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

8. We heard the submissions of the ld DR and gone through the relevant material. Since the assessee has not assailed the findings recorded by the lower authorities with relevant material, we dismiss the assessee’s appeal . Assessee’s appeal in ITA No 1390/2016 of A Y 2008-09 & the Revenue’s cross appeal in ITA No.1417/2016 : 9. The assessee

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

8. We heard the submissions of the ld DR and gone through the relevant material. Since the assessee has not assailed the findings recorded by the lower authorities with relevant material, we dismiss the assessee’s appeal . Assessee’s appeal in ITA No 1390/2016 of A Y 2008-09 & the Revenue’s cross appeal in ITA No.1417/2016 : 9. The assessee

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

8. We heard the submissions of the ld DR and gone through the relevant material. Since the assessee has not assailed the findings recorded by the lower authorities with relevant material, we dismiss the assessee’s appeal . Assessee’s appeal in ITA No 1390/2016 of A Y 2008-09 & the Revenue’s cross appeal in ITA No.1417/2016 : 9. The assessee

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)

section 144C r.w.s. 92CA of the Act by making disallowance of ₹.7,35,900/-. 8. Aggrieved by the assessment order

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)

section 144C r.w.s. 92CA of the Act by making disallowance of ₹.7,35,900/-. 8. Aggrieved by the assessment order

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

8,45,48,991/- B ADD: 1. TPO Adjustment 7,40,95,333 2. Disallowance of Deduction u/s.10AA 10,06,80,541 3. Interest paid on TDS and 18,20,39,564/- service-tax 24,98,559 4. Disallowance of Forex Loss 47,65,131 C Total income assessed as 9,74,90,573/- per this order Demand Notice u/s.156

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

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

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 in disallowing

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

8,45,48,991/- B ADD: 1. TPO Adjustment 7,40,95,333 2. Disallowance of Deduction u/s.10AA 10,06,80,541 3. Interest paid on TDS and 18,20,39,564/- service-tax 24,98,559 4. Disallowance of Forex Loss 47,65,131 C Total income assessed as 9,74,90,573/- per this order Demand Notice u/s.156

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. 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

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

disallowing expenditure of INR 5,45,37,056 towards management fees paid to its associated :-4-: IT(TP)A. No: 35/Chny/2021 & ITA No: 1010/Chny/2017 enterprises ("AEs"), under section 37(1) of the Act, alleging that the Appellant had failed to establish receipt of services. 5.2 That on the facts and circumstances of the case

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

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

8 I.T.A. No.1483/Chny/17 compliance to the order of the Transfer Pricing Officer as required under Section 92CA(4) of the Act, preferred to pass a draft assessment order as provided in Section 144C(1) of the Act, whether the assessee is challenging the jurisdiction of the Assessing Officer to pass a draft assessment order under Section 144C

SL LUMAX LIMITED,KANCHIPURAM vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, the appeal filed by assessee in ITA No

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy*नधा,रण वष, /Assessment Year: 2013-14 M/S.Sl Lumax Ltd., V. The Principal Commissioner G-14, 15 & 25, Sipcot Industrial Of Income Tax, Room No.602, Park, Irrungattukottai, Vi Floor, Aayakar Bhawan, Sriperumbudur-602 117. New Block, Mahatama Gandhi Kancheepuram District. Road, Nungambakkam, Chennai-600034. [Pan: Aaacl 1857 B] (अपीलाथ//Appellant) (01यथ//Respondent) : Mr. Vikram Vijayaraghavan, अपीलाथ/ क2 ओर से/ Appellant By Adv. : Mr. A.Sundararajan, Cit 01यथ/ क2 ओर से /Respondent By : 28.11.2019 सुनवाई क2 तार"ख/Date Of Hearing : 10.02.2020 घोषणा क2 तार"ख /Date Of Pronouncement आदेश / O R D E R Per Ramit Kochar:

Section 144C(3) of the 1961 Act by the AO , vide assessment order dated 27.02.2017 assessing the income of the assessee at Rs. 76.04 Crs. The learned PCIT after examining records was of the view that provision for warranty claimed by assessee to the tune of Rs. 1,40,45,352/- for financial year 2012-13 in its Profit

VODAFONE MOBILE SERVICES LIMITED,NEW DELHI vs. DCIT, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.587/Chny/2017 िनधा:रण वष: /Assessment Year: 2010-11

144C of the Act. Each of the ground is referred to separately, which may kindly be considered independent of each other. 1. Ground No. 1 Assessment order is bad in law and hence, void-ab- initio. 1.1 On the facts and circumstances of the case and in law, the learned CIT(A) has failed to adjudicate the following ground taken

VISUAL GRAPHICS COMPUTING SERVICES INDIA (P) LTD,CHENNAI vs. ACIT CO CLE III (4), CHENNAI

In the result, the appeal of the assessee is partly allowed for 28

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No.2340/Mds/2012 "नधा"रण वष" /Assessment Year : 2008-2009

section (8) to Sec. 144C of the Act. 12. We have considered the rival contentions and perused the orders of the authorities below. Directions of the ld. DRP as it appear at paragraph 16(vi) of its order is reproduced hereunder:- Disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUNELVELI vs. LOYAL TEXTILE MILLS LTD, KOVILPATTI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

144C(3) dated 30.09.2023, assessed the income at Rs.22,07,36,266/-, making additions (i)Rs.21,29,06,078/- towards difference in deduction u/s.80IA of the Act; (ii)Rs.42,48,536/- towards disallowance u/s.40(a)(ia) of the Act for non- deduction of tax on domestic commission (iii) Rs.10,56,694/- towards disallowance u/s.40(a)(i) for non-deduction