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

29. In so far as the issue pertaining to the provision increased for dimination for investments for actively traded, the Id. Senior Standing Counsel submits that the assessee ought to have applied Rule 5(b)(ii) of the IT Rules. Since the Assessing Officer failed to apply Rule 5(b)(ii) in so far as the issue of provision

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

10(38) of the Act as well as section 14A of the Act vide question No. 12(1) and dealt the issue extensively. The reasons recorded by us in the aforementioned paragraphs are equally applicable to the present issue for AY 2017-18. Thus, ground Nos. 2 (a) along with 3 to 7 are allowed. 42. Ground

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:

29 taxmann.com 223 (Delhi Trib.) it has been held by the Delhi bench of the ITAT that only annual receipt of school or university would be considered for deciding the exemption limit under 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

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

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

29. The brief facts of the case are that Appellant filed return of income for the Assessment Year 2011-12 which was selected for detailed scrutiny. The Assessing Officer completed the assessment after making the following additions / disallowance: AY 2014-15 Particular Amount (INR) Disallowed deduction of proportionate interest on 51,89,484 the capital borrowed under Section

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

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

29. The brief facts of the case are that Appellant filed return of income for the Assessment Year 2011-12 which was selected for detailed scrutiny. The Assessing Officer completed the assessment after making the following additions / disallowance: AY 2014-15 Particular Amount (INR) Disallowed deduction of proportionate interest on 51,89,484 the capital borrowed under Section

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

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

29. The brief facts of the case are that Appellant filed return of income for the Assessment Year 2011-12 which was selected for detailed scrutiny. The Assessing Officer completed the assessment after making the following additions / disallowance: AY 2014-15 Particular Amount (INR) Disallowed deduction of proportionate interest on 51,89,484 the capital borrowed under Section

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, 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 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Cognizant Technology Solutions Vs 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. (प्रत्यर्थी/Respondent) Pan: Aaacd 3312M (अपीलार्थी/Appellant) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 (निर्धारण वर्ष / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) The Asst. Commissioner Of Vs 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 (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) निधारिती की ओर से/Assessee By राजस्व की ओर से /Revenue By : Shri N.V. Balaji, Advocate : Shri R. Clement Ramesh Kumar, Cit & Ms. Anitha, Addl. Cit सुनवाई की तारीख/Date Of Hearing : 11.03.2025 घोषणा की तारीख/Date Of Pronouncement : 16.05.2025 - 2 -

disallowance of set-off of losses incurred by units eligible for deduction u/s.10A and 10AA against other taxable income is common for all the A.Ys being Α.Υ.2010-11 to A.Y. 2014-15 Assessment Appeal by Year Ground No. AY 2010-11 Department (ITA No. 1262/CHNY/2024) 2 AY 2011-12 Department (ITA No. 1263/CHNY/2024) 2 AY 2012-13 Department

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)

29 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024 outside India as the assessee is an exporter of computer software and related services. - The assessee cannot be expected to effect tax deduction at source on the payments due to subsequent amendment made under the Explanation 4 to section 9(1)(vi) of the Act. Reliance was placed on various

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)

29 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024 outside India as the assessee is an exporter of computer software and related services. - The assessee cannot be expected to effect tax deduction at source on the payments due to subsequent amendment made under the Explanation 4 to section 9(1)(vi) of the Act. Reliance was placed on various

SMT. D. SAILAJA,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes in the manner indicated above

Bench: Shri Ramit Kochar & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 2350/Chny/2016 िनधा"रण वष"/Assessment Year: 2012-13 Mrs. D. Sailaja, The Deputy Commissioner Of No. 4, 10Th Street, Nandanam Vs. Income Tax, Extension, Nandanam, Non Corporate Circle Ii, Chennai 600 035. Chennai 600 034. [Pan:Aaops2743J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri J. Purshothaman, C.A. Shri Guru Bashyam, Addl. Cit ""थ" की ओर से/Respondent By : सुनवाई की तारीख/ Date Of Hearing : 26.11.2019 घोषणा की तारीख /Date Of Pronouncement : 23.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy:

10. Before us, the ld. Counsel for the assessee has submitted that the receipt of share of profit from various partnership firms amounting to ₹.1,01,02,703/- is nothing but salary and taxable under ‘income from salary’, which cannot be treated as exempt income. It was further submission that the assessee has voluntarily disallowed ₹.1,29,921/- under section

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

section 43B of the Act, the ld. Counsel for the assessee has submitted that the assessee itself has disallowed the expenditure in the computation of income, and therefore, he has pleaded that the Assessing Officer cannot make double disallowance, which was already disallowed by the assessee. In view of the above submissions, we direct the Assessing Officer to verify

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

section 43B of the Act, the ld. Counsel for the assessee has submitted that the assessee itself has disallowed the expenditure in the computation of income, and therefore, he has pleaded that the Assessing Officer cannot make double disallowance, which was already disallowed by the assessee. In view of the above submissions, we direct the Assessing Officer to verify

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. On the issues of the disallowances ; of consulting fee and escrow fee paid to bank , the ld DR invited our attention to the relevant portion of the order of the ld CIT(A), which is extracted as under “ 5.5 Ground No.6 raised by the appellant is against disallowance of Rs.13,70,90,436 and Rs.2,01,663 paid

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. On the issues of the disallowances ; of consulting fee and escrow fee paid to bank , the ld DR invited our attention to the relevant portion of the order of the ld CIT(A), which is extracted as under “ 5.5 Ground No.6 raised by the appellant is against disallowance of Rs.13,70,90,436 and Rs.2,01,663 paid

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. On the issues of the disallowances ; of consulting fee and escrow fee paid to bank , the ld DR invited our attention to the relevant portion of the order of the ld CIT(A), which is extracted as under “ 5.5 Ground No.6 raised by the appellant is against disallowance of Rs.13,70,90,436 and Rs.2,01,663 paid

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. On the issues of the disallowances ; of consulting fee and escrow fee paid to bank , the ld DR invited our attention to the relevant portion of the order of the ld CIT(A), which is extracted as under “ 5.5 Ground No.6 raised by the appellant is against disallowance of Rs.13,70,90,436 and Rs.2,01,663 paid

ACIT, CHENNAI vs. M/S MACRO MARVEL PROJECTS LTD, CHENNAI

In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallowing the appellant's claim u/s 80IB(10). The grounds of the appellant in this regard thus fail.” Aggrieved, assessee is in appeal before Tribunal. 7. Now, Ld. Counsel for the assessee Shri. G. Baskar, Advocate argued that the commercial area is only to the extent of 98.4 sq.m. which is for the daily needs of the residents

M/S MACRO MARVEL PROJECTS LTD.,CHENNAI vs. ITO, COMPANY WARD-IV(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallowing the appellant's claim u/s 80IB(10). The grounds of the appellant in this regard thus fail.” Aggrieved, assessee is in appeal before Tribunal. 7. Now, Ld. Counsel for the assessee Shri. G. Baskar, Advocate argued that the commercial area is only to the extent of 98.4 sq.m. which is for the daily needs of the residents