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

34)\n588,85,02,720/-\n₹.\n22,52,211/-\n₹.\n1,76,12,403/-\n₹.\n4,40,105/-\n₹.\n388,58,24,247/-\n24. On perusal of the above, it is noted that the Tribunal observed that\nthe Assessing Officer granted exemption in respect of all above except on\nLTCG on transfer of shares under section 10

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

34)\n₹.\n22,52,211/-\n₹.\n1,76,12,403/-\n₹.\n4,40,105/-\n₹.\n388,58,24,247/-\n24.\nOn perusal of the above, it is noted that the Tribunal observed that\nthe Assessing Officer granted exemption in respect of all above except on\nLTCG on transfer of shares under section 10(38) of the Act to an extent

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

34)\n₹.\n4,40,105/-\n₹.\n388,58,24,247/-\n24.\nOn perusal of the above, it is noted that the Tribunal observed that\nthe Assessing Officer granted exemption in respect of all above except on\nLTCG on transfer of shares under section 10(38) of the Act to an extent of\nRs.588,85,02,720/-. Therefore, it is clear

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

34)\n₹.\n4,40,105/-\n₹.\n388,58,24,247/-\n24.\nOn perusal of the above, it is noted that the Tribunal observed that\nthe Assessing Officer granted exemption in respect of all above except on\nLTCG on transfer of shares under section 10(38) of the Act to an extent of\nRs.588,85,02,720/-. Therefore, it is clear

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

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

disallowance of mark-to-market losses was also deemed allowable.", "result": "Partly Allowed", "sections": [ "Section 14A", "Rule 8D", "Section 36(1)(vii)", "Section 36(1)(viia)(c)", "Section 43B(c)", "Section 43B(d)", "Section 43B(e)", "Section 10(34

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

10\n\n(b) Payments towards license to use software ('Software\nLicense')\n\nAssessment\nYear\nAppeal by\nGround\nNo.\nAY 2010-11\nAssessee (ITA No. 1193/CHNY/2024)\n12 to 17\nAY 2011-12\nAssessee (ITA No. 1194/Chny/2024)\n12 to 17\nAY 2012-13\nAssessee (ITA No. 1205/CHNY/2024)\n11 to 16\n\n8.1 During the AY 2010-11, the assessee had made

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 Xenos Group Canada USD 1,59,300 74,20,194 Inc 11 Zoho Corp USA USD 2,923 1,31,798 12 Zoho Corp USA USD 8,320 3,76,480 Total of payments (with ‘make available’ 2,62,162 1,20,46,349 clause) (A) Payments made towards Software AMC - countries without ‘make available’ clause

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 Xenos Group Canada USD 1,59,300 74,20,194 Inc 11 Zoho Corp USA USD 2,923 1,31,798 12 Zoho Corp USA USD 8,320 3,76,480 Total of payments (with ‘make available’ 2,62,162 1,20,46,349 clause) (A) Payments made towards Software AMC - countries without ‘make available’ clause

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

34,735/- in respect of the inflated amount was disallowed and moreover the receipt of ₹.55 lakhs on account of accommodation entries was rightly treated as IT(TP)A Nos.105 to 107/Chny/2024 & ITA No. 3113 & 3251/Chny/24 unexplained money under section 69A of the Act and prayed that the ground raised by the assessee may be dismissed. 28. We have heard

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

34,735/- in respect of the inflated amount was disallowed and moreover the receipt of ₹.55 lakhs on account of accommodation entries was rightly treated as IT(TP)A Nos.105 to 107/Chny/2024 & ITA No. 3113 & 3251/Chny/24 unexplained money under section 69A of the Act and prayed that the ground raised by the assessee may be dismissed. 28. We have heard

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. IDFC LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.877/Chny/2018 & 677/Chny/2020 िनधा&रण वष& /Assessment Years: 2010-11

disallowance u/s. 14A of the Act - Rs. 134,25,40,754: 3. The assessee company received a dividend of Rs 134.25 crores during the relevant previous year, and claimed net income on the dividend of Rs 133,50,42,218 as exempt income under Section 10(34

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

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

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.877/Chny/2018 & 677/Chny/2020 िनधा&रण वष& /Assessment Years: 2010-11

disallowance u/s. 14A of the Act - Rs. 134,25,40,754: 3. The assessee company received a dividend of Rs 134.25 crores during the relevant previous year, and claimed net income on the dividend of Rs 133,50,42,218 as exempt income under Section 10(34

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

Section 36(1)(vii) of the Act, with effect from 01.04.1989, all that is necessary for an assessee to claim a bad debt is for reversal or write-off of the debt in the relevant financial year. There is no necessity for a justification that the debt has, in fact, gone bad. The relevant portion of the judgment is extracted

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

Section 36(1)(vii) of the Act, with effect from 01.04.1989, all that is necessary for an assessee to claim a bad debt is for reversal or write-off of the debt in the relevant financial year. There is no necessity for a justification that the debt has, in fact, gone bad. The relevant portion of the judgment is extracted

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

34,28,46,960 on assumption that Appellant has failed to disallow an expenditure which has been debited to Profit and Loss account but that Appellant claimed weighted deduction @ 150% on such expenditure, without understanding that such expenditure was NEVER debited to P&L account rather it was capitalized in the Books of Accounts and hence, the question of disallowance

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

disallowance under Section 36(1)(iii) is warranted. 2.2.3. Observations of the Hon'ble CIT(A) in this regard • The observations of the Hon'ble CIT(A) in the order passed has been summarized below (refer para 6.4.9 to 6.4.11 of the CIT(A) order, Pg no. 285 & 286 of the paperbook): o The Company had sufficient equity funds

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

disallowance under Section 36(1)(iii) is warranted. 2.2.3. Observations of the Hon'ble CIT(A) in this regard • The observations of the Hon'ble CIT(A) in the order passed has been summarized below (refer para 6.4.9 to 6.4.11 of the CIT(A) order, Pg no. 285 & 286 of the paperbook): o The Company had sufficient equity funds

IDFC LIMITED,CHENNAI vs. JCIT-RANGE-II, CHENNAI

In the result, the appeal of the assessee in ITA No

disallowed the retail bond\nissue expenses to the tune of Rs.72,34,85,405/- as capital in nature.\nAggrieved by the aforesaid decision of Ld. CIT(A), the assessee is before\nus.\n4.\nWe have heard both the parties and perused the material available\non record. The Ld.AR of the assessee submitted that the retail bonds\nwere issued

N.PURUSHOTHAMAN,COIMBATORE vs. DCIT, COIMBATORE

In the result appeal of the assessee is party allowed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपीलसं./I.T.A.No.76/Chny/2017 & C.O. No.34/Chny/2017 [In Ita No.76/Chny/2017] ("नधा"रणवष" / Assessment Year: 2011-12)

34,448/- for development expenses and out of which the assessee debited a sum of Rs.1,91,09,889/- being cash paid to Purushothaman, the assessee. The Assessing Officer required the assessee to file documents and vouchers of such expenses and details of nature of such expenses. The assessee before the Assessing Officer filed reply in response to show-cause