ACIT CORPORATE CIRCLE-6(2), CHENNAI vs. M/S SUN EDISON SOLAR POWER INDIA PVT LTD, CHENNAI

In the result, the appeals filed by the assessee for the assessment years 2013-14, 2014-15 and 2015-16 are allowed and the appeal filed by the Revenue for the assessment year 2015-16 is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

138] and treated it as goodwill and claimed allowable depreciation under section 32(1) of the Income Tax Act as intangible

M/S. SUN EDITION SOLAR POWER INDIA PVT. LTD.,,CHENNAI vs. DCIT, CORPORATE CIRCLE - 6 (2),, CHENNAI

In the result, the appeals filed by the assessee for the assessment years 2013-14, 2014-15 and 2015-16 are allowed and the appeal filed by the Revenue for the assessment year 2015-16 is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

138] and treated it as goodwill and claimed allowable depreciation under section 32(1) of the Income Tax Act as intangible

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 43(1), 43(6) and 47(iii) of the Act, finally held as under:- 23. Proceeding to the question of actual cost of goodwill or trade name, it is well established that goodwill is an important asset of business which is acquired over a period of time. There are well-recognized methods of computing value of goodwill/trade name

HOSPIRA HEALTHCARE INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No. 821/Mds/2016 "नधा"रण वष" /Assessment Year : 2011-2012

138 The business model adopted by the assessee and its trading partners mentioned above were on profit sharing basis. Profits were worked out by deducting from the sales effected by the entities abroad cost of products sold and marketing cost. Associated Enterprise abroad who ITA No.821/Mds/2016. :- 5 -: were selling assessee’s products were entitled for marketing cost

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

138 Taxman 177 (Madras) wherein the court observed that the assessee was clearly not entitled to have the amount paid by it to its collaborator for acquiring know-how as an item of revenue expenditure allowable as a deduction under section 37 and that payment was required to be considered only under section 35AB. In view of the above decision

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

138 Taxman 177 (Madras) wherein the court observed that the assessee was clearly not entitled to have the amount paid by it to its collaborator for acquiring know-how as an item of revenue expenditure allowable as a deduction under section 37 and that payment was required to be considered only under section 35AB. In view of the above decision

AGILE ELECTRIC SUB ASSEMBLY (P) LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal is disposed of in the aforesaid terms

Bench: Shri Sanjay Arora & Shri G. Pavan Kumarआयकर अपील सं./Ita No.2497/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

section 79 in the facts and circumstances 15 Agile Electric Sub Assembly Pvt. Ltd. v. Dy. CIT of the case. In any case, we cannot be oblivious to that eventuality, or base our order on the presumption of its confirmation by both the higher appellate forums. And in which case, i.e., it being not approved on that aspect, the satisfaction

DCIT CIRCLE 1, TIRUPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING (P) LIMITED, TIRUPUR

The appeal of the revenue stand dismissed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

138 DTR 36 (SC). 9. Applying the ratio of these decisions to the facts of the case before us, it could be seen that the purpose of the scheme was to offset infrastructure inefficiencies. There was no requirement to map the expenditure associated with the subsidy and in fact, the assessee was not required to furnish any utilization certificate. Therefore

DCIT CIRCLE 1, TIRUPUR vs. M/S EASTERN EXPORTS GLOBAL CLOTHING (P) LIMITED, TIRUPUR

The appeal of the revenue stand dismissed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

138 DTR 36 (SC). 9. Applying the ratio of these decisions to the facts of the case before us, it could be seen that the purpose of the scheme was to offset infrastructure inefficiencies. There was no requirement to map the expenditure associated with the subsidy and in fact, the assessee was not required to furnish any utilization certificate. Therefore

DCIT, CORPORATE CIRCLE 2(1), CHENNAI vs. FREINS ENGINEERING LTD., CHENNAI

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

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy

section 14A of the Act. The ld. DR could not controvert the above findings of the Hon’ble Bombay High Court. Thus, we are of the considered opinion that the ld. CIT(A) has rightly followed the above judgement of Hon’ble Bombay High Court and held that no disallowance under Rule 8D(2)(ii) could be made in this

DCIT, CORPORATE CIRCLE 2(1), CHENNAI vs. FREINS ENGINEERING LTD. , CHENNAI

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

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy

section 14A of the Act. The ld. DR could not controvert the above findings of the Hon’ble Bombay High Court. Thus, we are of the considered opinion that the ld. CIT(A) has rightly followed the above judgement of Hon’ble Bombay High Court and held that no disallowance under Rule 8D(2)(ii) could be made in this