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)

depreciation on bogus purchases and addition under section 69A of the Act for AY 2011-12. Thus, the grounds raised by the assessee are allowed for statistical purposes. 29. The next common ground raised in the appeals of the assessee for the assessment years 2011-12, 2012-13, 2013-14 and 2014-15 is with regard to the confirmation

ACIT, CHENNAI vs. MAHAVEER SAFETY GLASS PVT LTD., CHENNAI

In the result, the Revenue’s appeal is dismissed

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5A of the Income –tax Rules,1962) for claiming additional depreciation u/s 32(1) (iia) of the Income-tax Act,1961, was not filed along with the return of income but was filed during assessment proceedings before final order of assessment was made that would amount to sufficient compliance for grant of additional depreciation in terms of section

PENUPETRUNI CHINNA RAO,CHENNAI vs. ITO, INTERNATIONAL TAXATION, WARD-1(1), CHENNAI

In the result, the appeal stand partly allowed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.401/Chny/2022 (िनधा*रण वष* / Assessment Year: 2016-17) Mr. Penupatruni Chinna Rao Ito बनाम 8, Pughs Road, Sundaram Salai, International Taxation, / Vs. R.A. Puram, Chennai-600 028. Ward-1(1), Chennai. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aecpc-1481-R (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Ms. N.V. Lakshmi (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Shri D. Hema Bhupal (Jcit)- Ld. Sr. Dr सुनवाईकीतारीख/Date Of Final Hearing : 04-03-2024 घोषणाकीतारीख /Date Of Pronouncement : 25-04-2024 आदेश / O R D E R

Section 45(5A), though applicable from A.Y. 2018-19, lays down that in cases of specified agreement for development of real estate project, capital gain shall be chargeable to tax in the year in which completion certificate is given by the competent authority. This will put at rest many disputes arising in cases of JDA regarding the year in which

DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

5A of New Appendix 1 read with Rule 5, the assessee is entitled for 50% depreciation on new motor vehicles acquired and put to use after certain dates. However, the Assessing Officer as well as the learned CIT(A) has relied upon Circular No. 609 dated 29.07.1991 and judgement of Hon’ble Bombay High Court in the case

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP CIRCLE 8, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

5A of New Appendix 1 read with Rule 5, the assessee is entitled for 50% depreciation on new motor vehicles acquired and put to use after certain dates. However, the Assessing Officer as well as the learned CIT(A) has relied upon Circular No. 609 dated 29.07.1991 and judgement of Hon’ble Bombay High Court in the case

DEPUTY COMMISSIONER OF INCOMETAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1282, 1283, 1284 & 1285/Chny/2024 निर्धारण वर्ष/Assessment Years: 2011-12, 2016-17, 2017-18 & 2018-19 M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. V. The Dcit, Non Corporate Circle-8, Chennai. [Pan: Aabcc 6633 K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.470, 1339, 1438, 1462 & 1463/Chny/2024 निर्धारण वर्ष/Assessment Years: 2012-13, 2018-19, 2011-12, 2016-17 & 2017-18 The Dcit, Non Corporate Circle-8, Chennai. (अपीलार्थी/Appellant) V. M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. [Pan: Aabcc 6633 K] (प्रत्यर्थी/Respondent) Assessee By Department By : Mr. Sandeep Bagmar, Advocate; Mr. Balachandar, Fca : Mr. Nilay Baran Som, Cit सुनवाईकीतारीख/Date Of Hearing : 22.01.2025 घोषणाकीतारीख /Date Of Pronouncement : 19.03.2025

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed....". It is noted that the Hon'ble Coordinate Bench has considered the ratios laid down by Hon'ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon'ble Calcutta High Court. 13.4 Further we have noted that Hon'ble Delhi High Court

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP CIRCLE 8, CHENNAI

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed...." It is noted that the Hon'ble Coordinate Bench has considered the ratios laid down by Hon'ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon'ble Calcutta High Court. 13.4 Further we have noted that Hon'ble Delhi High Court

DEPUTY COMMISSINOER OF INCOME TAX,, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita Nos.1282, 1283, 1284 & 1285/Chny/2024 निर्धारण वर्ष/Assessment Years: 2011-12, 2016-17, 2017-18 & 2018-19 M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. V. The Dcit, Non Corporate Circle-8, Chennai. [Pan: Aabcc 6633 K] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita Nos.470, 1339, 1438, 1462 & 1463/Chny/2024 निर्धारण वर्ष/Assessment Years: 2012-13, 2018-19, 2011-12, 2016-17 & 2017-18 The Dcit, Non Corporate Circle-8, Chennai. (अपीलार्थी/Appellant) M/S. Cholamandalam Ms General Insurance Co. Ltd., Dare House, 2Nd Floor, No.2, N.S.C. Bose Road, Chennai-600 001. [Pan: Aabcc 6633 K] (प्रत्यर्थी/Respondent) Assessee By Mr. Sandeep Bagmar, Advocate; Mr. Balachandar, Fca Department By Mr. Nilay Baran Som, Cit सुनवाईकीतारीख/Date Of Hearing 22.01.2025 घोषणाकीतारीख /Date Of Pronouncement 19.03.2025

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed...." It is noted that the Hon'ble Coordinate Bench has considered the ratios laid down by Hon'ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon'ble Calcutta High Court. 13.4 Further we have noted that Hon'ble Delhi High Court

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP WARD 8, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

5A of New Appendix 1 read with Rule 5, the assessee is entitled for 50% depreciation on new motor vehicles acquired and put to use after certain dates. However, the Assessing Officer as well as the learned CIT(A) has relied upon Circular No. 609 dated 29.07.1991 and judgement of Hon’ble Bombay High Court in the case

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

5A of New Appendix 1 read with Rule 5, the assessee is entitled for 50% depreciation on new motor vehicles acquired and put to use after certain dates. However, the Assessing Officer as well as the learned CIT(A) has relied upon Circular No. 609 dated 29.07.1991 and judgement of Hon’ble Bombay High Court in the case

DEPUTY COMMISSIONER OF INCOME TAX OFFICER , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

5A of New Appendix 1 read with Rule 5, the assessee is entitled for 50% depreciation on new motor vehicles acquired and put to use after certain dates. However, the Assessing Officer as well as the learned CIT(A) has relied upon Circular No. 609 dated 29.07.1991 and judgement of Hon’ble Bombay High Court in the case

ACIT, COIMBATORE vs. M/S. CRAFTSMAN AUTOMATION PVT LIMITED, COIMBATORE

In the result, the appeals of the Revenue for the AYs 2003-04 &

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

5A in form 3AA signed by either a Chartered Accountant or any person entitled to be appointed to act as an Auditor as per provision of Sec.226, subsection (2) of Companies Act, 1956 has been filed. 4. The learned CIT(A) ought to have considered that the production capacity in any manufacturing industry consists of three ingredients namely (1) license

ACIT, COIMBATORE vs. M/S. CRAFTMAN AUTOMATION PVT LIMITED, COIMBATORE

In the result, the appeals of the Revenue for the AYs 2003-04 &

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

5A in form 3AA signed by either a Chartered Accountant or any person entitled to be appointed to act as an Auditor as per provision of Sec.226, subsection (2) of Companies Act, 1956 has been filed. 4. The learned CIT(A) ought to have considered that the production capacity in any manufacturing industry consists of three ingredients namely (1) license

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

depreciation @ 60% on UPS, printers and routers etc. as claimed by the assessee. 9. In the result, appeal filed by the assessee for AY 2014-15 is partly allowed for statistical purposes. ITA No.2867/Chny/2024 (AY 2016-17): 10. For the AY 2016-17, the assessee has raised two grounds of appeal–(i) Disallowance u/s.14A r.w. Rule 8D amounting to Rs.40

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

depreciation @ 60% on UPS, printers and routers etc. as claimed by the assessee. 9. In the result, appeal filed by the assessee for AY 2014-15 is partly allowed for statistical purposes. ITA No.2867/Chny/2024 (AY 2016-17): 10. For the AY 2016-17, the assessee has raised two grounds of appeal–(i) Disallowance u/s.14A r.w. Rule 8D amounting to Rs.40

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

depreciation @ 60% on UPS, printers and routers etc. as claimed by the assessee. 9. In the result, appeal filed by the assessee for AY 2014-15 is partly allowed for statistical purposes. ITA No.2867/Chny/2024 (AY 2016-17): 10. For the AY 2016-17, the assessee has raised two grounds of appeal–(i) Disallowance u/s.14A r.w. Rule 8D amounting to Rs.40

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.2865, 2866, 2867 & 2868/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2010-11, 2014-15, 2016-17 & 2018-19) M/S. Carborundum Universal Vs The Assistant Commissioner Of Income-Tax, Limited, No. 43, Vi Floor, Parry House Moore Street,Chennai Gpo Parrys, – 600 001. Pan: Aaacc-2474-P (अपीलार्थी/Appellant) Large Taxpayer Unit-1, Chennai. (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/ Appellant By : Mr.R.Vijayaraghavan, Advocate प्रत्यर्थीकीओरसे/Respondent By : Mrs.Samantha Mullamudi, Addl.Cit सुनवाईकी तारीख/Date Of Hearing : 27.03.2025 घोषणाकीतारीख / Date Of Pronouncement : 05.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)]All Dated10.09.2024 For Assessment Years 2010-11, 2014-15, 2016-17 & 2018-19.Since The Facts & Issues Are Common In These Appeals, They Are Heard Together & Disposed Off By This Common Order.

depreciation @ 60% on UPS, printers and routers etc. as claimed by the assessee. 9. In the result, appeal filed by the assessee for AY 2014-15 is partly allowed for statistical purposes. ITA No.2867/Chny/2024 (AY 2016-17): 10. For the AY 2016-17, the assessee has raised two grounds of appeal-(i) Disallowance u/s.14A r.w. Rule 8D amounting to Rs.40

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

depreciation claimed on motor vehicles. The assessee has claimed depreciation @ 50% on motor vehicles as per Rule 5 read with Appendix I clause III (Machinery & Plant) (via), as per which new motor vehicles purchased after certain dates is entitled for 50% depreciation. The Assessing Officer has allowed depreciation @ 15% as per Item 3 of Part A of Appendix - entry