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

13,70,90,436 and INR 201,663, respectively under section 37 of the Act. These amounts were paid to SCB for being a financial advisory to a transaction in connection with acquisition of overseas subsidiary and also to the SCB as it has acted as an escrow agent for the acquisition of the shipping business. The escrow

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

13,70,90,436 and INR 201,663, respectively under section 37 of the Act. These amounts were paid to SCB for being a financial advisory to a transaction in connection with acquisition of overseas subsidiary and also to the SCB as it has acted as an escrow agent for the acquisition of the shipping business. The escrow

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

13,70,90,436 and INR 201,663, respectively under section 37 of the Act. These amounts were paid to SCB for being a financial advisory to a transaction in connection with acquisition of overseas subsidiary and also to the SCB as it has acted as an escrow agent for the acquisition of the shipping business. The escrow

YCH LOGISTICS (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Disallowance of Forex Loss 47,65,131 C Total income assessed as 9,74,90,573/- per this order Demand Notice u/s.156 and calculation sheet are enclosed. Penalty proceedings u/s.271(1)(c) initiated for the reasons discussed above.” Thereafter final assessment order was passed by the ACIT, Corporate Circle 3(2), Chennai u/s.143(3) r.w.s. 92CA(3) r.w.s. 144C

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)

144C(3) r.w.s. 92CA of the Act dated 29.05.2015, the Assessing Officer disallowed a sum of ₹. 7,35,900/- as TP adjustment. On appeal, the CIT(A) confirmed the above TP adjustment. The assessee contended that Tribunal is consistently holding that TP adjustment in respect of guarantee given to AE shall be at 0.5% and prayed to restrict the disallowance

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)

144C(3) r.w.s. 92CA of the Act dated 29.05.2015, the Assessing Officer disallowed a sum of ₹. 7,35,900/- as TP adjustment. On appeal, the CIT(A) confirmed the above TP adjustment. The assessee contended that Tribunal is consistently holding that TP adjustment in respect of guarantee given to AE shall be at 0.5% and prayed to restrict the disallowance

EATON POWER QUALITY PRIVATE LIMITED,PONDICHERRY vs. DCIT, PONDICHERRY

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1010/Chny/2017 िनधा"रण वष" / Assessment Year: 2012-13 Eaton Power Quality Private The Deputy Commissioner Of Limited, V. Income Tax, No.2, Evr Street Sedarapet, Pondicherry Circle, Puducherry 605 111, Pondicherry. Puducherry (Ut). [Pan: Aacc-6943-R] आयकर अपील सं./It(Tp)A No.: 35/Chny/2021 िनधा"रण वष" / Assessment Year: 2016-17 Eaton Power Quality Private The Assessing Officer, Limited, V. National E-Assessment Centre, No.2, Evr Street Sedarapet, Delhi. Puducherry 605 111, Puducherry (Ut). [Pan: Aacc-6943-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vishal Kalra, Advocate : Shri. S. Maruthu Pandian, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 01.05.2023 घोषणा क" तारीख/Date Of Pronouncement : 03.05.2023 आदेश /O R D E R

144C(13) and 1448 of the Act is contrary to law, facts and circumstances of the case and thus, liable to be quashed. 3. That on the facts and circumstances of the case and in law, the order dated November 1, 2019 passed by the TPO under section 92CA(3) of the Act is barred by limitation

KELLER GROUND ENGINEERING INDIA PRIVATE LTD,CHENNAI vs. ACIT, CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Disallowance of Forex Loss 47,65,131 C Total income assessed as 9,74,90,573/- per this order Demand Notice u/s.156 and calculation sheet are enclosed. Penalty proceedings u/s.271(1)(c) initiated for the reasons discussed above.” Thereafter final assessment order was passed by the ACIT, Corporate Circle 3(2), Chennai u/s.143(3) r.w.s. 92CA(3) r.w.s. 144C

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

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

13) of the Act pursuant to the order of Dispute Resolution Panel dated 30.12.2010 passed under section 144C(5) r.w.s 144C(8) of the Act. 2. The assessee has raised in its appeal several elaborate grounds, however the cruxes of the issues are as follows:- 2 i) The learned DRP as well as the learned Assessing Officer has erred

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

144C of the Income Tax Act, 1961 (hereinafter the 'Act') for the\n assessment years 2014-15, 2015-16 and 2017-18 dated 29.03.2024,\n29.03.2024 and 29.03.2024 respectively. The CO has been raised by the\nassessee for the A.Y.2015-16 only. Since the facts are common/identical and\nthe issue of assessee's claim of depreciation on goodwill arising on\namalgamation

DCIT, CHENNAI vs. REDINGTON (INDIA) LTD., CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

144C(1) of the Act dated 05.02.2016. Aggrieved, the assessee has filed appeal before this Tribunal. 4. On the issue of trademark licence fee, the Ld. AR of the assessee argued that the assessee has paid an amount of `1,81,51,501/- as trademark fees to M/s Redington Distribution Pte Ltd. The facts are that the Ld. Transfer Pricing

REDINGTON (INDIA) LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

144C(1) of the Act dated 05.02.2016. Aggrieved, the assessee has filed appeal before this Tribunal. 4. On the issue of trademark licence fee, the Ld. AR of the assessee argued that the assessee has paid an amount of `1,81,51,501/- as trademark fees to M/s Redington Distribution Pte Ltd. The facts are that the Ld. Transfer Pricing

DCIT, CHENNAI vs. PARRYWARE ROCA PVT. LTD., CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

144C of the Income-tax Act, 1961 (in short 'the Act'). 14. Now coming to Revenue’s appeal in I.T.A. No.1169/Mds/2014, the only issue arises for consideration is with regard to disallowance under Section 40(a)(ia) of the Act for short deduction of tax at source. 15. The assessee deducted tax under Section 194C of the Act. However

ROCA BATHROOM PRODUCTS PRIVATE LIMITED,CHENNAI vs. JCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

144C of the Income-tax Act, 1961 (in short 'the Act'). 14. Now coming to Revenue’s appeal in I.T.A. No.1169/Mds/2014, the only issue arises for consideration is with regard to disallowance under Section 40(a)(ia) of the Act for short deduction of tax at source. 15. The assessee deducted tax under Section 194C of the Act. However

VESTAS WIND TECHOLOGY INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.177/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12 M/S Vestas Wind Technology India The Assistant Commissioner Of Pvt. Ltd., V. Income Tax, No.298, Rajiv Gandhi Salai, Corporate Circle 3(2), Sholinganallur, Chennai - 600 119. Chennai - 600 034. Pan : Aaaca 9274 F (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144C(13) of the Act. 5. Now coming to the second ground of appeal with regard to disallowance of `10,50,000/- towards

EAST WIND FOOTWEAR COMPANY LIMITED - INDIA BRANCH ,THIRUVANNAMALAI vs. DCIT INTERNATIONAL TAXATION 1(1) & 1(2) , CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No.1655/Chny/2017 िनधा"रण वष"/Assessment Year:2014-15 M/S. East Wind Footwear Company The Deputy Commissioner Of Vs. Limited – India Branch, Plot No. 3, Income Tax, D&E, Sipcot Industrial Park, Mathur, International Taxation 1(1) & 1(2), Mangal Village, Cheyyar T.K., Chennai. Thiruvannamalai, Tamil Nadu 631 701. [Pan: Aacce5043N] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ashik Shah, C.A. ""थ" की ओर से/Respondent By : Shri S. Ramakrishnan, Cit सुनवाई की तारीख/ Date Of Hearing : 29.01.2020 घोषणा की तारीख /Date Of Pronouncement : 31.01.2020 आदेश /O R D E R Per Duvvurul Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Final Assessment Order Passed Under Section 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [“Act” In Short] Dated 28.04.2017 Relevant To The Assessment Year 2014-15. The Effective Grounds Raised In The Appeal Of The Assessee Are That The Assessing Officer & The Drp Have Erred In Law In Not Allowing The Deduction Under Section 10Aa Of The Act & Computation Of Tax Payable & Levy Of Interest Under Section 234D Of The Act.

13) of the Income Tax Act, 1961 [“Act” in short] dated 28.04.2017 relevant to the assessment year 2014-15. The effective grounds raised in the appeal of the assessee are that the Assessing Officer and the DRP have erred in law in not allowing the deduction under section 10AA of the Act and computation of tax payable and levy

PANASONIC CORPORATION,HARYANA vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

144C(1) of the order instead of passing an order in conformity with the order of the Transfer Pricing Officer as provided under Section 92CA(4) of the Act. 21. Now, coming to merit of the appeal, the Assessing Officer disallowed the claim of the assessee only on the ground that the assessee received assessee fee for technical service

RECKITT BENCKISER SCHOLL INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita No.756/Mds/2016 िनधा"रण वष" / Assessment Year : 2011-12 M/S. Reckitt Benckiser Scholl The Deputy Commissioner Of India Private Limited V. Income Tax, (Formerly Known As M/S. Corporate Circle – V (1), Reckitt Benekiser Scholl India Chennai Limited). Plot F 73/74, Sipcot Industrial Park, Irungattukottai, Sriperumbudur, Kancheepuram – 602 117

disallowance under Section 14A of the Act and the DRP has rejected. vii) The assessee objected for excluding of income, interest dividend, provision for foreign exchange, etc., for deduction u/s.10B which was rejected by the DRP and upheld the order of the TPO. Consequent to the DRP order, the Assessing Officer passed the assessment order under Section 143(3) r.w.s