YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

10. The Learned CIT(A) vide order dated 22.09.2023 confirmed the disallowance u/s.10AA of the Act made by the AO. The ld.AR submitted that the AO and the ld.CIT(A) had not denied the fact that the assessee renders services from the SEZ to foreign parties / customers. Before us the ld.AR submitted that the Export has been defined

ABAN OFFSHORE LIMITED,CHENNAI vs. DCIT, INTL, TAX 1(1), CHENNAI

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

disallowance by invoking the\nprovisions of section 40(a)(i) of the Act. In the circumstances, the finding of\nthe learned Commissioner of Income-tax (Appeals) and that of the\nAssessing Officer stands reversed.\n7. We may also mention here that we are not in agreement with the\nsubmission of the learned authorised representative that the provisions of\nsection

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

10. As regards to intervening issue of applicability of provisions of section 40A(3) of the Act and disallowance made by CIT(A) by enhancing the assessment on cash payments, since we have adjudicated the issue of profit rate on unaccounted purchases and consequent sale, the provisions of section 40A(3) of the Act did not apply, where estimation

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

10. As regards to intervening issue of applicability of provisions of section 40A(3) of the Act and disallowance made by CIT(A) by enhancing the assessment on cash payments, since we have adjudicated the issue of profit rate on unaccounted purchases and consequent sale, the provisions of section 40A(3) of the Act did not apply, where estimation

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

10. As regards to intervening issue of applicability of provisions of section 40A(3) of the Act and disallowance made by CIT(A) by enhancing the assessment on cash payments, since we have adjudicated the issue of profit rate on unaccounted purchases and consequent sale, the provisions of section 40A(3) of the Act did not apply, where estimation

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

10. As regards to intervening issue of applicability of provisions of section 40A(3) of the Act and disallowance made by CIT(A) by enhancing the assessment on cash payments, since we have adjudicated the issue of profit rate on unaccounted purchases and consequent sale, the provisions of section 40A(3) of the Act did not apply, where estimation

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

10. As regards to intervening issue of applicability of provisions of section 40A(3) of the Act and disallowance made by CIT(A) by enhancing the assessment on cash payments, since we have adjudicated the issue of profit rate on unaccounted purchases and consequent sale, the provisions of section 40A(3) of the Act did not apply, where estimation

GOLD AK,TENKASI vs. ITO 3(3), CHENNAI

In the result, the appeals filed by the assessee are partly- allowed for statistical purposes as indicated against each of the issues

Bench: Shri Mahavir Singhand Shri Jagadish

10. As regards to intervening issue of applicability of provisions of section 40A(3) of the Act and disallowance made by CIT(A) by enhancing the assessment on cash payments, since we have adjudicated the issue of profit rate on unaccounted purchases and consequent sale, the provisions of section 40A(3) of the Act did not apply, where estimation

ASSISTANT COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), CHENNAI vs. DORMAKABA INDIA PRIVATE LIMITED, KANCHEEPURAM

In the result the appeal of the Revenue is dismissed

Section 10 (2) (xv) of the Act (Indian Income Tax Act, 1922)\nif it satisfies otherwise the tests laid down by the law\".\nConclusion\n47. For the aforementioned reasons, the Court is of the view that as far as the\npresent appeals are concerned, the Revenue has been unable to demonstrate by\nsome tangible material that there is an international

SAI TELECOM,CHENNAI vs. ITO NON CORPORATE WARD 3(3), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manjunatha. Gआयकर अपील सं./Ita No.2534/Chny/2017 िनधा"रण वष" /Assessment Year: 2012-13 M/S. Sai Telecom, The Income Tax Officer, No.407, 4Th Floor, Kaveri Complex, Vs. Non Corporate Ward-3(3), Nungambakkam, Chennai. Chennai – 600 034. [Pan: Abrfs-4178-F] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N. Arjun Raj, C.A ""यथ" क" ओर से /Respondent By : Shri Arv Sreenivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 24.07.2023 घोषणा क" तारीख /Date Of Pronouncement : 15.09.2023

2. The first issue in this appeal of assessee is as regards to the order of CIT(A) confirming the action of the A.O in sustaining the addition of Rs. 44,13,610/- being long term borrowings added as loan creditors u/s. 68 of the Act. The following are long term borrowings added by the A.O as loan creditors: Long