SHRIRAM OWNERSHIP TRUST,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals of the assessee for both

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. Nos. 406 & 407/Mds/2017 "नधा"रण वष" /Assessment Years : 2013-2014 & 2014-2015. Shriram Ownership Trust, Vs. The Deputy Commissioner Of No.4, Shriram House, I Floor, Income Tax, Burkit Road, T. Nagar, Non Corporate Circle 2, Chennai 600 017. Chennai 600 034. [Pan Aagts 2243H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

164 does not provide for such contingency. The principal contention raised by Mr. Salve on behalf of the assessee must, accordingly, be rejected. Why, then, should the beneficiary of a discretionary trust stand on a footing different from that of the beneficiary of a specific trust ? It is true that the language of section 166 does not avail the Revenue

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

disallowed a sum of Rs.5,99,34,183/- and assessed business loss at Rs.11,26,98,263/-. 3.0 The assessee went on appeal before the CIT(A) and the Ld.CIT(A) allowed the assessee’s appeal. However, the Ld.CIT(A) brought to tax the income in respect of income from investment in Venture Capital Undertaking (in short ‘VCU’) amounting

ITO, CHENNAI vs. TVS SHRIRAM GRWOTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

disallowed a sum of Rs.5,99,34,183/- and assessed business loss at Rs.11,26,98,263/-. 3.0 The assessee went on appeal before the CIT(A) and the Ld.CIT(A) allowed the assessee’s appeal. However, the Ld.CIT(A) brought to tax the income in respect of income from investment in Venture Capital Undertaking (in short ‘VCU’) amounting

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

disallowed a sum of Rs.5,99,34,183/- and assessed business loss at Rs.11,26,98,263/-. 3.0 The assessee went on appeal before the CIT(A) and the Ld.CIT(A) allowed the assessee’s appeal. However, the Ld.CIT(A) brought to tax the income in respect of income from investment in Venture Capital Undertaking (in short ‘VCU’) amounting

ITO, CHENNAI vs. TVS SHRIRAM GROWTH FUND, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

disallowed a sum of Rs.5,99,34,183/- and assessed business loss at Rs.11,26,98,263/-. 3.0 The assessee went on appeal before the CIT(A) and the Ld.CIT(A) allowed the assessee’s appeal. However, the Ld.CIT(A) brought to tax the income in respect of income from investment in Venture Capital Undertaking (in short ‘VCU’) amounting

T vs. SHRIRAM GROWTH FUND,CHENNAIVS.ITO, CHENNAI

In the result, the Appeal of the assessee is partly allowed and the Revenue’s appeals dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

disallowed a sum of Rs.5,99,34,183/- and assessed business loss at Rs.11,26,98,263/-. 3.0 The assessee went on appeal before the CIT(A) and the Ld.CIT(A) allowed the assessee’s appeal. However, the Ld.CIT(A) brought to tax the income in respect of income from investment in Venture Capital Undertaking (in short ‘VCU’) amounting

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

164(2) of the Act, the ld.CIT(A) observed that when whole or relevant part of any income is not exempt u/s.11 on account of provisions enshrined in section 13(1)(c) of the Act, tax would be charged on the whole of the relevant income or part of the relevant income at the maximum marginal rate and thus, entire

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

164(2) of the Act, the ld.CIT(A) observed that when whole or relevant part of any income is not exempt u/s.11 on account of provisions enshrined in section 13(1)(c) of the Act, tax would be charged on the whole of the relevant income or part of the relevant income at the maximum marginal rate and thus, entire

M/S JAYA EDUCATIONAL TRUST,THIRUVALLUR vs. DCIT, CC1(2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

164(2) of the Act, the ld.CIT(A) observed that when whole or relevant part of any income is not exempt u/s.11 on account of provisions enshrined in section 13(1)(c) of the Act, tax would be charged on the whole of the relevant income or part of the relevant income at the maximum marginal rate and thus, entire

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

164(2) of the Act, the ld.CIT(A) observed that when whole or relevant part of any income is not exempt u/s.11 on account of provisions enshrined in section 13(1)(c) of the Act, tax would be charged on the whole of the relevant income or part of the relevant income at the maximum marginal rate and thus, entire

M/S. TAMILNADU URBAN DEVELPMENT FUND,CHENNAI vs. DCIT, NCC-2,, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Dr. M.L. Meena

164 of the Act to the facts of the present case does not simply arise. 11. Therefore, we are satisfied that the Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1) of the Act which would apply only to the Revocable Transfer of the funds made for a period which

TAMIL NADU URBAN DEVELOPMENT FUND,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Dr. M.L. Meena

164 of the Act to the facts of the present case does not simply arise. 11. Therefore, we are satisfied that the Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1) of the Act which would apply only to the Revocable Transfer of the funds made for a period which

M/S. TAMILNADU URBAN DEVELPMENT FUND,CHENNAI vs. DCIT, NCC-2,, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Dr. M.L. Meena

164 of the Act to the facts of the present case does not simply arise. 11. Therefore, we are satisfied that the Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1) of the Act which would apply only to the Revocable Transfer of the funds made for a period which

TAMIL NADU URBAN DEVELOPMENT FUND,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Dr. M.L. Meena

164 of the Act to the facts of the present case does not simply arise. 11. Therefore, we are satisfied that the Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1) of the Act which would apply only to the Revocable Transfer of the funds made for a period which

TAMIL NADU URBAN DEVELOPMENT FUND,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Dr. M.L. Meena

164 of the Act to the facts of the present case does not simply arise. 11. Therefore, we are satisfied that the Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1) of the Act which would apply only to the Revocable Transfer of the funds made for a period which

TAMIL NADU URBAN DEVELOPMENT FUND,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Dr. M.L. Meena

164 of the Act to the facts of the present case does not simply arise. 11. Therefore, we are satisfied that the Tribunal was perfectly justified in invoking Section 62(2) of the Act read with Section 61(1) of the Act which would apply only to the Revocable Transfer of the funds made for a period which

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

Appeals of the revenue are dismissed

164 taxmann.com 376 (Calcutta) held as under:\n\n9. Substantial questions Nos. D & E pertain to the deletion of the disallowance\nmade under Section

VNC STEEL DISTRIBUTORS,,KARUR vs. DCIT, CIRCLE-1(1), TRICHY

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1937/Chny/2024 & Stay Petition No: 40/Chny/2024 [In Ita No: 1937/Chny/2024)] िनधा"रणवष" / Assessment Year: 2017-18 Vnc Steel Distributors, Deputy Commissioner Of No.2, Industrial Estate, V. Income Tax, S. Vellalapatti, Circle -1(1), Karur – 639 004. Trichy. [Pan: Aadfv-9137-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Abhinov Vaidyanathan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. R. Clement Ramesh Kumar, Cit सुनवाई क" तारीख/Date Of Hearing : 21.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 14.11.2024 आदेश /O R D E R

164) in support of the expenditure made by the assessee and prayed for deleting the disallowance made u/s. 40(a)(ia) of the Act to the tune of Rs.2,51,293/- for non-deduction of TDS. 5.2 Per contra, the ld.DR stated that the assessee has made payments to the Department of EPFO, Trichy, however the payment channels

M/S TAMILNADU STATE MARKETING CORPORATION LIMITED,CHENNAI vs. ACIT,CORPORATE CIRCLE 3 [1], CHENNAI

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

Bench: Shri Mahavir Singhand Dr. Dipak P. Ripoteआयकर अपीलसं./Ita No.: 353/Chny/2022 "नधा"रण वष"/Assessment Year: 2014-15 M/S. Tamilnadu State The Acit, Marketing Corporation Ltd., Vs. Corporate Circle 3(1), Cmda Tower, Ii, Iv Floor, Chennai. Gandhi Irwin Bridge Road, Egmore, Chennai – 600 008. Pan: Aaact 2964P (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओरसे/Appellant By : Shri R.Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई क" तार"ख/Date Of Hearing : 16.08.2022 घोषणा क" तार"ख/Date Of Pronouncement : 14.11.2022 आदेश /O R D E R Per Mahavir Singh: This Appeal By The Assessee Is Arising Out Of The Revision Order Passed U/S.263 Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) By The Principal Commissioner Of Income Tax (Appeals), Chennai-3 In Revision No.Pcit, Chennai-3/Revision-263/100000339483/2022 Dated 31.03.2022. The Assessment Was Framed By The Acit, Corporate Circle-3(1), Chennai For The Assessment Year 2014-15 U/S.143(3) Of The Act Vide Order Dated 30.12.2016. 2. The Only Issue In This Appeal Of Assessee Is As Regards To The Revision Order Passed By Pcit By Holding The Assessment Framed As Erroneous & Prejudicial To The Interest Of Revenue On Account Of Value Added Tax Paid By Assessee & Claimed As Deduction U/S.37 R.W.S. 43B Of The Act & Allowed.

disallow royalty, license fee, service fee, privilege fee, service charge or any other fee or charge, by whatever name called, which is levied exclusively on state Government undertakings. If it had been the intention to include Sales Tax/VAT, then in the section, taxes would have mentioned first before Royalty etc. The section refers to only Fees which are levied