ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing the shares/making the investment

M/S CROWN REAL ESTATE PVT LTD. ,CHENNAI vs. ITO, CORPORATE WARD-1(3), NUNGAMBAKKAM, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

144 r.w.s 147 of the Income Tax Act for the assessment year 2013-14, in so far as it goes against the appellant, is contrary to law and facts, against the weight of evidence and probabilities of the case.” Now, the ld.counsel for the assessee before us pointed out that the CIT(A) has not adjudicated this jurisdictional issue

DEPUTY COMMISSINOER OF INCOME TAX,, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

144 of the Act. Therefore\nin our view, the AO could not have travelled beyond Section 44 in the\nfirst schedule of the Act\"\n5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded\nwhile computing the Income Tax of an Insurance Company, in view of the non-\nobstante clause contained in Section

DEPUTY COMMISSIONER OF INCOMETAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

144 of the Act. Therefore\nin our view, the AO could not have travelled beyond Section 44 in the\nfirst schedule of the Act\"\n5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded\nwhile computing the Income Tax of an Insurance Company, in view of the non-\nobstante clause contained in Section

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

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

144 of the Act. Therefore in our view, the AO could not have travelled beyond Section 44 in the first schedule of the Act" 5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded while computing the Income Tax of an Insurance Company, in view of the non- obstante clause contained in Section

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

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

144 of the Act. Therefore in our view, the AO could not have travelled beyond Section 44 in the first schedule of the Act" 5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded while computing the Income Tax of an Insurance Company, in view of the non- obstante clause contained in Section

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

144 of the Act. Therefore\nin our view, the AO could not have travelled beyond Section 44 in the\nfirst schedule of the Act\"\n5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded\nwhile computing the Income Tax of an Insurance Company, in view of the non-\nobstante clause contained in Section

DEPUTY COMMISSIONER OF INCOME TAX OFFICER , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

144 of the Act. Therefore in our view, the AO could not have travelled beyond Section 44 in the first schedule of the Act" 5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded while computing the Income Tax of an Insurance Company, in view of the non- obstante clause contained in Section

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

144 of the Act. Therefore in our view, the AO could not have travelled beyond Section 44 in the first schedule of the Act" 5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded while computing the Income Tax of an Insurance Company, in view of the non- obstante clause contained in Section

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

depreciation claimed by the\nassessee on UPS @60%. Therefore, we confirm the order of the\nLd.CIT(A) and dismiss the grounds of appeal of the Revenue.\n6.\nGround No.4 / Issue 3: Disallowance under section 14A of\nthe Act\n Assessment Year\nAppeal by\nGround No.\nAY 2011-12\nAssessee (ITA No.1282/2024)\nGround no. 1 to 5\nAY 2012-13\nDepartment

DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

144 of the Act. Therefore in our view, the AO could not have travelled beyond Section 44 in the first schedule of the Act" 5. It is thus clear that Section 14A of Income Tax Act, 1956 stands excluded while computing the Income Tax of an Insurance Company, in view of the non- obstante clause contained in Section

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

depreciation allowance or any other allowance, as the case may be, for the concerned assessment year in the case of an assessee if he has reason to believe that income chargeable to tax has escaped assessment, subject to the provisions of Sections 148 to 153. A pre-condition to initiate proceedings under Section 147 is the issuance of notice under

YUGENDIRAN VISHNUPRIYA,CHENNAI vs. ITO, WARD-2(2), CHENNAI

The appeals of the assessee are allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.3241 &3242/Chny/2024 (िनधा"रणवष" / Assessment Years: 2016-2017 & 2017-18) Yugendiran Vishnupriya Vs. Income Tax Officer, Door No.284/3, International Tax, Thiruveni Colony, Bellyarea, Ward 2(2) Anna Nagar, Chennai-600040 Chennai. [Pan: Apzpv 9903M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. Y. Sridhar, F.C.A ""यथ" क" ओर से /Respondent By : Mr. R. Clement Ramesh Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2025 घोषणा क" तार"ख /Date Of Pronouncement : 25.03.2025 आदेश / O R D E R Per Manu Kumar Giri ()

depreciation allowance or any other allowance, as the case may be, for the concerned assessment year in the case of an assessee if he has reason to believe that income chargeable to tax has escaped assessment, subject to the provisions of Sections 148 to 153. A pre-condition to initiate proceedings under Section 147 is the issuance of notice under

HYUNDAI TRANSYS INC,REPUBLIC OF KOREA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.338/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Hyundai Transys Inc, Vs. The Deputy Commissioner Of 105, Sindang Income Tax, 1 Ro Seongyeon, International Tax, Myeon, Corporate Circle 1(1) Seosan, Ccn 356851 Chennai. Korea.

depreciation allowance or any other allowance, as the case may be, for the concerned assessment year in the case of an assessee if he has reason to believe that income chargeable to tax has escaped assessment, subject to the provisions of Sections 148 to 153. A pre-condition to initiate proceedings under Section 147 is the issuance of notice under