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

section 14A of the Act. Thus, the ground raised by the assessee is allowed and the ground raised by the Revenue become academic and requires no adjudication. 4. The next ground raised in the appeal of the Revenue in ground No. 3 to 3.3 relates to deletion of disallowance of royalty payment of ₹.56,43,969/-. The assessee has claimed

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

ACIT, MADURAI vs. J.K.FENNER (INDIA) LIMITED, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

ACIT CORPORATE CIRCLE 1, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. ACIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

J.K.FENNER (INDIA) LIMITED,MADURAI vs. ACIT CORPORATE CIRCLE 1, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry forward

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

depreciation at 60%. Unrealized gains on mutual funds were not added to income. Disallowance for book profits under Section 115JB was deleted. Penalty proceedings were kept open.", "result": "Partly Allowed", "sections": [ "14A

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

14A, disallowance under Section 40(a)(ia) for software AMC and license payments, set-off of losses, and depreciation on software

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

Depreciation on computer software was allowed at 60%. Unrealized gains on mutual fund units were not taxable as income in the current year. The addition of disallowance under Section 14A

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

14A and section 40(a)(ia) of the Income Tax Act, depreciation on software, and treatment of unrealized gains on mutual