ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

depreciation on intangible assets.\n15. Adverting to the finding of the AO that the goodwill cannot be self-\ngenerated and that the claim of the assessee is on account of self-generated\ngoodwill is not correct. The AO has relied upon Explanation 7 to section 43(1)\nand Explanation 2(b) to section 43(6

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

depreciation shall be calculated on the written down value u/s.32(1)(ii) of the Act, and as per explanation-2 to Section 32(1) of the Act, written down value of the block assets shall have the same meaning as in clause-c of sub-section 6 of section 43

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

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation

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

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation

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

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation

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

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation

M/S. HYUNDAI MOTOR INDIA LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

section 43(1) of the Act and that the subsidy was intended to offset the cost of assets. By the impugned order dated 09.12.2024, the Ld. PCIT set aside the order giving effect and directed the AO to apportion the subsidy among :-3-: ITA. No:434/Chny/2025 various blocks of assets and reduce the same from WDV for recomputation of depreciation

HAMEED MARINE PRIVATE LIMITED,EDALAKUDY, NAGERCOIL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGERCOIL, INCOME TAX OFFICE, NAGERCOIL

In the result, Grounds relating to validity of notice u/s 143(2) are dismissed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

depreciation with reference to an enhanced cost) as required under Explanation 3 to section 43(1). 5. The learned CIT (Appeals) erred in confirming the action of the assessing officer in determining the actual cost of the second hand machinery at Nil without taking the approval of the Addl/Joint CIT as required under Explanation 3 to section 43(1). 6

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

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

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 43(1) of the Act. However, the Assessing Officer chose to examine the valuation of goodwill alone in order to disallow the claim of depreciation on the ground that value of goodwill is enhanced. Accordingly, the Assessing Officer disallowed the claim of depreciation on goodwill amounting to ₹.6

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 43(1) of the Act. However, the Assessing Officer chose to examine the valuation of goodwill alone in order to disallow the claim of depreciation on the ground that value of goodwill is enhanced. Accordingly, the Assessing Officer disallowed the claim of depreciation on goodwill amounting to ₹.6