UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

disallowance\nunder section 14A r.w. Rule 8D is not applicable to insurance companies\ndue to the special provisions of section 44 of the Act. Similarly, in the\ncase of Cholamandalam MS General Insurance Co. Ltd. v. DCIT [2025]\n174 taxmann.com 603 (Madras), the Hon'ble High Court of Madras was\npleased to hold that the provisions of section

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

Disallowance for book profits under Section 115JB was deleted. Penalty proceedings were kept open.", "result": "Partly Allowed", "sections": [ "14A", "8D", "40(a)(i)", "9(1)(vii)", "10A", "10AA", "115JB", "195", "271(1)(c)", "274", "10(35)", "10(38)", "12

ICF SILVER JUBILEE NURSERY & PRIMARY SCHOOL,CHENNAI vs. DCIT NON CORP WARD 10(1), CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 126/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19 Icf Silver Jubilee Nursery & Deputy Commissioner Of Income Primary School, V. Tax, Konnur High Road, Non Corporate Ward -10(1), Chennai – 600 038. Chennai. [Pan: Aabai-0461-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. D. Anand, Advocate ""यथ" क" ओर से/Respondent By : Ms. R. Anita, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 04.02.2025 घोषणा क" तारीख/Date Of Pronouncement : 14.02.2025 आदेश /O R D E R Per S. R. Raghunatha:

section 10(23C)(iiiad). and prayed for deleting the addition. 10. Per contra, the ld.DR stated that the assessee is running educational institution in the same building and the same teaching staff is teaching for both the entities as seen in the website of the society and hence, the decision of the ld.AO and that of the ld.CIT

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

12,52,512/- is being disallowed u/s 40(a)(i)\nof the Income-tax Act and it is added to the total income of the current year.\n3.5.8 Basis the above, I am of the considered opinion that the AO has rightly\nrejected the claim of the Appellant. Therefore, the grounds of appeal no 15 to\n27 stand dismissed

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

12 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\nalso submitted that the regarding the issue of enhancement of the\nexemption u/s.10A, 10AA of the Act, this issue was not discussed by\nthe Ld. CIT(A) in their orders.\n\n5.3 For AY 2010-11 the Assessee submitted that the AO provided\nthe relief under Section 10A / 10AA

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

12,52,512/- is being disallowed u/s 40(a)(i)\nof the Income-tax Act and it is added to the total income of the current year.\n3.5.8 Basis the above, I am of the considered opinion that the AO has rightly\nrejected the claim of the Appellant. Therefore, the grounds of appeal no 15 to\n27 stand dismissed

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

12,52,512/- is being disallowed u/s 40(a)(i)\nof the Income-tax Act and it is added to the total income of the current year.\n3.5.8 Basis the above, I am of the considered opinion that the AO has rightly\nrejected the claim of the Appellant. Therefore, the grounds of appeal no 15 to\n27 stand dismissed

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

Disallowance under Section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

12,52,512/- is being disallowed u/s 40(a)(i)\nof the Income-tax Act and it is added to the total income of the current year.\n3.5.8 Basis the above, I am of the considered opinion that the AO has rightly\nrejected the claim of the Appellant. Therefore, the grounds of appeal no 15 to\n27 stand dismissed

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

10. The learned CIT(A) has erred in not considering the submissions of the Appellant that the said issue is decided by the Hon’ble ITAT in the Appellant’s favor in an earlier AY in ITA No. 1202/Mds/2013. 11. Without prejudice to the above, the learned CIT(A) has failed to consider the fact that disallowance under section

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

10. The learned CIT(A) has erred in not considering the submissions of the Appellant that the said issue is decided by the Hon’ble ITAT in the Appellant’s favor in an earlier AY in ITA No. 1202/Mds/2013. 11. Without prejudice to the above, the learned CIT(A) has failed to consider the fact that disallowance under section

IDFC LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE II(3), CHENNAI

In the result, the appeal filed by the assessee in ITA\nNo

10,00,00,000/- is within permissible limit\nprescribed in section? Ld. AR fairly agreed that it is not\nreflected in the orders of lower-authorities. Ld. AR,\nhowever, raised a plea that the assessee was entitled to\nmuch higher deduction but claimed only Rs.\n10,00,00,000/-. In absence of any finding on this aspect\nby lower-authorities

DCIT, CEN CIR 2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

10 would be much wider than the one available under sub-section (2) of section 12.” 10.15 The decision rendered by the Hon’ble Supreme Court in the case of Indian Bank Limited v. CIT [56 ITR 77] is also found to be relevant in the given facts before us. In the decided case, the Hon'ble Supreme Court

DCIT, CC2(2), CHENNAI, CHENNAI vs. JAYAPRIYA COMPANY, CHENNAI

In the result, both the appeals of the Revenue are dismissed and

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

10 would be much wider than the one available under sub-section (2) of section 12.” 10.15 The decision rendered by the Hon’ble Supreme Court in the case of Indian Bank Limited v. CIT [56 ITR 77] is also found to be relevant in the given facts before us. In the decided case, the Hon'ble Supreme Court

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

10 -: On appeal, it was submitted before the CIT(A) that for the assessment year under Appeal viz., 2013-14, the AO has applied amended provisions of Rule 8D which came into force on 2nd June 2016. However, CIT(A) following the order of his predecessor for the assessment year 2015 16, confirmed the disallowances made by the AO. Aggrieved

KAUMARA MADALAYAM,COIMBATORE vs. DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), COIMBATORE, COIMBATORE

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri S.R. Raghunathaआयकर अपील सं./Ita No.680/Chny/2024 िनधा:रण वष: /Assessment Year: 2015-16 Kaumara Madalayam, The Dy. Commissioner Of Income Chinnavedampatti Post, Vs. Tax (Exemptions), Coimbatore – 641 049. Coimbatore. [Pan: Aabtk 6034B]. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथG की ओर से/ Assessee By : Shri N.V. Krishnan, Advocate IjथG की ओर से /Revenue By : Shri N. Sanjay Gandhi, Jcit सुनवाई की तारीख/Date Of Hearing : 13.06.2024 घोषणा की तारीख /Date Of Pronouncement : 30.08.2024 आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), [Nfac], Delhi [Hereinafter Cit(A)] In Din & Order No.Itba/Nfac/S/250/2023-24/1059915043(1), Dated 19.01.2024. The Assessment Was Framed By The Dy. Commissioner Of Income Tax (Exemptions), Coimbatore For The Assessment Year 2015-16 U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’), Vide Order Dated 12.12.2017. :- 2 -: 2. The Assessee Has Raised The Following Grounds Of Appeal:

disallowed the exemption claimed under section 10(23BBA) of the Act and CIT(A) sustained the decision of the It is submitted that the CIT(A) failed consider the implication of the second proviso to section 12A(2) of the Act. ii. It is submitted that the second proviso to section 12A(2) of the Act reads as follows: “Provided