DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing consultancy fee of Rs.13,70,90,436/- and Escrow fee of Rs.2,01,663/- paid to standard chartered bank is confirmed. This ground of appeal is dismissed. ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 13 -: ITA Nos.1417 & 1421/Chny/2016 5.6 Additional ground No.7 raised by the appellant is against adjustment of interest

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing consultancy fee of Rs.13,70,90,436/- and Escrow fee of Rs.2,01,663/- paid to standard chartered bank is confirmed. This ground of appeal is dismissed. ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 13 -: ITA Nos.1417 & 1421/Chny/2016 5.6 Additional ground No.7 raised by the appellant is against adjustment of interest

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

200. In view of the above facts and figures it is apparent that assessee had utilized interest free funds for making fresh investments and that too into its subsidiaries which is not for the purpose of earning exempt income and which are for strategic purposes only. 8. In view of the above facts, we hold that no disallowance of interest

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

200. In view of the above facts and figures it is apparent that assessee had utilized interest free funds for making fresh investments and that too into its subsidiaries which is not for the purpose of earning exempt income and which are for strategic purposes only. 8. In view of the above facts, we hold that no disallowance of interest

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

disallowance is required to be made. With this direction, a ground of appeal raised by the Assessee is allowed for statistical purposes. 3.3 The Next issue is regarding allowance of deduction under Section 35(2AB). The Assessee has raised an additional ground stating that weighted deduction under Section 35(2AB) should be granted on the entire expenditure incurred

SHRIRAMINSIGHT SHARE BROKERS LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 6(1), 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.2975/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 Shriram Insight Share Brokers Ltd., The Deputy Commissioner Of Mookambika Complex, No. 4, Lady Vs. Income Tax, Desika Road, Mylapore, Corporate Circle – 6(1), Chennai 600 004. Chennai. [Pan: Aaaci2727H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Gautham Venketanarayanan, Advocate ""थ" की ओर से/Respondent By : Shri J. Pavitran Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 16.09.2019 घोषणा की तारीख /Date Of Pronouncement : 11.10.2019 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 31.07.2018 Relevant To The Assessment Year 2014-15. The Grounds Raised In The Appeal Of The Assessee Are That The Ld. Cit(A) Has Erred In Confirming The Part Disallowance Made Under Section 14A R.W. Rule 8D, Disallowance Of Depreciation In Respect Of Royalty, Disallowance Of Bad Debt & Part

section 115JB of the Act, the ld. CIT(A) restricted the disallowance to the extent the exempt income earned by the assessee by following the decision of Joint Investments Pvt. Ltd. v. CIT (supra). In this case, the assessee has voluntarily disallowed ₹.7,200

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance made under section 35(2AB) of the Act. 33. The assessee has claimed weighted deduction @ 200% under section 35(2AB) of the Act for ₹.9,29,85,000/-, out of which

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance made under section 35(2AB) of the Act. 33. The assessee has claimed weighted deduction @ 200% under section 35(2AB) of the Act for ₹.9,29,85,000/-, out of which

KRISHNAMURTHY SRINIVASAN,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.3396/Mds/2016 "नधा"रण वष"/Assessment Year:2012-13 Shri Krishnamurthy Srinivasan, The Assistant Commissioner Of No. 1C, Vanagaram Road, Athipet, Vs. Income Tax, Ambattur Industrial Estate, Ambattur, Non Corporate Circle 7(1), Chennai 600 058. Chennai. [Pan:Bbkps4428J] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri D. Anand, Advocate ""यथ" क" ओर से/Respondent By : Shri S. Mohamed Mustafa, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 25.05.2017 घोषणा क" तार"ख /Date Of Pronouncement : 12.07.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This The Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 7, Chennai, Dated 17.10.2016 Relevant To The Assessment Year 2012-13. The Only Effective Ground Raised By The Assessee Is That The Ld. Cit(A) Has Erred In Confirming The Disallowance Of ₹.75,66,470/- Made Under Section 40(A)(Ia) Of The Income Tax Act, 1961 [“Act” In Short].

disallowed by the Assessing Officer as per the provisions of Section 40(a)(ia) of the Act. Against the order of the Assessing Officer, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Shimla who vide its order dated August 17, 2012 upheld the order dated November 30, 2011. The matter thereafter came up in appeal before

ACIT, CHENNAI vs. ESKAY DESIGNS, CHENNAI

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

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddyआयकर अपील सं./I T.A. No. 247/Mds/2017 "नधा"रण वष"/Assessment Year:2012-13 The Assistant Commissioner Of M/S. Eskay Designs, No. 25, 1St Street, Cenotaph Road, Income Tax, Non-Corporate Circle 3, Vs. 121, Mahatma Gandhi Road, Teynampet, Chennai 600 018. Nungambakkam, Chennai 600 034. [Pan:Aaafe1480C] (Appellant) (Respondent) अपीलाथ" क" ओर से / Appellant By : Mrs. S. Vijayaprabha, Jcit ""यथ" क" ओर से/Respondent By : Shri K. Ravi, Advocate सुनवाई क" तार"ख/ Date Of Hearing : 07.02.2018 घोषणा क" तार"ख /Date Of Pronouncement : 28.02.2018 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 4, Chennai Dated 31.10.2016 Relevant To The Assessment Year 2012-13. The First Issue Raised In The Appeal Of The Revenue Is That The Ld. Cit(A) Erred In Directing To Assess The Rental Income Received By The Assessee On Sub-Letting Of Its Leased Out Properties Under The Head “Income From House Property” & The Second Issue Is That The Ld. Cit(A) Erred In Directing To Allow The Expenses If They Are Paid As On 2

disallowed by the Assessing Officer as per the provisions of Section 40(a)(ia) of the Act. Against the order of the Assessing Officer, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Shimla who vide its order dated August 17, 2012 upheld the order dated November 30, 2011. The matter thereafter came up in appeal before

DCIT CORPORATE CIRCLE 1 (2), CHENNAI vs. M/S CAPLIN POINT LABORATORIES LTD, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1716/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 The Deputy Commissioner Of Vs. M/S. Caplin Point Laboratories Ltd., Income Tax, No. 3, Narbavi, Lakshmanan Street, Corporate Circle 1(2), T. Nagar, Chennai 600 017. Chennai 600 034. [Pan:Aabcc2667F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri P. Sajit Kumar, Jcit ""थ" की ओर से/Respondent By : Shri R. Vijayaraghavan, Advocate सुनवाई की तारीख/ Date Of Hearing : 17.07.2023 घोषणा की तारीख /Date Of Pronouncement : 26.07.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai, Dated 07.03.2019 Relevant To The Assessment Year 2013-14. 2. The Appeal Filed By The Revenue Is Delayed By Two Days In Filing The Appeal, For Which, The Revenue Has Filed An Affidavit For Condonation Of The Delay, To Which; The Ld. Counsel For The Assessee Has Not Raised Any Serious Objection. Consequently, Since The Revenue Was Prevented By 2

200%. The return filed by the assessee was selected for scrutiny under CASS. After considering the various details and submissions of the assessee, the Assessing Officer has completed the assessment under section 143(3) of the Act dated 29.03.2016 assessing total income of the assessee at ₹.17,21,01,070/- by making various additions. On appeal

WABCO INDIA LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 3(2), CHENNAI

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

Bench: Shri Ramit Kochar & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 2606/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 Vs. The Assistant Commissioner Of M/S. Wabco India Limited, Plot No. 3 (Sp), Iii Main Road, Income Tax, Ambattur Industrial Estate, Corporate Circle 3(2), Chennai 600 058. Chennai. [Pan: Aafca6421P] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" की ओर से/ Appellant By Shri S. Venkatasubramanian, C.A. ""थ" की ओर से /Respondent By : Shri A. Sundararajan, Addl. Cit : सुनवाई की तारीख/Date Of Hearing 18.11.2019 घोषणा की तारीख /Date Of Pronouncement : 26.12.2019

section 35(2AB) of the Act to the extent of ₹.4,33,22,839/- being revenue expenditure and ₹.6,19,46,239/- being 200% of capital expenditure. Since the assessee could not provide certificate from DSIR on which the claim can be allowable, the weighted deduction claimed of ₹.10,52,69,078/- was disallowed

MANSI FINANCE CHENNAI LIMITED,CHENNAI vs. THE ACIT, CC 4(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 108 & 109/Chny/2021 िनधा"रण वष"/Assessment Years: 2012-13 & 2013-14

200/- and the assessment under section 143(3) of the Income Tax Act, 1961 [“Act” in short] was completed on 30.03.2015 determining the assessed income of the assessee at ₹.77,91,865/-. Thereafter, the assessee preferred further appeal before the ld. CIT(A) and the ld. CIT(A) has confirmed the additions by dismissing the appeals of the assessee

MANSI FINANCE CHENNAI LIMITED,CHENNAI vs. THE ACIT, CC-4(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 108 & 109/Chny/2021 िनधा"रण वष"/Assessment Years: 2012-13 & 2013-14

200/- and the assessment under section 143(3) of the Income Tax Act, 1961 [“Act” in short] was completed on 30.03.2015 determining the assessed income of the assessee at ₹.77,91,865/-. Thereafter, the assessee preferred further appeal before the ld. CIT(A) and the ld. CIT(A) has confirmed the additions by dismissing the appeals of the assessee

M/S POTHYS,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(3), CHENNAI

The appeal is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No. 1360/Chny/2023 (िनधा"रणवष" / Assessment Year: 2020-21) M/S. Pothys, Vs. The Deputy Commissioner Of No.15, Dr.Nageswara Rao Road, Income Tax, T. Nagar, Central Circle 1(3), Chennai – 600 017. Chennai. [Pan: Aaffp 2437B] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri N. Arjun Raj, Advocate For Shri Y. Sridhar, Ca ""यथ" क" ओर से /Respondent By : Shri Ar.V. Srinivasan, Addl. Cit सुनवाई क" तारीख/Date Of Hearing : 09.05.2024 घोषणा क" तारीख /Date Of Pronouncement : 15.05.2024 आदेश / O R D E R Manu Kumar Giri ()

200 or the proviso to sub-Section (3) of after the 1st day of July, 2012. Section 234E of Income Tax Act was introduced by the Finance Act, 2012 w.e.f. 01.07.2012 which applies for the late filing of TDS statement. The vires of Section 234E of the Income Tax Act, 1961 was challenged before the Hon’ble Jurisdictional High Court

PARRY INFRASTRUCTURE CO P LTD. ,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1) , CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

200/- (sic) and that this amount has to be disallowed under section 40A(2)(b) of the Act. 13.2 The CIT(A) has, both

ROCA BATHROOM PRODUCTS PRIVATE LIMITED,CHENNAI vs. JCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

200.)” Section 201(1A) enables the assessing officer to levy interest in case the tax was not deducted either wholly or partly or after deduction it was not paid as required under the Act. In fact, the provisions of section 201(1A) was amended by Finance Act, 2001 with retrospective effect from 01-04-1962 after the judgment

DCIT, CHENNAI vs. PARRYWARE ROCA PVT. LTD., CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

200.)” Section 201(1A) enables the assessing officer to levy interest in case the tax was not deducted either wholly or partly or after deduction it was not paid as required under the Act. In fact, the provisions of section 201(1A) was amended by Finance Act, 2001 with retrospective effect from 01-04-1962 after the judgment