M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

section 32 the same has to be taken as the cost as if the succession from firm to company had not taken place that is Nil. Thus on the issue of claim of depreciation on goodwill it is held that Depreciation would be available on Nil value only i.e. Nil. The claim made by the appellant is thus not found

DCIT CORPORATE CIRCLE 6(2), CHENNAI vs. SUNDARAM CLAYTON LTD., CHENNAI

In the result, appeals filed by Revenue and the assessee

Bench: Shri V.Durga Rao & Shri G.Manjunatha

depreciation was allowable on the plant and machinery only for the year in which the capacity expansion had taken place 4) For these and other grounds that may be adduced at the time of hearing, it is prayed that the Order of the Commissioner of Income Tax (Appeals) be set aside and that of the Assessing Officer be restored

SUNDARAM CLAYTON LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, appeals filed by Revenue and the assessee

Bench: Shri V.Durga Rao & Shri G.Manjunatha

depreciation was allowable on the plant and machinery only for the year in which the capacity expansion had taken place 4) For these and other grounds that may be adduced at the time of hearing, it is prayed that the Order of the Commissioner of Income Tax (Appeals) be set aside and that of the Assessing Officer be restored

SUNDARAM CLAYTON LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, appeals filed by Revenue and the assessee

Bench: Shri V.Durga Rao & Shri G.Manjunatha

depreciation was allowable on the plant and machinery only for the year in which the capacity expansion had taken place 4) For these and other grounds that may be adduced at the time of hearing, it is prayed that the Order of the Commissioner of Income Tax (Appeals) be set aside and that of the Assessing Officer be restored

DCIT CORPORATE CIRCLE 6(2), CHENNAI vs. SUNDARAM CLAYTON LTD., CHENNAI

In the result, appeals filed by Revenue and the assessee

Bench: Shri V.Durga Rao & Shri G.Manjunatha

depreciation was allowable on the plant and machinery only for the year in which the capacity expansion had taken place 4) For these and other grounds that may be adduced at the time of hearing, it is prayed that the Order of the Commissioner of Income Tax (Appeals) be set aside and that of the Assessing Officer be restored

AGILE ELECTRIC SUB ASSEMBLY (P) LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal is disposed of in the aforesaid terms

Bench: Shri Sanjay Arora & Shri G. Pavan Kumarआयकर अपील सं./Ita No.2497/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

260 ITR 433 (Mad)), also moved by the fact that the issue of loss and depreciation are inter- connected, if not intertwined, in-as-much as the provision of s. 72A is equally applicable and required to be met for both, and on a continuing basis. An anomalous situation on the non-satisfaction of the conditions of s. 72A - which

DCIT CORPORATE CIRCLE 1(1), CHENNAI vs. A.V.THOMAS LEATHER AND ALLIED PRODUCTS PVT. LTD., CHENNAI

In the result, the appeal filed by the Revenue is allowed for statistical purposes

Bench: Shri Ramit Kochar & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 2309/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of M/S. A.V. Thomas Leather & Allied Income Tax, Vs. Products Pvt. Ltd., No. 22, Marshalls Corporate Circle 1(1), Road, Egmore, Chennai 600 008. Chennai 600 034. [Pan:Aaaca6246K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Guru Bashyam, Addl. Cit ""थ" की ओर से/Respondent By : Shri Sanjeev Aditya, C.A. सुनवाई की तारीख/ Date Of Hearing : 28.11.2019 घोषणा की तारीख /Date Of Pronouncement : 05.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai, Dated 21.05.2018 Relevant To The Assessment Year 2014-15. The Effective Ground Raised In The Appeal Of The Revenue Is That The Ld. Cit(A) Has Erred In Deleting The Disallowance Under Section 14A R.W. Rule 8D While Computing Book Profit Under Section 115Jb Of The Income Tax Act, 1961 [“Act” In Short].

depreciation, disallowance under section 40(a)(i) and disallowance of commission expenses under section 37 of the Act. The tax payable was computed on book profit under section 115JB of the Act as the same was higher than the normal computation. Subsequently, on perusal of the assessment records, the Assessing Officer has noticed that the assessee company itself has disallowed

M/S. CHENNAI PETROLEUM CORPORATION LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, both the assessee’s and the Revenue’s appeals are partly allowed and partly allowed for statistical purposes

Bench: Shri Sanjay Arora & Shri George Mathanआयकर अपील सं./Ita No.1858/Mds/2011 "नधा"रण वष" / Assessment Year : 2004-05 Chennai Petroleum Corporation Ltd., Asst. Commissioner Of Income Refinery House, Manali, Vs. Tax, Chennai – 600 068 Company Circle-I(3), [Pan: Aaacm 4392C] Chennai – 600 034 (अपीलाथ" /Appellant) (""यथ"/Respondent)

section 32(1). Can, for example, a plant or machinery, which could not be used for want of (say) 19 ITA Nos. 1858 & 1980/Mds/2011 (AY 2004-05) Chennai Petroleum Corporation Ltd. feedstock or energy, be regarded as ‘used’, so as to be eligible for depreciation. The answer, to our mind, would depend on whether the same is functional as also

MTANDT RENTALS LIMITED,THIRUVALLUR vs. ITO CORPORATE WARD 4(3), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.2410/Chny/2017 "नधा"रण वष" /Assessment Year : 2014-2015. M/S. Mtandt Rentals Ltd, Vs. The Income Tax Officer, No.62/2B, New No.99, Old No.144, Corporate Ward 4(3) Padur Village, Chennai. Poonamallee Taluk. Tiruvallur - 602 105. [Pan Aagcm 2269J (अपीलाथ"/Appellant) (""यथ"/Respondent)

depreciation purpose. CIT Vs Theatre SriRangaraj (Mad) 260 ITR 453 Assessee company received capital assets from its holding company- WDV to be worked on the basis of Expl.6 to sec.43(1) and sec.47(iv) -Chanqe in shareholdinq subsequently and before the close of the accounting year will not alter this legal position. DCIT Vs NTPC -SAIL Power supply

INDUS CITYSCAPES,CHENNAI vs. DCIT CORPORATE CIRCLE 2 (2), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1226/Chny/2018 िनधा"रण वष"/Assessment Year: 2008-09 M/S. Indus Cityscapes Constructions Vs. The Deputy Commissioner Of Pvt. Ltd., No. 5-C, Ega Trade Centre, Income Tax, 809, Poonamalle High Road, Kilpauk, Corporate Circle 2(2), Chennai 600 010. Chennai. [Pan:Aabci2175A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri T. Banusekar, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 06.09.2022 घोषणा की तारीख /Date Of Pronouncement : 16.09.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-13, Chennai Dated 06.12.2017 Relevant To The Assessment Year 2008-09. 2. Facts Are, In Brief, That The Assessee Company Is Carrying Real Estate, Construction & Related Activities, Filed Return Of Income For The Assessment Year 2008-09 On 30.09.2008 Declaring A Total Income Of ₹.84,76,260/- & The Same Was Processed Under Section 143(1) Of The 2

260/- and the same was processed under section 143(1) of the 2 I.T.A. No.1226/Chny/18 Income Tax Act, 1961 [“Act” in short]. The case was selected for scrutiny and the assessment under section 143(3) of the Act was completed on 23.12.2010 on an income of ₹.6,79,89,064/-. Subsequently a notice under section 148 of the Act dated

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

260\nCorporation\n4\nApnic Pty Ltd\nAustralia\nAUD\n7,226\n3,28,677\n5\nAtlassian\nAustralia\nUSD\n5,139\n2,30,484\nSoftware\nSystems Pty\nLtd\n6\nFlexera\nUnited\nUSD\n8,592\n3,85,351\nSoftware Ltd\nKingdom\n(Ind)\n7\nMobile\nUSA\nUSD\n4,900\n2,18,197\nComplete Inc\n8\nParasoft\nUSA\nUSD

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

260\n| Corporation\n| 4 | Apnic Pty Ltd\n| Australia\n| AUD\n| 7,226\n| 3,28,677\n\n- 22 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\n| 5 | Atlassian\n| Australia\n| USD\n| 5,139\n| 2,30,484\n| Software\n| Systems Pty\n| Ltd\n| 6 | Flexera\n| United

LIFECELL INTERNATIONAL PVT LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita No.: 3334/Chny/2019 िनधा"रण वष" / Assessment Year: 2016-17 M/S. Lifecell International Assistant Commissioner Of Private Ltd., V. Income Tax, No. 26, Vandalur Corporate Circle 4(1), Kelambakkam Main Road, Chennai. Keelakkottaiyur, Chennai. [Pan: Aaeca-7997-B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Ajith Kumar Choradia, Ca ""यथ" क" ओर से/Respondent By : Shri. S. Senthil Kumaran, Cit सुनवाई की तारीख/Date Of Hearing : 23.11.2022 घोषणा की तारीख/Date Of Pronouncement : 04.01.2023 आदेश /O R D E R

260 ITR 102 had explained the concept of matching principle as under:- "The mercantile system of accounting is based on accrual. Basically, it is a double entry system of accounting. Under the mercantile system of accounting, profits arising or accruing at the date of the transaction are liable to be taxed notwithstanding the fact that they are not actually received