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

3) read with section 92CA (4) making the following disallowances / additions. Disallowance of interest expense under section 14A at INR 9,34,74,475 Disallowance of consulting fee paid to bank under section 37at INR 13,70,90,436 Disallowance of escrow fee paid to bank under section 37 at INR 201,663 Transfer Pricing adjustment

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

3) read with section 92CA (4) making the following disallowances / additions. Disallowance of interest expense under section 14A at INR 9,34,74,475 Disallowance of consulting fee paid to bank under section 37at INR 13,70,90,436 Disallowance of escrow fee paid to bank under section 37 at INR 201,663 Transfer Pricing adjustment

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

3) read with section 92CA (4) making the following disallowances / additions. Disallowance of interest expense under section 14A at INR 9,34,74,475 Disallowance of consulting fee paid to bank under section 37at INR 13,70,90,436 Disallowance of escrow fee paid to bank under section 37 at INR 201,663 Transfer Pricing adjustment

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

3) to Section 14A\nof the Act, the AO does not have power to compute\ndisallowance under Section 14A as per provisions of Rule 8D,\neven for A.Ys.2008-09 and onwards, if the AO does not\nexpress dissatisfaction.\n- For the purpose of computation of disallowance u/s.14A of\nthe Act read with rule 8D, the investments which have

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

3) to section 14A\nof the Act, the AO does not have power to compute\ndisallowance under section 14A as per provisions of Rule 8D,\neven for A.Ys.2008-09 and onwards, if the AO does not\nexpress dissatisfaction.\n\n- For the purpose of computation of disallowance u/s.14A of\nthe Act read with rule 8D, the investments which have

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

3) to section 14A\nof the Act, the AO does not have power to compute\ndisallowance under section 14A as per provisions of Rule 8D,\neven for A.Ys.2008-09 and onwards, if the AO does not\nexpress dissatisfaction.\n- For the purpose of computation of disallowance u/s.14A of\nthe Act read with rule 8D, the investments which have

PRATHYUSHA EDUCATIONAL TRUST,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri George Mathan & Shri Inturi Rama Rao

disallowance u/s.40(a)(ia) prior period expense, deposit refund, salary paid to Managing Trustee were made contrary to the facts of the case and against the principles of law.” 4. Consequent to the Miscellaneous Petition order, the appeals came to be heard on 15th May, 2019. For the purpose of filing detailed submission and to specifically point out the issues

PRATHYUSHA EDUCATIONAL TRUST,CHENNAI vs. ACIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri George Mathan & Shri Inturi Rama Rao

disallowance u/s.40(a)(ia) prior period expense, deposit refund, salary paid to Managing Trustee were made contrary to the facts of the case and against the principles of law.” 4. Consequent to the Miscellaneous Petition order, the appeals came to be heard on 15th May, 2019. For the purpose of filing detailed submission and to specifically point out the issues

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

3) to section 14A\nof the Act, the AO does not have power to compute\ndisallowance under section 14A as per provisions of Rule 8D,\neven for A.Ys.2008-09 and onwards, if the AO does not\nexpress dissatisfaction.\n- For the purpose of computation of disallowance u/s.14A of\nthe Act read with rule 8D, the investments which have

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

3) to section 14A\nof the Act, the AO does not have power to compute\ndisallowance under section 14A as per provisions of Rule 8D,\neven for A.Ys.2008-09 and onwards, if the AO does not\nexpress dissatisfaction.\n- For the purpose of computation of disallowance u/s.14A of\nthe Act read with rule 8D, the investments which have

M/S. P.P. FINANCIERS,CHENNAI vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

144 of the Act, as detailed in paragraph 1 of\nthis order, making various additions on both substantive as well as\nprotective bases.\n4. Aggrieved by the assessment orders, the assessees preferred\nappeals before the Learned Commissioner of Income Tax (Appeals).\nBy orders dated 31.07.2024, except in the case of PP Enterprises\n(Oddanchatram) wherein the appellate order was passed

M/S. P.P. ENTERPRISES,DINDIGUL vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

144 of the Act, as detailed in paragraph 1 of\nthis order, making various additions on both substantive as well as\nprotective bases.\n4. Aggrieved by the assessment orders, the assessees preferred\nappeals before the Learned Commissioner of Income Tax (Appeals).\nBy orders dated 31.07.2024, except in the case of PP Enterprises\n(Oddanchatram) wherein the appellate order was passed

ACIT, MADURAI vs. J.K.FENNER (INDIA) LIMITED, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

144 ITD 141 (kol.). 3. The Commissioner of Income Tax (Appeals) erred in directing the assessing officer to restrict the addition to Rs.2,57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014

J.K.FENNER (INDIA) LIMITED,MADURAI vs. ACIT CORPORATE CIRCLE 1, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

144 ITD 141 (kol.). 3. The Commissioner of Income Tax (Appeals) erred in directing the assessing officer to restrict the addition to Rs.2,57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

144 ITD 141 (kol.). 3. The Commissioner of Income Tax (Appeals) erred in directing the assessing officer to restrict the addition to Rs.2,57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

144 ITD 141 (kol.). 3. The Commissioner of Income Tax (Appeals) erred in directing the assessing officer to restrict the addition to Rs.2,57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

144 ITD 141 (kol.). 3. The Commissioner of Income Tax (Appeals) erred in directing the assessing officer to restrict the addition to Rs.2,57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

144 ITD 141 (kol.). 3. The Commissioner of Income Tax (Appeals) erred in directing the assessing officer to restrict the addition to Rs.2,57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014