ILJIN AUTOMOTIVE PRIVATE LIMITED,IRUNGATTUKOTTAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), ),, CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

19 February 2021 is without jurisdiction as the said order was passed without providing an opportunity of being heard as required under section 154(3) of the Act which is in violation of principles of natural justice and thereby, liable to be quashed. 3. The Ld.DR opposed admitting of the aforesaid additional ground. However, we note that this

ILJIN AUTOMOTIVE PRIVATE LIMITED,,KANCHIPURAM vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

19 February 2021 is without jurisdiction as the said order was passed without providing an opportunity of being heard as required under section 154(3) of the Act which is in violation of principles of natural justice and thereby, liable to be quashed. 3. The Ld.DR opposed admitting of the aforesaid additional ground. However, we note that this

ILJIN AUTOMOTIVE PRIVATE LIMITED,KANCHIPURAM vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 2(1), CHENNAI, CHENNAI

In the result, appeals filed by the assessee are allowed

Bench: Shri Aby T. Varkey & Shri S.R.Raghunatha

19 February 2021 is without jurisdiction as the said order was passed without providing an opportunity of being heard as required under section 154(3) of the Act which is in violation of principles of natural justice and thereby, liable to be quashed. 3. The Ld.DR opposed admitting of the aforesaid additional ground. However, we note that this

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

155/- already offered ITA Nos.2330 & 2618/Chny/2019 (AY 2015-16) M/s. Ashok Leyland Ltd. :: 6 :: by the assessee, the further disallowance in terms of Rule 8D(2)(iii) comes to Rs.27,88,820/-. Hence, respectfully following the decision of Special Bench (supra), the AO is directed to verify this computation provided by the assessee and re-compute the disallowance under section

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

155, wherein by dismissing the appeal of the Revenue, appeal of the Revenue, the Hon’ble High Court has held as under: the Hon’ble High Court has held as under:-- Held, dismissing the appeal, that on a reading of section Held, dismissing the appeal, that on a reading of section Held, dismissing the appeal, that on a reading

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

19, Chennai erred in not adjudicating and dismissing the ground on the legal validity of the notice issued u/s 148 of the Act, which lacks jurisdiction, as the prescribe authority, as specified u/s 151 of the Act did not approve the same. :- 60 -: ITA Nos.1881, 1882 & 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. 3. Adjudication of disallowance

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

19, Chennai erred in not adjudicating and dismissing the ground on the legal validity of the notice issued u/s 148 of the Act, which lacks jurisdiction, as the prescribe authority, as specified u/s 151 of the Act did not approve the same. :- 60 -: ITA Nos.1881, 1882 & 1883/Chny/2025 ITA Nos.1874, 1876 & 1879/Chny/2025 Integrated Service Point Ltd. 3. Adjudication of disallowance

DCIT, CHENNAI vs. V.A. TECH WABAG LIMITED, CHENNAI

Appeal is allowed for statistical purposes

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

19,46,943/- is hereby disallowed.” Aggrieved, the assessee raised objection before DRP. 27. The DRP considering the earlier orders, allowed the claim of the assessee by observing in para 3.1 to 3.1.3 as under: “3.1.2. We have considered the order of the Assessing Officer, the contentions of the assessee, orders of the CIT(A), etc. carefully. The issue

VA TECH WABAG LIMITED,CHENNAI vs. ACIT, CHENNAI

Appeal is allowed for statistical purposes

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

19,46,943/- is hereby disallowed.” Aggrieved, the assessee raised objection before DRP. 27. The DRP considering the earlier orders, allowed the claim of the assessee by observing in para 3.1 to 3.1.3 as under: “3.1.2. We have considered the order of the Assessing Officer, the contentions of the assessee, orders of the CIT(A), etc. carefully. The issue

ASHOK LEYLAND LIMITED,,CHENNAI vs. ACIT,, CHENNAI

155/- already offered\nITA Nos.2330 & 2618/Chny/2019 (AY 2015-16)\nM/s. Ashok Leyland Ltd.\n:: 6 ::\nby the assessee, the further disallowance in terms of Rule 8D(2)(iii)\ncomes to Rs.27,88,820/-. Hence, respectfully following the decision of\nSpecial Bench (supra), the AO is directed to verify this computation\nprovided by the assessee and re-compute the disallowance under

FAURECIA EMISSIONS CONTROL TECHNOLOGIES INDIA PRIVATE LIMITED,CHENNAI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX - CORPORATE CIRCLE 1(1) CHE, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1223/Chny/2025 Assessment Years: 2023-24 Faurecia Emissions Control Assistant Commissioner Of Technologies India Pvt Ltd, Income Tax, 1St Floor, No.634, Karumuthu Center, Corporate Circle-1(1), Anna Salai, Nandanam, Chennai. Chennai-600 035 [Pan: Aaaca8450F] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.Siddhesh Chaugula, C.A. प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 04.09.2025 घोषणा की तारीख /Date Of Pronouncement : 14.11.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

disallowance of deduction claimed under 95[section 10AA or under any of the provisions of Chapter VI-A under the heading “C.-Deductions in respect of certain incomes”, if] the return is furnished beyond the due date specified under sub-section (1) of section 139; or (vi) addition of income appearing in Form 26AS or Form 16A or Form

PUDUKOTTAI DISTRICT COOPERATIVE MILK PRODUCERS UNION LTD,PUDUKOTTAI vs. ITO CIRCLE 2(1), TRICHY

In the result the appeal filed for the A

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1434/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19 Pudukottai District Cooperative Milk Income Tax Officer, Producers Union Ltd., V. Circle -2(1), 6527/3, Kalyanaramapuram 1St Trichy. Street, Thirukokarnam, Pudukottai – 622 002. [Pan: Aaaat-6119-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Y. Sridhar, Fca : Smt. M.S. Deeptha, Jcit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 08.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 01.10.2024

155/- u/s.80P(2)(d) in respect of interest income earned from Pudukkottai District Central Cooperative Bank on the ground that the deduction is available in the above section is only for the interest received from the co-operative society and not from the co- operative bank. Aggrieved by the addition, the appellant preferred an appeal before

FUJI ELECTRIC INDIA PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI

In the result the appeal of the Assessee is partly allowed for statistical purposes

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

155 (Cochin ITAT) These decisions reinforce that TDS liability arises only when income accrues to the payee. In view of the above, the Appellant respectfully submits that: • Provisions for ASP charges and sales commission are legitimate business expenditures allowable under Section 37. • Disallowance under Section 40(a)(ia) is not warranted. • Alternatively, if disallowance is contemplated, the expenditure should

M/S. TRIVITRON HEALTHCARE PVT. LTD.,CHENNAI vs. PCIT, , CHENNAI-3

In the result, the appeal filed by the assessee is partly\nallowed

19 169\nASSESSMENT PROCEEDING\n4 22.09.2019 Notice under Section 143(2) of the Act 204\n5 04.10.2019 Reply to Notice under Section 143(2) of the 208\nAct\n6 21.12.2020 Notice under Section 142(1) of the Act 210\n7 05.01.2021 1st Reply to Notice under Section 142(1) of 214\nthe Act\n8 Form No. 3CK filed

DCIT, CENTRAL CIRCLE 2(2), CHENNAI vs. N RAMASAMY, CHENNAI

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

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपील सं./I.T.A Nos.127 & 128/Chny/2019 िनधा"रण वष" /Assessment Years : 2015-2016 & 2016-2017 The Deputy Commissioner Of Vs. Shri. N. Ramasamy, Income Tax, No.14/19, Saraswathi Street, Central Circle 2(2), Mahaingapuram, Nungambakkam High Road, Chennai 600 034. Chennai 600 034. [Pan Adupr 8003P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Nilay Baran Som, Irs, Cit. ""यथ" क" ओर से /Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 18.12.2023. घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023 आदेश / O R D E R Per Mahavir Singh:

155/- is disallowed added back to the assessee total income’’. Aggrieved, assessee preferred an appeal before the CIT(A). The CIT(A) deleted addition by observing as under:- 8. ‘’7. The same principle applies to the addition of Rs. 1,07,56,041/- in respect of the movie "PISASU". On verification of the cost, it is seen that, the same

DCIT, CENTRAL CIRCLE 2(2), CHENNAI vs. N RAMASAMY, CHENNAI

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

Bench: Shri Mahavir Singh & Shri Manjunatha.Gआयकर अपील सं./I.T.A Nos.127 & 128/Chny/2019 िनधा"रण वष" /Assessment Years : 2015-2016 & 2016-2017 The Deputy Commissioner Of Vs. Shri. N. Ramasamy, Income Tax, No.14/19, Saraswathi Street, Central Circle 2(2), Mahaingapuram, Nungambakkam High Road, Chennai 600 034. Chennai 600 034. [Pan Adupr 8003P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Nilay Baran Som, Irs, Cit. ""यथ" क" ओर से /Respondent By : Shri. S. Sridhar, Advocate सुनवाई क" तारीख/Date Of Hearing : 18.12.2023. घोषणा क" तारीख /Date Of Pronouncement : 29.12.2023 आदेश / O R D E R Per Mahavir Singh:

155/- is disallowed added back to the assessee total income’’. Aggrieved, assessee preferred an appeal before the CIT(A). The CIT(A) deleted addition by observing as under:- 8. ‘’7. The same principle applies to the addition of Rs. 1,07,56,041/- in respect of the movie "PISASU". On verification of the cost, it is seen that, the same

SUNDARAM FASTENERS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee in IT(TP)A No

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Section 40(a)(i) shall, therefore, not apply in respect of the impugned payments. There is no finding with regard to the foreign agents being tax residents of USA or, as the case may be, UK; the assessee not making it’s case with reference to the relevant DTAAs before the Revenue. Accordingly, subject to finding of it being

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

Disallowance of provision for subcontracting expenses 3.1The Ld. CIT has, in the facts and circumstances of the case and in law, erred by disregarding the fact that the Appellant had created a provision for warranty based on unbilled revenue recorded by Keller India in percentage of completion method and therefore, the provision created shall be regarded as scientific