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...

92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

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...

92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

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...

92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets of such enterprises

TWENTY FIRST CENTURY MANAGEMENT SERVICES LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita No.1470/Mds/2016 "नधा"रण वष" /Assessment Year: 2005-06

section 92E;] (c) where an assessment has been made, but— (i) income chargeable to tax has been underassessed ; or such income has been assessed at too low a rate41 ; or (ii) (iii) such income has been made the subject of excessive relief under this Act ; or (iv) excessive loss or depreciation

JESUDASON BIJI ,CHENNAI vs. OFFICE OF INCOME TAX OFFICER INT. TAXN WARD1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

section 92E; (c) where an assessment has been made, but— (i) income chargeable to tax has been under assessed; or (ii) such income has been assessed at too low a rate; or (iii) such income has been made the subject of excessive relief under this Act; or (iv) excessive loss or 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)

92E "international transaction" means a transaction between two or more associated enterprises, either or both of whom are non more associated enterprises, either or both of whom are non-residents, residents, in the nature of purchase, sale or lease of tangible or intangible in the nature of purchase, sale or lease of tangible or intangible in the nature of purchase

ACIT, CHENNAI vs. M/S. SKI RETAIL PVT. LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed whereas, the cross-objection filed by the assessee stands allowed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita No.2276/Mds/2016 & C.O. No.129/Mds/2016 (In I.T.A. No.2276/Mds/2016) "नधा"रण वष" / Assessment Year : 2007-08

section 92E ; (c) where an assessment has been made, but-- (i) income chargeable to tax has been under assessed; or (ii) such income has been assessed at too low a rate; or (iii) such income has been made the subject of excessive relief under this Act; or 8 I.T.A. No.2276/Mds/16 C.O. No.129/Mds/16 (iv) excessive loss or depreciation

ACIT, MADURAI vs. ARUNA ALLOY STEELS PRIVATE LTD., MADURAI

In the result, the Revenue’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.3, 933 & 847/Mds/2016 "नधा"रण वष" / Assessment Years : 2006-07, 2008-09 & 2007-08 The Assistant Commissioner Of M/S Aruna Alloy Steels (P) Ltd., Income Tax, V. Super B-3, Industrial Estate, Corporate Circle I, K-Pudur, Madurai – 625 007. Madurai. Pan : Aaeca 6781 D (अपीलाथ"/Appellant) (""यथ"/Respondent)

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall

ACIT, MADURAI vs. ARUNA ALLOY STEELS PRIVATE LTD., MADURAI

In the result, the Revenue’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.3, 933 & 847/Mds/2016 "नधा"रण वष" / Assessment Years : 2006-07, 2008-09 & 2007-08 The Assistant Commissioner Of M/S Aruna Alloy Steels (P) Ltd., Income Tax, V. Super B-3, Industrial Estate, Corporate Circle I, K-Pudur, Madurai – 625 007. Madurai. Pan : Aaeca 6781 D (अपीलाथ"/Appellant) (""यथ"/Respondent)

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall

ACIT, MADURAI vs. ARUNA ALLOY STEELS (P) LTD., MADURAI

In the result, the Revenue’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.3, 933 & 847/Mds/2016 "नधा"रण वष" / Assessment Years : 2006-07, 2008-09 & 2007-08 The Assistant Commissioner Of M/S Aruna Alloy Steels (P) Ltd., Income Tax, V. Super B-3, Industrial Estate, Corporate Circle I, K-Pudur, Madurai – 625 007. Madurai. Pan : Aaeca 6781 D (अपीलाथ"/Appellant) (""यथ"/Respondent)

depreciation allowance or any other allowance, as the case may be, for the assessment year concerned (hereafter in this section and in sections 148 to 153 referred to as the relevant assessment year): Provided that where an assessment under sub-section (3) of section 143 or this section has been made for the relevant assessment year, no action shall

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)

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 of TP adjustment Particulars Reference Amount

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

section 92E; (c) where an assessment has been made, but— (i) income chargeable to tax has been under assessed ; or (ii) such income has been assessed at too low a rate ; or (iii) such income has been made the subject of excessive relief under this Act ; or (iv) excessive loss or depreciation

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

section 92E; (c) where an assessment has been made, but— (i) income chargeable to tax has been under assessed ; or (ii) such income has been assessed at too low a rate ; or (iii) such income has been made the subject of excessive relief under this Act ; or (iv) excessive loss or depreciation

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

section 92E; (c) where an assessment has been made, but— (i) income chargeable to tax has been under assessed ; or (ii) such income has been assessed at too low a rate ; or (iii) such income has been made the subject of excessive relief under this Act ; or (iv) excessive loss or depreciation

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

92E of the Act. The appellant filed the return of income for the AY 2010-11 to AY 2015-16 declaring total income as under:\nAsst Year Date of filing Returned Income/(Loss) Book profits u/s.\nof ROI under 115JB of the Act\nnormal\nprovisions\n2010-11 25-09-2010 (89,63,844)\n2011-12 29-11-2011 Nil\n2012

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

92E of the Act. The appellant filed the return of income for the AY 2010-11 to AY 2015-16 declaring total income as under:\nAsst Year\nDate of filing\nReturned\nIncome/(Loss)\nBook\nprofits u/s.\n115JB of the Act\nof ROI\nunder\nnormal\nprovisions\n2010-11\n25-09-2010\n(89,63,844)\n2011-12\n29-11-2011\nNil