ADP INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), CHENNAI

In the result, the appeal in ITA No

Bench: Shri George George Kand Shri Jagadishआयकर अपीलसं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 िनधा"रण वष"/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, The Deputy Commissioner Of Thamarai Tech Park, 6Th Floor, Vs. Income Tax, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Corporate Circle 1(1), Industrial Estate, Inner Ring Road, Chennai. Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Sandeep Bagmar, Advocate ""यथ" क" ओर से/Respondent By : Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 08.05.2025 घोषणा क" तारीख/Date Of Pronouncement : 21.05.2025 आदेश/ O R D E R Per George George K: These Four Appeals Filed At The Instance Of The Assessee Are Directed Against Four Separate Orders Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (All Dated 21.08.2024) Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Called ‘The Act’). The Relevant Assessment Years Are 2016-17, 2017-18, 2018-19 & 2020-21. Ita Nos.2670 To 2672 & 2698/Chny/2024

6. One more aspect needs to be highlighted. In the present case, the Assessing Officer, as a matter of fact, came to the conclusion that no amount was actually paid on account of goodwill. This is a factual finding. The Commissioner of Income-tax (Appeals) ("the CIT(A)", for short) has come to the conclusion that the authorised representatives

THE MUSIC ACADEMY MADRAS,CHENNAI vs. DDIT, CHENNAI

Accordingly, the same is dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1098/Mds/2015 "नधा"रण वष" / Assessment Year : 2010-11 The Music Academy Madras, The Deputy Director Of Income Tax No.168 (Old No.306), Ttk Road, V. (Exemptions), Royapettah, Chennai - 600 014. Chennai - 600 034 . Pan : Aaatt 0256 B (अपीलाथ"/Appellant) (""यथ"/Respondent)

6) of section 43; Explanation 3.— For the purposes of this sub-section, 10the expressions "assets" shall mean-- (a) tangible assets, being buildings, machinery, plant or furniture ; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. Explanation 4.— For the purposes of this sub-section, the expression

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

depreciation allowed @5% as per Income Tax Rules. Hence, we uphold the order of the Assessing Officer and dismiss the ground of the assessee.” 7.2 In view of the above decision (supra), we see no reason to interfere with the orders of the lower authorities and thus confirm the impugned disallowance. Ground No. 6 of the assessee is accordingly dismissed

M/S. RAJA MUTHIAH CHETTIAR CHARITABLE AND EDUCATIONAL TRUST,CHENNAI vs. DDIT, CHENNAI

In the result, the appeal of the assessee stands dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singh

6) of section 43; Explanation 3.— For the purposes of this sub-section, 10the expressions "assets" shall mean-- (a) tangible assets, being buildings, machinery, plant or furniture ; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. Explanation 4.— For the purposes of this sub-section, the expression

ASHOK LEYLAND LIMITED,,CHENNAI vs. ACIT,, CHENNAI

depreciation allowed @5% as per Income Tax Rules.\nHence, we uphold the order of the Assessing Officer and dismiss the\nground of the assessee.\"\n7.2\nIn view of the above decision (supra), we see no reason to interfere\nwith the orders of the lower authorities and thus confirm the impugned\ndisallowance. Ground No. 6 of the assessee is accordingly dismissed

SOUTHER INDIA MILLS ASSOCIATION,CHENNAI vs. DCIT, COIMBATORE

In the result, both the appeals of the assessee stand dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singh

6) of section 43; Explanation 3.— For the purposes of this sub-section, 10the expressions "assets" shall mean-- (a) tangible assets, being buildings, machinery, plant or furniture ; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. Explanation 4.— For the purposes of this sub-section, the expression

M/S. SAKTHI FOUNDATION,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee stand dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singh

6) of section 43; Explanation 3.— For the purposes of this sub-section, 10the expressions "assets" shall mean-- (a) tangible assets, being buildings, machinery, plant or furniture ; (b) intangible assets, being know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature. Explanation 4.— For the purposes of this sub-section, the expression

ACIT LTU 2 , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

M/S. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

ACIT LTU 2 , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

ACIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. DCIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

DCIT, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

6 applies." 3.22. From the perusal of the relevant clause of Article 5(4) of the treaty reproduced supra, it could be concluded that the said Article is not at all applicable for reinsurer. This is relevant in view of the observations made by the ld. CIT(A) in 4.2.6 as under:- “As per the appellant there are certain treaties