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)

156 & 157 Ltd. taxmann.com 136 • Although the above rulings were rendered in the context of Section 14A, the principles establish shall squarely apply to the instant, case and accordingly, there shall be a presumption that the non-interest bearing equity funds were utilized for the payment of buyback consideration and hence, Section 36(1)(iii) would not be applicable. This

SHRIRAM FINANCE LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.173/Chny/2024 िनधा"रण वष"/Assessment Year: 2020-21 Shriram Finance Limited Vs. The Deputy Commissioner Of [Formerly Known As Shriram Transport Income Tax, Finance Company Limited), Corporate Circle 3(1), Sri Towers, Plot No. 14A, South Phase, Chennai. Industrial Estate, Guindy, Chennai 600 017. [Pan: Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.07.2024 घोषणा की तारीख /Date Of Pronouncement : 09.08.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 29.11.2023 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2020-21. 2. Ground No. 1 Is General In Nature & Requires No Adjudication.

156/-. However, the TDS allowed by rectification order under section 154 of the Act dated 21.12.2022 is only at ₹.402,06,11,108/- and TDS credit disallowed

DCIT CORPORATE CIRCLE 5(1), CHENNAI vs. REPCO HOME FINANCE P LTD., CHENNAI

In the result, the appeal of Revenue in ITA no

Bench: Shri George Mathan & Shri Ramit Kochar

disallowed under section 43B which, as stated above, was inserted with effect from 1-4-1984. It is also relevant to note that the first proviso which came into force with effect from 1-4-1988 was not on the statute book when the assessments were made in the case of Allied Motors (P.) Ltd. (supra). However, the assessee contended

SRINIVASA FASHINS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(4), CHENNAI

In the result, the appeal filed by the assessee in ITA

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy)नधा+रण वष+ /Assessment Year: 2014-15 Heard Through Video Conferencing V. M/S.Srinivasa Fashions Pvt. Ltd., The Income Tax Officer, No.57G, Sidco Industrial Estate, Corporate Ward-6(4), Ambattur, Chennai. Chennai-600 098. [Pan: Aaics 9511 R] (अपीलाथ./Appellant) (/0यथ./Respondent) : अपीलाथ. क1 ओर से/ Appellant By Mr.N.Vijay Kumar, Ca : Mr.Ar.V.Sreenivasan, Jcit /0यथ. क1 ओर से /Respondent By : 28.09.2020 सुनवाई क1 तार"ख/Date Of Hearing : 28.09.2020 घोषणा क1 तार"ख /Date Of Pronouncement आदेश / O R D E R Per Ramit Kochar:

disallowed under section 43B which, as stated above, was inserted with effect from 1-4-1984. It is also relevant to note that the first proviso which came into force with effect from 1-4-1988 was not on the statute book when the assessments were made in the case of Allied Motors (P.) Ltd. (supra). However, the assessee contended

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowed the claim of the assessee. Aggrieved, the assessee went in appeal before the CIT(Appeals). 14. On appeal, the CIT(Appeals), after considering the CBDT Circular No.2/2002 dated 15.2.2002 and 4/2004 dated 13.5.2004, relied on by the assessee, observed that these are issued by the CBDT in relation to a clarification regarding Tax Deduction at Source u/s.193

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowed the claim of the assessee. Aggrieved, the assessee went in appeal before the CIT(Appeals). 14. On appeal, the CIT(Appeals), after considering the CBDT Circular No.2/2002 dated 15.2.2002 and 4/2004 dated 13.5.2004, relied on by the assessee, observed that these are issued by the CBDT in relation to a clarification regarding Tax Deduction at Source u/s.193

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowed the claim of the assessee. Aggrieved, the assessee went in appeal before the CIT(Appeals). 14. On appeal, the CIT(Appeals), after considering the CBDT Circular No.2/2002 dated 15.2.2002 and 4/2004 dated 13.5.2004, relied on by the assessee, observed that these are issued by the CBDT in relation to a clarification regarding Tax Deduction at Source u/s.193

SWELECT ENERGY SYSTEMS LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 6(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.2652/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Swelect Energy System Ltd., The Deputy Commissioner Of No. 5, Numeric House, Vs. Income Tax, Sir P.S. Sivasami Salai, Corporate Circle -6(2), Mylapore, Chennai - 600 004. Chennai. [Pan: Aaacn2366F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Ms. R. Anita, Jcit सुनवाई की तारीख/ Date Of Hearing : 07.04.2021 घोषणा की तारीख /Date Of Pronouncement : 19.04.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-15, Chennai, Dated 29.06.2018 Relevant To The Assessment Year 2014-15. The Assessee Has Raised Following Grounds: “1. The Order Of The Commissioner Of Income Tax (Appeals) - 15, Chennai Dated 29.06.2018 In I.T.A.No.517/2016-17//Cit(A)-15 For The Above Mentioned Assessment Year Is Contrary To Law, Facts & In The Circumstances Of The Case. 2. The Cit (Appeals) Erred In Sustaining The Disallowance Of Notional Expenses Aggregating To Rs.2,49,84,018/- (Rs.2,51, 76,518 - Rs.1,92,500) For Maintaining Tax Free Portfolio/For Earning Tax Free Income To The Extent Of Rs,3,74,62,711/- On The Application Of Section 14A Of The Act Read With Rule 8D

disallowance of the assessee that it was unrealistic to state that only ₹.1,92,500/- was made as expenses to maintain the investment amount of ₹.393,01,06,156/-, by invoking the provisions of section

SRINIVASAN MOHAMMAD IBRAHIM,MADURAI vs. ITO,NON-CORPORATE WRD-2(3), MADURAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.233 & 234/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 Srinivasan Mohammad Ibrahim, Vs. The Income Tax Officer, 69, South Marret Street, Non Corporate Ward 2(3), Madurai South, South Gate S.O., Chennai. Madurai 625 001. [Pan: Ailpm0929R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri R. V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 23.07.2024 घोषणा की तारीख /Date Of Pronouncement : 26.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi:

156/- made under section 68 of the Act. 4. At the outset, we note that the assessment was completed under section 147 read with section 144B of the Act by disallowing

SRINIVASAN MOHAMMAD IIBRAHIM,MADURAI vs. THE INCOME TAX OFFICER, NON CORPORATE WARD-2(3), MADURAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.233 & 234/Chny/2024 िनधा"रण वष"/Assessment Year: 2013-14 Srinivasan Mohammad Ibrahim, Vs. The Income Tax Officer, 69, South Marret Street, Non Corporate Ward 2(3), Madurai South, South Gate S.O., Chennai. Madurai 625 001. [Pan: Ailpm0929R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri I Dinesh, Advocate ""थ" की ओर से/Respondent By : Shri R. V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 23.07.2024 घोषणा की तारीख /Date Of Pronouncement : 26.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi:

156/- made under section 68 of the Act. 4. At the outset, we note that the assessment was completed under section 147 read with section 144B of the Act by disallowing

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

disallowed by the Appellant. 5. Set off of brought forward business loss before allowing deduction under Section 10B of the Act. 5.1 The DRP/AO erred in setting off the brought forward business loss of earlier years from profits of the undertaking before allowing deduction under Section 10B of the Act. 5.2 The DRP/AO failed to appreciate that the term ‘total

M/S. CEEBROS HOTELS PVT. LTD.,,CHENNAI vs. DCIT, CC - 1 (2),, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

disallowance of the interest expenses. 6. The CIT (Appeals) failed to appreciate that the conclusion reached on the non commencement of the project which was related to the claim of the interest expenses was wholly unjustified and ought to have appreciated that the commencement of the project/business under consideration should be reckoned from the date of the purchase

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Income Tax, Pvt. Ltd.,) The Dy./Asst. Commissioner Of Central Circle-2(4), 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P Chennai. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Integrated Service Point Ltd., Income Tax, Central Circle-2(4), Chennai. (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख / Date Of Pronouncement 13.10.2025 30.12.2025 - : 2 -:

disallowances at 20% of the alleged bogus purchases, which is over and above the disallowances of 12% on alleged bogus purchases voluntarily returned by the appellant in ROI u/s.148 for the impugned AY 2019-20. 3.2 On the facts and circumstances of the case, the learned Commissioner of Income Tax (Appeals)-19, Chennai erred in enhancing the disallowances over

VYASARPADI CO-OP. INDUSTRIAL ESTATE LTD.,,CHENNAI vs. ITO, CHENNAI

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita Nos.252, 253 & 254/Mds/2017 "नधा"रण वष" / Assessment Years : 1996-97 To 1998-99

disallowed the claim of the assessee under Section 80P(2)(d) of the Act in respect of interest income received by the assessee on the fixed deposit with Tamil Nadu Industrial Co-operative Bank Ltd. The assessee subsequently filed application under Section 154 of the Act on the ground that there is an error in the order of the Assessing

VYASARPADI CO-OP. INDUSTRIAL ESTATE LTD.,,CHENNAI vs. ITO, CHENNAI

In the result, all the appeals filed by the assessee are dismissed

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita Nos.252, 253 & 254/Mds/2017 "नधा"रण वष" / Assessment Years : 1996-97 To 1998-99

disallowed the claim of the assessee under Section 80P(2)(d) of the Act in respect of interest income received by the assessee on the fixed deposit with Tamil Nadu Industrial Co-operative Bank Ltd. The assessee subsequently filed application under Section 154 of the Act on the ground that there is an error in the order of the Assessing

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon'Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./ Ita Nos.1874, 1876 & 1879/Chny/2025 निर्धारण वर्ष / Assessment Years: 2016-17, 2019-20 & 2022-23 The Dy./Asst. Commissioner Of Income Tax, Central Circle-2(4), Chennai. Integrated Service Point Ltd., (Formerly Integrated Service Point Vs. Pvt. Ltd.,) 6C, 6Th Floor, Gaiety Palace I/L, Blackers Road, Anna Road H.O., Chennai - 600 002. Pan: Aaaci 9527P (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr. Y. Sridhar, Fca प्रत्यर्थी की ओर से /Revenue By : Mr. Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 13.10.2025 घोषण की तारीख / Date Of Pronouncement : 30.12.2025 :- 2 -:

disallowances over and above the voluntary disallowance, without appreciating the fact that the search did not result in unearthing of any excess/unexplained cash or assets or investments or expenditure or payments for non-business purposes or any other incriminating evidences. Ground No. 2 for A.Y. 2016-17 153. Ground No. 2 is specific to A.Y. 2016-17 and is considered

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

disallowance at 20% of alleged bogus purchases as against appellant’s voluntary disallowance of 12% in ROI u/s 148. 3.1 On facts and under the circumstances of the case, the learned Commissioner of Income Tax (Appeals)-19, Chennai erred in adjudicating the disallowances at 20% of the alleged bogus purchases, which is over and above the disallowances

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

disallowance at 20% of alleged bogus purchases as against appellant’s voluntary disallowance of 12% in ROI u/s 148. 3.1 On facts and under the circumstances of the case, the learned Commissioner of Income Tax (Appeals)-19, Chennai erred in adjudicating the disallowances at 20% of the alleged bogus purchases, which is over and above the disallowances

ASSISTANT COMMISSIONER OF INCOME TAX, MADURAI vs. RAMCO INDUSTRIES LIMITED, CHENNAI

Appeals of the revenue are dismissed

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकरअपीलसं./I.T.A.No.2900 & 2901/Chny/2024 (निर्धारण वर्ष / Assessment Year: 2011-12 & 2013-14)

156 ITD 72 wherein it has been held that the addition on account of disallowance u/s. 14A r.w.Rule 8D being expenditure in relation to earning of exempt income to Book Profit u/s I 15JB is justified. (7) For these and such other grounds that may be adduced at the time of hearing and it is prayed that the order