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:

disallowing an amount of Rs.60,07,830/- representing net surpluses of two different schools i.e. ICF Silver Jubilee Nursery school lCF Silver Jubilee Primary school. 3. The ld. CIT(A) has not considered the Grounds of Appeal filed by the Appellant and has adjudicated on the wrong grounds which is irrelevant to the case of the Appellant. Reference is drawn

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

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

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

23,21,315/-. However, the AO is directed to verify that the amount remains paid as on 31.03.2012. If, however, the impugned amount or part thereof remains unpaid as on 31.03.2012, the same shall be disallowed.” (Emphasis supplied) 31. Thus, the Learned CIT(A) had confirmed the disallowance under Section 40(a)(ia) of the Act. However, CIT(A) granted

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

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

23,21,315/-. However, the AO is directed to verify that the amount remains paid as on 31.03.2012. If, however, the impugned amount or part thereof remains unpaid as on 31.03.2012, the same shall be disallowed.” (Emphasis supplied) 31. Thus, the Learned CIT(A) had confirmed the disallowance under Section 40(a)(ia) of the Act. However, CIT(A) granted

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

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

23,21,315/-. However, the AO is directed to verify that the amount remains paid as on 31.03.2012. If, however, the impugned amount or part thereof remains unpaid as on 31.03.2012, the same shall be disallowed.” (Emphasis supplied) 31. Thus, the Learned CIT(A) had confirmed the disallowance under Section 40(a)(ia) of the Act. However, CIT(A) granted

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

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)

section 40(a)(ia) of the Act: The next issue in this appeal of assessee is as regards to the order of Ld.CIT(A) in confirming the action of the AO in making disallowance u/s.40(a)(ia) of the Act on the payment towards Software Annual Maintenance Charges (‘Software AMC’) and payments 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

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)

section 40(a)(ia) of the Act: The next issue in this appeal of assessee is as regards to the order of Ld.CIT(A) in confirming the action of the AO in making disallowance u/s.40(a)(ia) of the Act on the payment towards Software Annual Maintenance Charges (‘Software AMC’) and payments towards license to use software (‘Software License

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

23,866/- under section 14A of the Act r.w. Rule 8D. 3. The assessee carried the matter in appeal before the ld. CIT(A). After considering the submissions of the assessee and facts of the case, the ld. CIT(A) has confirmed the disallowance made under section 14A of the Act. 3 I.T.A. Nos.691 & 692/M/17 4. On being aggrieved

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

23,866/- under section 14A of the Act r.w. Rule 8D. 3. The assessee carried the matter in appeal before the ld. CIT(A). After considering the submissions of the assessee and facts of the case, the ld. CIT(A) has confirmed the disallowance made under section 14A of the Act. 3 I.T.A. Nos.691 & 692/M/17 4. On being aggrieved

TNCP LLP.,COIMBATORE vs. ITO, NCW-1(1), COIMBATORE

In the result, the quantum\nNo

Section\n23(1) r.w.s 23(5) of the Act by holding as follows:\n5. A notional ALV of such aforesaid WIP of Rs,38,80,75,826/- is computed\n@ 8% before allowing standard deduction u/s.24(b) of the Act. The working for\nthe same is as under:\nAnnual Letable Value = 8% of Rs.38,80,75,826/- = Rs.3,10

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

10. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

10. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

10. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business