DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

TRIVITRON HEALTH CARE PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.1340/Chny/2019 िनधा"रण वष" /Assessment Year: 2014-15 V. M/S.Trivitron Healthcare Pvt. Ltd., The Dy. Commissioner- “Sapthagiri Bhavan”, Of Income Tax, New No.15, Old No.25, Corporate Circle-3(1), Trivitron Sapthagiri Bhawan, Chennai. 4Th Street, Abhiramapuram, Chennai. [Pan: Aaact 9378 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Depreciation on goodwill, Provision for warranty and Disallowance under 14A read with Rule 8D to the Assessing Officer for verification. The Appellant submits: a) There is no ground to revise the order passed earlier under section 143(3) by the AO under section 263 of the IT Act; b) The order passed by the AO is not erroneous

DDIT, CHENNAI vs. VELS INSTITUTE OF SCIENCE, TECHNOLOGY & ADVANCED STUDIES,, CHENNAI

In the result, both the appeal of the Revenue and the cross- objection of the assessee stand dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1759/Mds/2013 & C.O. No.15/Mds/2014 (In I.T.A. No.1759/Mds/2013) "नधा"रण वष" / Assessment Year : 2010-11

92,078/-, the assessee is entitled for exemption under Section 11 of the Act. Therefore, this Tribunal do not find any infirmity in the order of the CIT(Appeals) and accordingly, confirmed. 12 I.T.A. No.1759/Mds/13 C.O. No.15/Mds/14 10. The assessee has filed the cross-objection claiming depreciation

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

92,00,000/-. Therefore, according to him, disallowance . Therefore, according to him, disallowance u/s.14A u/s.14A r.w.r.8D r.w.r.8D was was required. required. The The AO AO accordi accordingly ngly computed computed disallowance of Rs.8,28,74,299/ disallowance of Rs.8,28,74,299/- under Rule 8D. Having regard to the under Rule 8D. Having regard to the fact that the assessee

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

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 of the Act and thus, we direct the AO to allow depreciation on brand value from the year in which the assessee is entitled for such depreciation. 12. The next two common issues in all these 7 appeals of assessee are as regards to addition of construction expenses in regard to Anbu Illam Thulir School and RJ Mantra

INTERNATIONAL SEAPORT DREDGING PRIVATE LIMITED,CHENNAI vs. PCIT - 1, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI MANU KUMAR GIRI (Judicial Member)

depreciation against the current year income (1) (2) (3) (4) i 2016-17 ii 2013-14 14491494 14491494 iii 2012-13 148847374 148847374 iv 2010-11 270130659 270130659 v 2009-10 164803652 164803652 vi Total 598273179 598273179 ii. Facts and figures and issues recorded in ‘Reasons for reopening u/s 147’ (para 3 supra) is similar as observed by the ld.CIT

RENAULT INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No. 1078/Mds/2017 "नधा"रण वष" /Assessment Year : 2012-2013. M/S. Renault India Private Vs. The Deputy Commissioner Of Limited, Income Tax, No.37 & 38, Asv Ramana Corporate Circle 5(1) Towers, Chennai. 4Th Floor, Venkatnarayana Road, T.N Agar, Chennai 600 017. [Pan Aadcr 2042M ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

92,69,63,491 Add: Depreciation 2,67,72,822 Add: Interest 3,73,57,238 Less: Cost of design 11,63,79,436 engineering and related services Less: TP adj in 62,26,00,000 RNAIPL Adjusted cost 5,25,21,14,115 Net Loss -1,70,38,02,781 Net loss on Revenue -48.02% :- 9 -: Computation

M/S T vs. MOTOR COMPANY LIMITED,CHENNAIVS.ACIT CORPORATE CIRCLE 3 (1), CHENNAI

In the result, the appeal of the Revenue and the assessee are\ndecided as under:-\n\n| ITA Nos\n| Assessment\nYear\nResult\n| IT(TP)A No

Section 92C(2) of the Act postulates that if the difference between the actual price and the ALP is less than 3% no addition is required to be made. The Ld. Counsel for the assessee submitted that it operates its business in a captive customer scenario. Thus, it was argued that the assessee is doing captive or to say customized