income by way of transfer of carbon credits, at the rate of ten percent; and (b) The amount