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

22,70,740/- excluded from the total\nincome is incorrect. Be that as it may, there is no dispute with regard to\nissuance of notice dated 31.08.2015 under section 143(2), notice dated\n06.05.2016 under section 142(1) and another notice dated 05.12.2016\nunder section 142(1) of the Act, wherein, the Assessing Officer sought\nexplanations with regard to exemption

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

22,70,740/- excluded from the total\nincome is incorrect. Be that as it may, there is no dispute with regard to\nissuance of notice dated 31.08.2015 under section 143(2), notice dated\n06.05.2016 under section 142(1) and another notice dated 05.12.2016\nunder section 142(1) of the Act, wherein, the Assessing Officer sought\nexplanations with regard to exemption

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

22,70,740/- excluded from the total\nincome is incorrect. Be that as it may, there is no dispute with regard to\nissuance of notice dated 31.08.2015 under section 143(2), notice dated\n06.05.2016 under section 142(1) and another notice dated 05.12.2016\nunder section 142(1) of the Act, wherein, the Assessing Officer sought\nexplanations with regard to exemption

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

22,70,740/- excluded from the total\nincome is incorrect. Be that as it may, there is no dispute with regard to\nissuance of notice dated 31.08.2015 under section 143(2), notice dated\n06.05.2016 under section 142(1) and another notice dated 05.12.2016\nunder section 142(1) of the Act, wherein, the Assessing Officer sought\nexplanations with regard to exemption

NAREN RAJAN,COIMBATORE vs. ACIT, COIMBATORE

In the result, the appeal filed by the assessee for assessment year 2012-13 is partly allowed and appeal filed by the Revenue for assessment year 2012-13 is dismissed

Bench: Shri Mahavir Singh & Shri G. Manjunatha

10% voting right without any clear indication of receiving the amount back to avoid the dividend distribution tax. 8.13 Coming back to the case laws relied upon by the ld. senior standing counsel for the Revenue. The ld. Counsel has relied upon the decision of the Jurisdictional High Court of Madras in the case of Bhagavathy Velan reported

ACIT CORPORATE CIRCLE 2, COIMBATORE vs. LATE SHRI NAREN RAJAN, REP.BY L/H SMT. PADMINI V.R, COIMBATORE

In the result, the appeal filed by the assessee for assessment year 2012-13 is partly allowed and appeal filed by the Revenue for assessment year 2012-13 is dismissed

Bench: Shri Mahavir Singh & Shri G. Manjunatha

10% voting right without any clear indication of receiving the amount back to avoid the dividend distribution tax. 8.13 Coming back to the case laws relied upon by the ld. senior standing counsel for the Revenue. The ld. Counsel has relied upon the decision of the Jurisdictional High Court of Madras in the case of Bhagavathy Velan reported

PADMINI RAJAN, L/R OF LATE (SHRI) NAREN RAJAN,COIMBATORE vs. DCIT CORPORATE CIRCLE 2, COIMBATORE

In the result, the appeal filed by the assessee for assessment year 2012-13 is partly allowed and appeal filed by the Revenue for assessment year 2012-13 is dismissed

Bench: Shri Mahavir Singh & Shri G. Manjunatha

10% voting right without any clear indication of receiving the amount back to avoid the dividend distribution tax. 8.13 Coming back to the case laws relied upon by the ld. senior standing counsel for the Revenue. The ld. Counsel has relied upon the decision of the Jurisdictional High Court of Madras in the case of Bhagavathy Velan reported

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

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 License

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:

22,839/- as total receipt. The assessee was not filed their ITR for the year under consideration. As the assessee is not eligible for exemption u/s.10(23C)(iiad). Hence, Rs.60,07,821/- (1,58,10,382-98,02,561) is to be disallowed and added, and assessed as income of the assessee. Penalty proceeding u/s.270A

ALBERT & CO. P. LTD.,CHENNAI vs. ITO CORPORATE WARD 6(1), CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

10 16. During the assessment proceedings the assessing officer noticed that the Appellant had failed to deduct tax on source on hire charges of Crane, Front End Loader (FEL) and Grab [hereinafter referred to as ‘the Hire Charges’] which were included under the head Sugar/Wheat Handling Charges in the books of accounts. The Appellant contended I.T.A. Nos. 1618/CHNY/2017 &. 2577 & 2578/CHNY/2018

ALBERT & CO. P LTD. ,CHENNAI vs. ITO CORPORATE WARD 6(1) , CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

10 16. During the assessment proceedings the assessing officer noticed that the Appellant had failed to deduct tax on source on hire charges of Crane, Front End Loader (FEL) and Grab [hereinafter referred to as ‘the Hire Charges’] which were included under the head Sugar/Wheat Handling Charges in the books of accounts. The Appellant contended I.T.A. Nos. 1618/CHNY/2017 &. 2577 & 2578/CHNY/2018

ALBERT & CO. P. LTD.,CHENNAI vs. ITO CORPORATE WARD 6(1), CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

10 16. During the assessment proceedings the assessing officer noticed that the Appellant had failed to deduct tax on source on hire charges of Crane, Front End Loader (FEL) and Grab [hereinafter referred to as ‘the Hire Charges’] which were included under the head Sugar/Wheat Handling Charges in the books of accounts. The Appellant contended I.T.A. Nos. 1618/CHNY/2017 &. 2577 & 2578/CHNY/2018

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

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 License

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

section 40(a)(ia) of the Act:\n\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 License

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

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 License

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

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 License

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

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 License

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

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 License

JCIT (OSD), CC - 1(1),, CHENNAI vs. M/S. ABAN INVESTMENT PVT. LTD.,, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.380/Chny/2020 िनधा"रण वष"/Assessment Years: 2013-14 The Joint Commissioner Of Vs. M/S. Aban Investments P. Ltd., Income Tax (Osd), 113, Janpriya Crest, Pantheon Road, Corporate Circle 1(1), Chennai 600 008. Chennai 600 034. [Pan: Aaaca2926J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Johnson, Addl. Cit ""थ" की ओर से/Respondent By : Shri Saroj Kumar Parida, Advocate सुनवाई की तारीख/ Date Of Hearing : 05.04.2022 घोषणा की तारीख /Date Of Pronouncement : 08.06.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Revenue Are Directed Against Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai Dated 16.12.2019 Relevant To The Assessment Year 2013-14. The First Ground Raised In The Appeal Of The Revenue Relates To Restriction Of Disallowance Made Under Section 14A R.W. Rule 8D.

disallowed under section 2(22)(e) of the Act. After considering the submissions of the assessee, the Assessing Officer has held that the loans and advances received by the assessee from M/s. Aban Infrastructure Pvt. Ltd. amounting to ₹.1,19,00,031/- were held as deemed dividend within the meaning of section 2(22)(e) of the Act and added