GATEWAY OFFICE PARKS PRIOVATE LIMITEDI,CHENNAI vs. ACIT, CORPORATE CICLE-6(1), CHENNAI

In the result, the appeal of the assessee is partly allowed

viib) of sub-section (2) of section 56 shall be\nthe value, on the valuation date, of such unquoted equity shares as determined in\nthe following manner under clause (a) or clause (b), at the option of the assessee,\nnamely:-\n(a) The fair market value of unquoted equity shares =| (A-L)(PE)| x (PV)\nwhere,\nPage

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

In the result, the appeal in ITA No

depreciation? 2. Applicability of Section 56(2)(viib) to shares issued to non-residents.3. Disallowance of expenses under Section

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

depreciation on goodwill, which was confirmed by the CIT(A). Thus, we set aside the order of the CIT(A) and the addition made by the Assessing Officer stands deleted for all the assessment years under consideration. ITA Nos.2670 to 2672 & 2698/Chny/2024 18. The next ground raised by the assessee in ground Nos. 3.1 to 3.6 for the assessment year

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

depreciation on goodwill, which was confirmed by the CIT(A). Thus, we set aside the order of the CIT(A) and the addition made by the Assessing Officer stands deleted for all the assessment years under consideration. ITA Nos.2670 to 2672 & 2698/Chny/2024 18. The next ground raised by the assessee in ground Nos. 3.1 to 3.6 for the assessment year

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

depreciation and cannot constitute income in the hands of the appellant. Even according to the TP order the profit margin of MIPP was 26.67%. Rs.245 Crores remains unpaid to MIPP. Downward adjustment made for two years only (AYs 2013-14 and 2014-15) and that does not match the share premium of Rs.1973.77 crores (Rs.1847.05 crores in RKM + Rs.126.72 crores

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

In the result, the appeal in ITA No

depreciation was set aside.", "result": "Allowed", "sections": [ "250", "143(1)", "143(2)", "142(1)", "32", "43(1)", "47", "170", "40(a)(i)", "195", "56(2)(viib

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

depreciation and cannot constitute income in\nthe hands of the appellant. Even according to the TP order\nthe profit margin of MIPP was 26.67%. Rs.245 Crores\nremains unpaid to MIPP. Downward adjustment made for\ntwo years only (AYs 2013-14 and 2014-15) and that does\nnot match the share premium of Rs.1973.77 crores\n(Rs.1847.05 crores in RKM + Rs.126.72

M/S SHRIRAM PROPERTIES LIMITED,CHENNAI vs. PCIT-CENTRAL1, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 431/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

section 56(2)(viib) of the Act. This fact has been explained to the :-43-: ITA. No: 431/Chny/2022 PCIT, however, he has misunderstood the facts merely for the reason that there is increase in security premium account when compare to year ending 31.03.2016. But, fact remains that said entry is only a disclosure requirement in compliance with IND-AS standards

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

viib) of the Act, but confirmed addition made towards storage fees received in advance and partly allowed relief towards addition u/s. 35(2AB) of the Act. 4. The first issue that came up for our consideration from ground no. 5 to 19 of assessee’s appeal is addition towards storage fee received in advance amounting to Rs. 89,56