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

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 2. Common issues are raised in these appeals; hence, they were heard together and are being disposed off by this consolidated order. By the consent of both the parties

CLASSIC LINEN INTERNATIONAL PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, the appeal filed by assessee in iTA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा$रण वष$ /Assessment Year: 2011-12

depreciation allowance under section 32, the written down value of any asset used for the purposes of the business of the undertaking shall be computed as if the assessee had claimed and been actually allowed the deduction in respect of depreciation for each of the relevant assessment year. (7) The provisions of sub-section (8) and sub-section

M/S SUN EDISON SOLAR POWER INDIA PVT LTD,CHENNAI vs. ITO, CORPORATE WARD - 6 (3),, 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

depreciation on goodwill as claimed by the assessee for all the three assessment years. 22. The next issue that came up for consideration in the assessment year 2015-16 relates to confirmation of disallowance made under section 14A r.w. Rule 8D of IT Rules, 1962. The Assessing Officer has disallowed expenses relating to exempt income under section

M/S SUN EDISON 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

depreciation on goodwill as claimed by the assessee for all the three assessment years. 22. The next issue that came up for consideration in the assessment year 2015-16 relates to confirmation of disallowance made under section 14A r.w. Rule 8D of IT Rules, 1962. The Assessing Officer has disallowed expenses relating to exempt income under section

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

depreciation on goodwill as claimed by the assessee for all the three assessment years. 22. The next issue that came up for consideration in the assessment year 2015-16 relates to confirmation of disallowance made under section 14A r.w. Rule 8D of IT Rules, 1962. The Assessing Officer has disallowed expenses relating to exempt income under section

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

depreciation on goodwill as claimed by the assessee for all the three assessment years. 22. The next issue that came up for consideration in the assessment year 2015-16 relates to confirmation of disallowance made under section 14A r.w. Rule 8D of IT Rules, 1962. The Assessing Officer has disallowed expenses relating to exempt income under section

ADP INDIA PRIVATE LIMITED,CHENNAI vs. NATIONAL FACELESS ASSESSMENT CENTRE, NATIONAL FACELESS ASSESSMENT CENTRE

Bench: Shri George George K & Shri Jagadishआयकर अपीलसं/Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, Thamarai Tech Park, 6Th Floor, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Industrial Estate, Inner Ring Road, Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख/Date Of Hearing : घोषणा की तारीख/Date Of Pronouncement : The Deputy Commissioner Of Vs. Income Tax, Corporate Circle 1(1), Chennai. (प्रत्यर्थी/Respondent) Shri Sandeep Bagmar, Advocate Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit 08.05.2025 21.05.2025 आदेश / Order 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. -2-

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. -2- ITA Nos.2670 to 2672 & 2698/Chny/2024 2. Common issues are raised in these appeals; hence, they were heard together and are being disposed off by this consolidated order. By the consent of both the parties

ADP INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CC-1(1), CHENNAI

Bench: Shri George George K & Shri Jagadishआयकर अपील सं/.Ita Nos.: 2670, 2671, 2672 & 2698/Chny/2024 निर्धारण वर्ष/Assessment Years: 2016-17, 2017-18, 2018-19 & 2020-21 Adp India Private Limited, Thamarai Tech Park, 6Th Floor, Sp Plot No. 16 To 20 & 20A, Thiru Vi Ka Industrial Estate, Inner Ring Road, Guindy Industrial Estate So, Guindy, Chennai 600 032. [Pan: Aadcm-5547-J] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By : प्रत्यर्थी की ओर से/Respondent By : सुनवाई की तारीख/Date Of Hearing : घोषणा की तारीख/Date Of Pronouncement : The Deputy Commissioner Of Vs. Income Tax, Corporate Circle 1(1), Chennai. (प्रत्यर्थी/Respondent) Shri Sandeep Bagmar, Advocate Shri V. Justin, Cit & Ms. R. Anita, Addl. Cit 08.05.2025 21.05.2025 आदेश / Order 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. -2-

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. -2- ITA Nos.2670 to 2672 & 2698/Chny/2024 2. Common issues are raised in these appeals; hence, they were heard together and are being disposed off by this consolidated order. By the consent of both the parties

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision

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

4 raised by the Revenue i.e. the issue pertaining to disallowance under Section 14A of the Act for all the assessment years requires to be redone. 26. For all the above reasons, the appeals filed by both the Revenue as well as the assessee are allowed and the matters are remanded to the Tribunal to take a fresh decision