ALAGUMALAI IMPEX PVT LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

234/- under section 14A of the Act. 3 I.T.A. Nos.214, 2911 & 721/M/14 3. The assessee carried the matter in appeal before the ld. CIT(A). After considering the submissions of the assessee and by following various decisions, the ld. CIT(A) partly allowed the appeal filed by the assessee. 4. With regard to the claim of deduction under section 10A/10B

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)

234, Dare House, NSC Large Taxpayer Unit -1, Bose Road, Parrys Corner, Chennai. Chennai 600 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent by : Shri A. Sasikumar, CIT सुनवाई क" तारीख/Date of Hearing : 20.03.2025 घोषणा क" तारीख/Date of Pronouncement : 21.04.2025 आदेश

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)

234, Dare House, NSC Large Taxpayer Unit -1, Bose Road, Parrys Corner, Chennai. Chennai 600 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent by : Shri A. Sasikumar, CIT सुनवाई क" तारीख/Date of Hearing : 20.03.2025 घोषणा क" तारीख/Date of Pronouncement : 21.04.2025 आदेश

M/S. STANADYNE INDIA PVT. LTD.,TIRUVALLUR vs. ACIT, CC-IV(4), CHENNA

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

234 (Mad.) in support of its contention.\n12. The Ld. Departmental Representative (DR), on the other hand,\nhas relied on the orders of lower authorities.\n13. We have heard the rival submissions, and perused the materials\navailable on record. The A.O while computing the eligible profit u/s.\n10B of the Act as per section 10B(4) has not considered refurbishment

ACIT, CHENNAI vs. JOHNSON LIFTS PVT. LTD., CHENNAI

In the result the appeal is partly allowed

Bench: Shri Aby T. Varkey, Jm & Shri Amitabh Shuklaआयकर अपील सं./Ita No.47/Chny/2024 & Ita No.48/Chny/2024 निर्धारण वर्ा /Assessment Year: 2016-17 & 2017-18

depreciation on Computer Software to 25 percent as against 60 percent leading to addition of Rs.368,100. The said computer software licenses are only application software and are not income generating assets for the Assessee. 6. The Assessing Officer also initiated penalty proceedings u.s. 271(1)(C) of the Act.7. AO also levied interest of Rs.4 49,310 u.s. 234

SANTECH SOLUTONS PVT LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is treated as 9

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No.1036/Mds/2016 "नधा"रण वष" /Assessment Year : 2008-2009

depreciation for deduction of ₹1,50,74,601/- in place of ₹6,44,589/- is not admissible’’. Thus, the only reasonable conclusion that can be drawn is that ld. Assessing Officer, while framing the original assessment was aware of the recovery of "1,05,93,698/- made by the assessee on its semi finished M/s. Health Q Software product from

ITO EXEMPTION WARD 3, CHENNAI vs. SHRI SHIRDI SAIBABA SPIRITUAL AND CHARITABLE TRUST, CHENNAI

In the result, the Revenue’s appeal is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं/.I.T.A. No. 2859/Chny/2017 "नधा"रण वष"/Assessment Year : 2012-13 Income Tax Officer, M/S. Shri Shiridi Saibaba Spiritual & Exemption Ward 3, Vs. Charitable Trust, 121, Mahatma Gandhi Road, Sai Business Point, No. 17, 2Nd Floor, Mount Road, Little Mount, Nungambakkam, Chennai – 600 034. Chennai – 600 015. [Pan: Aats 3448J] (&'यथ)/Respondent) (अपीलाथ"/Appellant) Revenue By : Shri. N. Madhavan, Addl. Cit : Shri Saroj Kumar Parida, Advocate Assessee By सुनवाईक/तार"ख/Date Of Hearing : 03.04.2018 घोषणाक/तार"ख/Date Of Pronouncement : 10.04.2018

section 11(1)(a), then assessee cannot claim depreciation on value of such assets." 2.4 The Ld. CIT(A) ought to have considered the decision of the Hon'ble Delhi Court in the case of DIT Vs. M/s. Charanjiv Charitable Trust (2014) 43 taxmann.com 300 (DeL) wherein it has been held that depreciation would not be allowed in cases where

DOLPHIN CLUB,CHENNAI vs. CIT EXEMPTIONS, CHENNAI

The appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकरअपीलसं. Ita No 3107/Chny/2024 "नधा"रणवष"/Assessment Years: -- Dolphin Club V. Cit, (E), 3/15, Jeswanth Nagar, Mogappiar No. 121, Mahatma Gandhi West,Chennai-600037 Road, Nungambakkam Chennai-600034 [Pan: Aaatd 0288 P] (अपीलाथ"/Assessee) (""यथ"/Respondent)

234, the term “education” under section 2(15) refers to systematic instruction, schooling, or training imparted to the young to prepare them for life, and includes scholastic instruction received through a structured course of study. The term is not intended to cover every form of knowledge acquisition in its widest sense.If the term “education” ITA 3107 Chny 2024 Dolphin Club

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

234 ITR 10, affirmed the stand of the ld.CIT(A). No contrary facts were brought to our notice by either side and more specifically by the Revenue, therefore, we find no infirmity in the conclusion drawn by the ld.CIT(A). 4.3 Our above conclusion will also cover the remaining appeals of the Revenue on identical issue. 5. Now we shall

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

234 ITR 10, affirmed the stand of the ld.CIT(A). No contrary facts were brought to our notice by either side and more specifically by the Revenue, therefore, we find no infirmity in the conclusion drawn by the ld.CIT(A). 4.3 Our above conclusion will also cover the remaining appeals of the Revenue on identical issue. 5. Now we shall

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

234 ITR 10, affirmed the stand of the ld.CIT(A). No contrary facts were brought to our notice by either side and more specifically by the Revenue, therefore, we find no infirmity in the conclusion drawn by the ld.CIT(A). 4.3 Our above conclusion will also cover the remaining appeals of the Revenue on identical issue. 5. Now we shall

ACIT, COIMBATORE vs. K.RAJINIKANTH, COIMBATORE

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

Bench: Shri B.R. Baskaran & Shri Vikas Awasthyआयकर अपील सं./Ita No. 2495/Mds/2014 "नधा"रण वष" /Assessment Year : 2010-11 The Assistant Commissioner Of Shri K. Rajinikanth, Income Tax, V. 603, C-Block, Pioneer Complex, Circle Iii, 1075, Avinashi Road, 63, Race Course Road, Coimbatore – 641 018. Coimbatore – 641 018. Pan : Addpr 3075 L (अपीलाथ"/Appellant) (""यथ"/Respondent)

depreciation and investment allowances of earlier years should be taken into account in determining the quantum of deduction admissible under Section 80-IA, even though there may have been set off against the profits of taxpayer from other sources. Though the assessee placed reliance on the decision of Hon'ble jurisdictional High Court in the case of Velayudhaswamy Spinning Mills

ACIT, COIMBATORE vs. RANGAMMA STEELS AND MALLEABLES, COIMBATORE

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

Bench: Shri B.R. Baskaran & Shri Vikas Awasthyआयकर अपील सं./Ita No. 2494/Mds/2014 "नधा"रण वष" /Assessment Year : 2010-11

depreciation and investment allowances of earlier years should be taken into account in determining the quantum of deduction admissible under Section 80-IA, even though there may have been set off against the profits of taxpayer from other sources. Though the assessee placed reliance on the decision of Hon'ble jurisdictional High Court in the case of Velayudhaswamy Spinning Mills

ACIT, COIMBATORE vs. PIONEER WOVEN SACKS PVT. LTD., UDAMALPET

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

Bench: Shri B.R. Baskaran & Shri Vikas Awasthyआयकर अपील सं./Ita No. 1687/Mds/2014 "नधा"रण वष" /Assessment Year : 2010-11

depreciation and investment allowances of earlier years should be taken into account in determining the quantum of deduction admissible under Section 80-IA, even though there may have been set off against the profits of taxpayer from other sources. Though the assessee placed reliance on the decision of Hon'ble jurisdictional High Court in the case of Velayudhaswamy Spinning Mills

M/S MOHAN BREWERIES & DISTILLERIES LTD,CHENNAI vs. ACIT CENTRAL CIRCLE 2 (1), CHENNAI

The appeal stand dismissed

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

depreciation in respect of the assets used in the power generating units. 2.2. The Id CIT(A) failed to note that the above amendments were brought to allow tax holiday to an undertaking engaged in the business of generation or generation and distribution of power. The above deduction is allowed for 10 years out of the 15 years

M/S MOHAN BREWERIES & DISTILLERIES LTD,CHENNAI vs. ACIT CENTRAL CIRCLE 2 (1), CHENNAI

The appeal stand dismissed

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

depreciation in respect of the assets used in the power generating units. 2.2. The Id CIT(A) failed to note that the above amendments were brought to allow tax holiday to an undertaking engaged in the business of generation or generation and distribution of power. The above deduction is allowed for 10 years out of the 15 years

ACIT CENTRAL CIRCLE 2 (1), CHENNAI vs. M/S MOHAN BREWERIES & DISTILLERIES LTD, CHENNAI

The appeal stand dismissed

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

depreciation in respect of the assets used in the power generating units. 2.2. The Id CIT(A) failed to note that the above amendments were brought to allow tax holiday to an undertaking engaged in the business of generation or generation and distribution of power. The above deduction is allowed for 10 years out of the 15 years

ACIT CENTRAL CIRCLE 2 (1), CHENNAI vs. M/S MOHAN BREWERIES & DISTILLERIES LTD, CHENNAI

The appeal stand dismissed

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

depreciation in respect of the assets used in the power generating units. 2.2. The Id CIT(A) failed to note that the above amendments were brought to allow tax holiday to an undertaking engaged in the business of generation or generation and distribution of power. The above deduction is allowed for 10 years out of the 15 years