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

disallowance made u/s 14A r w r 8D to the returned income and computed the total income under the normal or regular computation of total income. The A O has not determined the total income under section 115

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

disallowance made u/s 14A r w r 8D to the returned income and computed the total income under the normal or regular computation of total income. The A O has not determined the total income under section 115

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

115 WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier. It is pertinent to note that

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

115 WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier. It is pertinent to note that

THIAGARAJAR MILLS (P) LIMITED,MADURAI vs. JCT, MADURAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.Nos.1202, 1203 & 1204/Chny/2015 िनधा"रण वष"/Assessment Years: 2009-10, 2010-11 & 2011-12 M/S. Thiagarajar Mills (P) Ltd., Joint Commissioner Of Gst Road, Kappalur Vs. Income Tax, Madurai – 625 008. Range – I, Madurai [Pan: Aaact 4304R] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Srinivasan, Advocate ""थ" की ओर से/Respondent By : Shri M. Srinivasa Rao, Cit सुनवाई की तारीख/ Date Of Hearing : 24.10.2019 घोषणा की तारीख /Date Of Pronouncement : 29.11.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: These Three Appeals Filed By The Same Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)-I, Chennai All Dated 20.03.2015 Relevant To The Assessment Years 2009-10, 2010-11 & 2011-12. Since Common Issues Have Been Raised In These Appeals, Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Brevity.

115 WH or under section 148 for the making of the return or by the notice under the first proviso to section 115WF or under the first proviso to section 144] to show cause why the assessment should not be completed to the best of the judgment of the Assessing Officer, whichever is earlier. It is pertinent to note that

SOUTHERN PETROCHEMICAL INDUSTRIES CORPORATION LTD.,CHENNAI vs. ITO, CHENNAI

Appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.84/Chny/2023 (िनधा)रण वष) / Assessment Year: 2008-09) M/S. Southern Petrochemical Income Tax Officer बनाम Industries Corporation Limited Corporate Ward-3(1) 88, Spic House, Mount Road, Guindy, Chennai-600 034. / Vs. Chennai-600 032. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-4668-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan & Shri Saroj Kumar Parida (Advocates)-Ld. Ars " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) & Shri Ar V Sreenivasan (Addl. Cit)-Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 16-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 10-01-2024 आदेश / O R D E R

disallowance under section 14A well computing book profits under section 115 JB (Para .6.1 at Page 50). As is evident

M/S. SAINT GOBAIN GLASS INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddy

Disallowance under section 14A of the Act r.w.r.8D of the Rules under section 115 JB of the Act: 4.3 On this

SHRIRAM FINANCE LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.173/Chny/2024 िनधा"रण वष"/Assessment Year: 2020-21 Shriram Finance Limited Vs. The Deputy Commissioner Of [Formerly Known As Shriram Transport Income Tax, Finance Company Limited), Corporate Circle 3(1), Sri Towers, Plot No. 14A, South Phase, Chennai. Industrial Estate, Guindy, Chennai 600 017. [Pan: Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.07.2024 घोषणा की तारीख /Date Of Pronouncement : 09.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. Ground No. 1 Is General In Nature & Requires No Adjudication.

disallowed is at ₹.88,35,048/- . The ld. AR pointed out that non-credit of amount of ₹.3,52,696/- being TDS paid by Shriram Equipment Finance Company Limited, which was amalgamated with Shriram Transport Finance Company Limited w.e.f. 01.04.2015 was brought to the notice of the ld. CIT(A) NFAC, but, however, the ld. CIT(A) has directed

ACIT, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

In the result, the appeals of the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance of ₹.85,132/-. Under the above facts and circumstances, we do not see any infirmity in the order of the authorities below, which calls for our interference. Thus, the ground raised by the assessee is dismissed. I.T.A. No. 1639/Mds/2014 6. The first ground raised in the appeal of the assessee for the assessment year 2006-07 is with regard

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

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are

disallowance of provisions on account of IBNR and IBNER claims charged to P & L account by holding it to be unascertained liability and not allowable under section 37(1) of the Act and added back to the total income under the normal provisions. It is noted that the Id. PCIT under section 263 of the Act, having found the same

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

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

disallowance of provisions on account of IBNR and IBNER claims charged to P & L account by holding it to be unascertained liability and not allowable under section 37(1) of the Act and added back to the total income under the normal provisions. It is noted that the ld. PCIT under section 263 of the Act, having found the same

M/S. MAXIVISION EYE HOSPITAL PVT. LTD.,,CHENNAI vs. DCIT, CORPORATE CIRCLE-4(1),, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallow the expenditure for one year for the presence of tax exempt another year from the same investments. In view of the same, it is held that the decision of the Hon'ble Madras High Court in M/s. Redington India Ltd is held as overruled by the decisions of the Apex Court on section 14 in M/s Walfort Share

ACIT, CORPORATE CIRCLE 1(1), CHENNAI vs. DURR INDIA PRIVATE LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is partly-allowed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 1638/Chny/2025 िनधा"रण वष"/Assessment Year: 2019-20 The Acit, Durr India Pvt. Ltd., Corporate Circle 1 (1), Vs. 471, Prestige Polygon, Chennai. Anna Salai, Nandanam, Chennai – 600 035. Pan: Aaacd 3568P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Gouthami Manivasagam, Jcit ""यथ" क" ओर से/Respondent By : Shri Suhrith Parthasarathy, Advocate सुनवाई क" तारीख/Date Of Hearing : 25.09.2025 घोषणा क" तारीख/Date Of Pronouncement : 26.09.2025

Section 115-0 (3) and (4) that the tax on distributed profits so paid by the company shall be treated as the final payment of tax and no further credit therefore shall be claimed by the company or by any other person in respect of the amount of tax so paid. Furthermore, no deduction under any other provision of this

DCIT CORPORATE CIRCLE 6(2), CHENNAI vs. SHRIRAM VENTURE LTD., CHENNAI

In the result, Revenue’s appeals are partly allowed for statistical purposes and the assessee’s appeals are dismissed

Bench: Shri George Mathan & Shri Inturi Rama Rao

section 251(1)(a) of the Act, the “power to set aside” or “examining the issue afresh” has been omitted with effect from 01.06.2001 as per Finance Act 2001. 2.2) The Ld CIT(A) erred in directing the AO to restrict the addition on account of u/s 14A amount eventhough, in assessee group case department appeals are pending before High

FOR SVL LIMITED,CHENNAI vs. ITO CORPORATE WARD 6(3), CHENNAI

In the result, Revenue’s appeals are partly allowed for statistical purposes and the assessee’s appeals are dismissed

Bench: Shri George Mathan & Shri Inturi Rama Rao

section 251(1)(a) of the Act, the “power to set aside” or “examining the issue afresh” has been omitted with effect from 01.06.2001 as per Finance Act 2001. 2.2) The Ld CIT(A) erred in directing the AO to restrict the addition on account of u/s 14A amount eventhough, in assessee group case department appeals are pending before High

FOR SVL LIMITED,CHENNAI vs. ITO CORPORATE WARD 6(3), CHENNAI

In the result, Revenue’s appeals are partly allowed for statistical purposes and the assessee’s appeals are dismissed

Bench: Shri George Mathan & Shri Inturi Rama Rao

section 251(1)(a) of the Act, the “power to set aside” or “examining the issue afresh” has been omitted with effect from 01.06.2001 as per Finance Act 2001. 2.2) The Ld CIT(A) erred in directing the AO to restrict the addition on account of u/s 14A amount eventhough, in assessee group case department appeals are pending before High

DCIT CORPORATE CIRCLE 6(2), CHENNAI vs. SHRIRAM VENTURE LTD., CHENNAI

In the result, Revenue’s appeals are partly allowed for statistical purposes and the assessee’s appeals are dismissed

Bench: Shri George Mathan & Shri Inturi Rama Rao

section 251(1)(a) of the Act, the “power to set aside” or “examining the issue afresh” has been omitted with effect from 01.06.2001 as per Finance Act 2001. 2.2) The Ld CIT(A) erred in directing the AO to restrict the addition on account of u/s 14A amount eventhough, in assessee group case department appeals are pending before High

M/S TAMILNADU STATE MARKETING CORPORATION LIMITED,CHENNAI vs. ACIT,CORPORATE CIRCLE 3 [1], CHENNAI

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

Bench: Shri Mahavir Singhand Dr. Dipak P. Ripoteआयकर अपीलसं./Ita No.: 353/Chny/2022 "नधा"रण वष"/Assessment Year: 2014-15 M/S. Tamilnadu State The Acit, Marketing Corporation Ltd., Vs. Corporate Circle 3(1), Cmda Tower, Ii, Iv Floor, Chennai. Gandhi Irwin Bridge Road, Egmore, Chennai – 600 008. Pan: Aaact 2964P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओरसे/Appellant By : Shri R.Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई क" तार"ख/Date Of Hearing : 16.08.2022 घोषणा क" तार"ख/Date Of Pronouncement : 14.11.2022 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Revision Order Passed U/S.263 Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) By The Principal Commissioner Of Income Tax (Appeals), Chennai-3 In Revision No.Pcit, Chennai-3/Revision-263/100000339483/2022 Dated 31.03.2022. The Assessment Was Framed By The Acit, Corporate Circle-3(1), Chennai For The Assessment Year 2014-15 U/S.143(3) Of The Act Vide Order Dated 30.12.2016. 2. The Only Issue In This Appeal Of Assessee Is As Regards To The Revision Order Passed By Pcit By Holding The Assessment Framed As Erroneous & Prejudicial To The Interest Of Revenue On Account Of Value Added Tax Paid By Assessee & Claimed As Deduction U/S.37 R.W.S. 43B Of The Act & Allowed.

Section 115 of the Tamil Nadu Panchayats Act, 1958, were said to be included in the meaning of land revenue. In that case, it was not in dispute that the cess which the Madras Village Panchayat Act proposes to levy was nothing but an "additional tax" and originally it was levied only on land revenue, and that apparently land revenue