GEENA GARMENTS,TIRUPPUR vs. ACIT, CIRCLE-1, TIRUPPUR, TIRUPPUR

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowance on weighted deduction under section 35(2AB) of the Act, accordingly, the Assessing Officer determined the income of the assessee at ₹.36,61,77,500/- vide order dated 04.07.2019 passed under section 143(3) of the Act. 6. Aggrieved by the said order of the Assessing Officer, the assessee challenged the same before

DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE-1, TIRUPPUR vs. EASTMAN EXPORTS GLOBAL CLOTHING P LTD, TIRUPPUR,TAMILNADU

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.3326/Chny/2019 & 326/Chny/2024 िनधा"रण वष"/Assessment Years: 2017-18 & 2018-19 The Assistant Commissioner Of Vs. Eastman Exports Global Clothing (P) Ltd., No. 10, 12, 2Nd Street, Kumar Income Tax, Circle 1(1), 121, Adams Buildings, 60 Feet Road, Nagar South, Tirupur 641 603. Tirupur 641 602. [Pan: Aaccc0952E] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.706/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 Victus Dyeings, The Assistant Commissioner Of 410, P.N. Road, R.K. Nagar, Income Tax, Circle 1, Vs. Tirupur 641 601. Tirupur. [Pan: Aacfv4420D] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.768/Chny/2022 िनधा"रण वष"/Assessment Year: 2017-18 The Deputy Commissioner Of M/S. K.M. Knit Wear, Income Tax, Circle 1, 14, E.F. Lakshmi Nagar, First Street, Vs. Tirupur. City Garden, Tirupur 641 602. [Pan: Aacfk3053B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.358/Chny/2022 िनधा"रण वष"/Assessment Year: 2018-19 M/S. K.M. Knit Wear, The Assistant Commissioner Of 14, E.F. Lakshmi Nagar, First Street, Income Tax, Circle 1, Vs. City Garden, Tirupur 641 602. Tirupur. (अपीलाथ"/Appellant) (""थ"/Respondent)

disallowance on weighted deduction under section 35(2AB) of the Act, accordingly, the Assessing Officer determined the income of the assessee at ₹.36,61,77,500/- vide order dated 04.07.2019 passed under section 143(3) of the Act. 6. Aggrieved by the said order of the Assessing Officer, the assessee challenged the same before

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)

145 304 2.1.2. Valuation undertaken by the Company is in adherence with Rule 11UA of the Income Tax Rules 1962 ('the Rules’) • To determine deemed income under Section 56(2)(viia) of the Act, section prescribes a valuation methodology under Rule 11UA of the Rules. As per Rule 11UA(1)(c) provides that the FMV of unquoted shares

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)

145 304 2.1.2. Valuation undertaken by the Company is in adherence with Rule 11UA of the Income Tax Rules 1962 ('the Rules’) • To determine deemed income under Section 56(2)(viia) of the Act, section prescribes a valuation methodology under Rule 11UA of the Rules. As per Rule 11UA(1)(c) provides that the FMV of unquoted shares

JCIT (OSD) CIRCLE-2, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

In the result, appeal filed by the Revenue for assessment year

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 620/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income M/S. Karur Vysya Bank, V. Tax, Finance &Control Dept., Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 635/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. Karur Vysya Bank, The Joint Commissioner Of V. Finance &Control Dept., Income Tax, Erode Road, Circle -2, Karur – 639 002. No.44, Williams Road, [Pan: Aaact-3373-J] Contanment, Trichy – 620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Ananthan, Ca & Smt. R. Lalitha, Ca Department By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 05.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 20.09.2024 आदेश /O R D E R Per S. R. Raghunatha:

2. The learned CIT(A) erred in sustaining the addition made by the learned Assessing Officer of Rs.2,92,42,379/- being depreciation on equity shares – restructured. :-3-: ITA. Nos: 620 & 635/Chny/2020 2.1. The learned CIT(A) failed to appreciate the fact that the Appellant followed Reserve Bank of India guidelines as mandated by ICDS and section 145

VICTUS DYEINGS ,TIRUPUR vs. ACIT , CIRCLE-1, TIRUPUR

disallowance on weighted deduction under\nsection 35(2AB) of the Act, accordingly, the Assessing Officer determined\nthe income of the assessee at ₹.36,61,77,500/- vide order dated\n04.07.2019 passed under section 143(3) of the Act.\n6.\nAggrieved by the said order of the Assessing Officer, the assessee\nchallenged the same before

KM KNIT WEAR,TIRUPUR vs. ADIT,CPC, BANGALORE

In the result, ITA Nos. 3326/Chny/2019, 326/Chny/2024 &\n768/Chny/2022 are dismissed; ITA No

disallowance on weighted deduction under\nsection 35(2AB) of the Act, accordingly, the Assessing Officer determined\nthe income of the assessee at ₹.36,61,77,500/- vide order dated\n04.07.2019 passed under section 143(3) of the Act.\n6.\nAggrieved by the said order of the Assessing Officer, the assessee\nchallenged the same before

GATES WEARS,TIRUPPUR vs. DCIT CIRCLE 1, TIRUPPUR

In the result, ITA Nos. 3326/Chny/2019, 326/Chny/2024 &\n768/Chny/2022 are dismissed; ITA No

disallowance on weighted deduction under\nsection 35(2AB) of the Act, accordingly, the Assessing Officer determined\nthe income of the assessee at ₹.36,61,77,500/- vide order dated\n04.07.2019 passed under section 143(3) of the Act.\n6.\nAggrieved by the said order of the Assessing Officer, the assessee\nchallenged the same before

SAN TEX INC.,TIRUPUR vs. ACIT CIRCLE 1, TIRUPUR

disallowance on weighted deduction under\nsection 35(2AB) of the Act, accordingly, the Assessing Officer determined\nthe income of the assessee at ₹.36,61,77,500/- vide order dated\n04.07.2019 passed under section 143(3) of the Act.\n6.\nAggrieved by the said order of the Assessing Officer, the assessee\nchallenged the same before

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

disallowance was made by the AO on the incorrect pretext of non-availability of details. 8.7 We now proceed to examine the merits of the impugned claim of bad debts. As per the provisions of section 36(1)(vii) of the Act which ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025 (AYs 2021-22 & 2022-23) Jayapriya Company :: 13 :: deals with allowability

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

disallowance was made by the AO on the incorrect pretext of non-availability of details. 8.7 We now proceed to examine the merits of the impugned claim of bad debts. As per the provisions of section 36(1)(vii) of the Act which ITA Nos.1251 & 1252/Chny/2025 & CO Nos.43 & 44/Chny/2025 (AYs 2021-22 & 2022-23) Jayapriya Company :: 13 :: deals with allowability

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

2) of the Act, read with\nrule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under section 144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect

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

2) of the Act, read with\nrule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under Section 144 was not\ncorrect. It will be in those cases where the assessee in his return

M/S. KARUR VYSYA BANK,,KARUR vs. DCIT, CIRCLE - 2 (1),, TRICHY

2) TMI 125,\nheld that no disallowance u/s. 14A is permissible in terms of\nRule 8D, where the assessee is engaged in banking business. A\nsimilar view is taken by the Hon'ble Supreme Court in the case\nof South Indian Bank Ltd vs. CIT in Civil Appeal No. 9606 of\n2011, and held that shares and securities held

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

2) of the Act, read with\nrule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under section 144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect

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

2) of the Act, read with\nRule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under Section 14A was not\ncorrect. It will be in those cases where the assessee in his return

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

2) of the Act, read with\nrule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under section 144 was not\ncorrect. It will be in those cases where the assessee in his return

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

2) of the Act, read with\nrule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under section 144 was not\ncorrect. It will be in those cases where the assessee in his return

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

2) of the Act, read with\nrule 8D of the Rules, we also make it clear that before applying the theory\nof apportionment, the AO needs to record satisfaction that having regard to\nthe kind of the assessee, suo moto disallowance under section 144 was not\ncorrect. It will be in those cases where the assessee in his return