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

C.E.S.ONYX PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Appeals of the assessee are dismissed

172\n(Ahmedabad-Trib.) that the assessee is a work contractor and not\neligible for deduction u/s. 80IA(4) of the Act.\nITA Nos.565 to 568/Chny/2020\n- 6 -:\n9. We have heard the rival submissions, and perused the materials\navailable on record. The only issue to adjudicate is whether the\nassessee-company is eligible for deduction u/s. 80IA(4

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

disallowed the entire claim of the assessee made certain additions. 4. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who partly allowed the appeal of the assessee, against which the Revenue is in further appeals before us. 5. In regard to ground nos.2 to 4.2 for the AY 2018-19 raised by the Revenue, the learned

C.E.S.ONYX PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.565, 566, 567 & 568/Chny/2020 िनधा<रण वष< /Assessment Years: 2004-05, 2005-06, 2006-07, 2007-08 Ces Onyx Pvt. Ltd., The Asst. Commissioner Of 46-B, Iv Floor, Krishnan Complex, Vs. Income Tax, South Boag Road, T. Nagar, Company Circle-1(3), Chennai – 600 017. Chennai. [Pan: Aabcc 1396D]

172 (Ahmedabad–Trib.) that the assessee is a work contractor and not eligible for deduction u/s. 80IA(4) of the Act. 9. We have heard the rival submissions, and perused the materials available on record. The only issue to adjudicate is whether the assessee-company is eligible for deduction u/s. 80IA(4) of the Act as enterprise carrying

C.E.S.ONYX PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.565, 566, 567 & 568/Chny/2020 िनधा<रण वष< /Assessment Years: 2004-05, 2005-06, 2006-07, 2007-08 Ces Onyx Pvt. Ltd., The Asst. Commissioner Of 46-B, Iv Floor, Krishnan Complex, Vs. Income Tax, South Boag Road, T. Nagar, Company Circle-1(3), Chennai – 600 017. Chennai. [Pan: Aabcc 1396D]

172 (Ahmedabad–Trib.) that the assessee is a work contractor and not eligible for deduction u/s. 80IA(4) of the Act. 9. We have heard the rival submissions, and perused the materials available on record. The only issue to adjudicate is whether the assessee-company is eligible for deduction u/s. 80IA(4) of the Act as enterprise carrying

C.E.S.ONYX PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals of the assessee are dismissed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.565, 566, 567 & 568/Chny/2020 िनधा<रण वष< /Assessment Years: 2004-05, 2005-06, 2006-07, 2007-08 Ces Onyx Pvt. Ltd., The Asst. Commissioner Of 46-B, Iv Floor, Krishnan Complex, Vs. Income Tax, South Boag Road, T. Nagar, Company Circle-1(3), Chennai – 600 017. Chennai. [Pan: Aabcc 1396D]

172 (Ahmedabad–Trib.) that the assessee is a work contractor and not eligible for deduction u/s. 80IA(4) of the Act. 9. We have heard the rival submissions, and perused the materials available on record. The only issue to adjudicate is whether the assessee-company is eligible for deduction u/s. 80IA(4) of the Act as enterprise carrying

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

disallowed the entire claim of the assessee\nmade certain additions.\n4. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who\npartly allowed the appeal of the assessee, against which the Revenue is in\nfurther appeals before us.\n5. In regard to ground nos.2 to 4.2 for the AY 2018-19 raised by the\nRevenue, the learned

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

disallowed the entire claim of the assessee\nmade certain additions.\n4. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who\npartly allowed the appeal of the assessee, against which the Revenue is in\nfurther appeals before us.\n5. In regard to ground nos.2 to 4.2 for the AY 2018-19 raised by the\nRevenue, the learned

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

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

172 taxmann.com 283 (Bombay)\nwhere it has been held Assessing Officer was justified in making\naddition of entire amount of bogus purchases & held in favour of\nrevenue.\n6. The Ld. LD.CIT(A) erred in deleting the addition made on\naccount of disallowances for Expenses without taking into\nconsideration the fact that the expenses per se were bogus in\nnature

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

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

172 taxmann.com 283 (Bombay)\nwhere it has been held Assessing Officer was justified in making\naddition of entire amount of bogus purchases & held in favour of\nrevenue.\n6. The Ld. LD.CIT(A) erred in deleting the addition made on\naccount of disallowances for Expenses without taking into\nconsideration the fact that the expenses per se were bogus in\nnature

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

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

172 taxmann.com 283 (Bombay)\nwhere it has been held Assessing Officer was justified in making\naddition of entire amount of bogus purchases & held in favour of\nrevenue.\n6. The Ld. LD.CIT(A) erred in deleting the addition made on\naccount of disallowances for Expenses without taking into\nconsideration the fact that the expenses per se were bogus in\nnature

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

172 taxmann.com 283 (Bombay)\nwhere it has been held Assessing Officer was justified in making\naddition of entire amount of bogus purchases & held in favour of\nrevenue.\n6. The Ld. LD.CIT(A) erred in deleting the addition made on\naccount of disallowances for Expenses without taking into\nconsideration the fact that the expenses per se were bogus in\nnature

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE 1(1), CHENNAI vs. DOOSAN POWER SYSTEMS INDIA PRIVATE LIMITED, CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1149/Chny/2023 िनधा"रणवष" / Assessment Year: 2015-16 Deputy Commissioner Of Doosan Power Systems India Income Tax, V. Private Limited, Corporate Circle -1(1), 18/2A, Sennerkuppam, Bye Chennai. Pass Road, Poonamallee, Chennai – 600 056. [Pan:Aabcb-5946-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Clement Ramesh Kumar, Cit ""यथ"क"ओरसे/Respondent By : Shri. Sandeep Bagmar, Ca सुनवाई क" तारीख/Date Of Hearing : 20.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 23.10.2024 आदेश /O R D E R

172 of the paper book filed on 04 July 2024). 8. IMPUGNED PAYMENTS ARE NOT IN NATURE OF ‘ROYALTY’ UNDER SECTION 9(1)(vi) OF THE ACT AS THE PAYMENTS WERE MERE SIMPLICITOR FREIGHT CHARGES; 8.1 The Ld.AR stated that in the Assessment order passed, the Ld. FAO referring to the explanation 2 of section

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

4 is noted to be against the disallowance of additional depreciation of Rs.9,65,562/- claimed by the assessee u/s 32(1)(iia) of the Act in relation to energy saving devices falling under the block(s) of 80% and 100%. At the onset, the Ld. AR pointed out that, out of the total claim, sum of Rs.13,996/- relates

ABAN OFFSHORE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is partly

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

disallowed u/s.40(a)(i) of the Act. 10. The ld. AR placed reliance on the decision of the Co-ordiante Bench in the case of Ford India Ltd., Vs. DCIT in ITA No.643 & 840/Mds,/2015 dated 31.01.2017 for the assessment years 2011-12 & 2012-13 and it was held in para 76 to 78 as follows:- “76 We have heard

NEELAMALAI AGRO INDUSTRIES LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal of the assessee is dismissed

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

4. The Commissioner of Income Tax should have found that in the light of the decision of the ‘C’ Bench of this Hon’ble Tribunal dated 7th November 2013 in ITA No.305/MDS/2013, also relating to assessment year 2009-2010, it is not permissible to make any disallowance under Section 14A of the Act unless the Assessing Officer proves that there

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. VIJAY DAIRY AND FARM PRODUCTS PRIVATE LIMITED, MUSIRI , TRICHY

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shrimanoj Kumar Aggarwal

4 :: of 20,60,848 liters of milk which was quantified as difference in purchase of 20,60,848 liters of milk which was quantified as difference in purchase of 20,60,848 liters of milk which was quantified as difference in purchase during the course of survey. during the course of survey. 4.1 The facts as noted are that