DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

3,48,31,838/- after making disallowance of ₹.34,28,05,564/- under section 14A r.w. Rule 8D. The disallowance

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

3,48,31,838/- after making disallowance of ₹.34,28,05,564/- under section 14A r.w. Rule 8D. The disallowance

SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

3,48,31,838/- after making disallowance of ₹.34,28,05,564/- under section 14A r.w. Rule 8D. The disallowance

SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

3,48,31,838/- after making disallowance of ₹.34,28,05,564/- under section 14A r.w. Rule 8D. The disallowance

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

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\n- For the purpose of computation of disallowance

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

ACIT CORPORATE CIRCLE 1, 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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A

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

disallowance as per Rule 8D. The application of Rule 8D, in our considered opinion, was not mechanical or automatic. 18. The Hon’ble Apex Court in the cited case of Godrej & Boyce Manufacturing Co. Ltd. V/s DCIT (2017 394 ITR 449) held that sub- sections (2) and (3) of Section 14A