UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

211/- Interest on Tax Free Bonds u/s 10(15)(i) ₹. 1,76,12,403/- Dividend income received from VCF u/s 10(34) ₹. 4,40,105/- Dividend income u/s 10(34) ₹. 388,58,24,247/- 24. On perusal of the above, it is noted that the Tribunal observed that the Assessing Officer granted exemption in respect of all above except

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

211/- Interest on Tax Free Bonds u/s 10(15)(i) ₹. 1,76,12,403/- Dividend income received from VCF u/s 10(34) Dividend income u/s 10(34) ₹. 4,40,105/- ₹. 388,58,24,247/- 24. On perusal of the above, it is noted that the Tribunal observed that the Assessing Officer granted exemption in respect of all above except

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)

disallowance of loss on actual re is against the disallowance of loss on actual re is against the disallowance of loss on actual re- payment of External Commercial Borrowings (hereinafter in short ‘ECB’) payment of External Commercial Borrowings (hereinafter in short ‘ECB’) payment of External Commercial Borrowings (hereinafter in short ‘ECB’) loan during the year. 8.1 The brief facts

UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

211/- ₹. 1,76,12,403/- ₹. 4,40,105/- ₹. 388,58,24,247/- 24. On perusal of the above, it is noted that the Tribunal observed that the Assessing Officer granted exemption in respect of all above except on LTCG on transfer of shares under section 10(38) of the Act to an extent of Rs.588,85,02,720/-. Therefore

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

disallowance made u/s 40(a)(i) in this regard is held to be unjustified and is directed to be deleted. This ground is therefore allowed. ITA Nos.2330 & 2618/Chny/2019 (AY 2015-16) M/s. Ashok Leyland Ltd. :: 21 :: 9. Ground No. 8 of the assessee’s appeal is against the Ld. CIT(A)’s action of confirming the AO’s order

MAHINDRA WORLD CITY DEVELOPERS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the corresponding grounds of the assessee are

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. Nos. 2084, 2085 & 2086/Chny/2016 "नधा"रणवष"/Assessment Years : 2010-11 To 2012-13

211 provides that until the Central Government prescribes an accounting standard in consultation with the National Advisory Committee as set up under section 210A of the Companies Act, 1956 pursuant to a recommendation of the ICAI; the Accounting Standard issued by the ICAI shall prevail. Therefore, we have no difficulty in accepting the submissions of the learned counsel

MAHINDRA WORLD CITY DEVELOPERS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the corresponding grounds of the assessee are

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. Nos. 2084, 2085 & 2086/Chny/2016 "नधा"रणवष"/Assessment Years : 2010-11 To 2012-13

211 provides that until the Central Government prescribes an accounting standard in consultation with the National Advisory Committee as set up under section 210A of the Companies Act, 1956 pursuant to a recommendation of the ICAI; the Accounting Standard issued by the ICAI shall prevail. Therefore, we have no difficulty in accepting the submissions of the learned counsel

MAHINDRA WORLD CITY DEVELOPERS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the corresponding grounds of the assessee are

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकरअपीलसं/.I.T.A. Nos. 2084, 2085 & 2086/Chny/2016 "नधा"रणवष"/Assessment Years : 2010-11 To 2012-13

211 provides that until the Central Government prescribes an accounting standard in consultation with the National Advisory Committee as set up under section 210A of the Companies Act, 1956 pursuant to a recommendation of the ICAI; the Accounting Standard issued by the ICAI shall prevail. Therefore, we have no difficulty in accepting the submissions of the learned counsel

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

211/- (Rs.8,05,21,425/- Rs.1,20,78,213/- ). Accordingly, we confirm the findings of the CIT(Appeals) on this issue and reject the ground taken by the Revenue. Therefore, the ground of appeal is dismissed. 11. The next issue raised by the Revenue in ITA No.1697/Mds/2014 is as under: “5.1 The ld. CIT(A) erred in deleting the disallowance

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

211/- (Rs.8,05,21,425/- Rs.1,20,78,213/- ). Accordingly, we confirm the findings of the CIT(Appeals) on this issue and reject the ground taken by the Revenue. Therefore, the ground of appeal is dismissed. 11. The next issue raised by the Revenue in ITA No.1697/Mds/2014 is as under: “5.1 The ld. CIT(A) erred in deleting the disallowance

DCIT, CHENNAI vs. SICAL LOGISTICS LTD., CHENNAI

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

211/- (Rs.8,05,21,425/- Rs.1,20,78,213/- ). Accordingly, we confirm the findings of the CIT(Appeals) on this issue and reject the ground taken by the Revenue. Therefore, the ground of appeal is dismissed. 11. The next issue raised by the Revenue in ITA No.1697/Mds/2014 is as under: “5.1 The ld. CIT(A) erred in deleting the disallowance

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

disallowed by invoking the provisions proviso to section 36(1)(iii) of the Act. The relevant findings of the Hon’ble High Court are as under:- 36 “9. He further contended that the Tribunal has also committed error in observing as under:- “18. We have heard the parties and perused the material available on record and also the orders

SHRIRAM INSIGHT SHARE BROKERS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.733, 734 & 735/Mds/2015 "नधा"रण वष" / Assessment Years : 2008-09, 2010-11 & 2011-12

disallow the claim of the assessee. The purchase of shares by the Shriram Insight Welfare Trust from the employees by using the funds advanced by the assessee- company is for the benefit of employees, therefore, it is allowable under Section 37 of the Act. 8. On the contrary, Shri Arun C. Bharat, the Ld. Departmental Representative, submitted that the assessee

SHRIRAM INSIGHT SHARE BROKERS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.733, 734 & 735/Mds/2015 "नधा"रण वष" / Assessment Years : 2008-09, 2010-11 & 2011-12

disallow the claim of the assessee. The purchase of shares by the Shriram Insight Welfare Trust from the employees by using the funds advanced by the assessee- company is for the benefit of employees, therefore, it is allowable under Section 37 of the Act. 8. On the contrary, Shri Arun C. Bharat, the Ld. Departmental Representative, submitted that the assessee

SHRIRAM INSIGHT SHARE BROKERS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita Nos.733, 734 & 735/Mds/2015 "नधा"रण वष" / Assessment Years : 2008-09, 2010-11 & 2011-12

disallow the claim of the assessee. The purchase of shares by the Shriram Insight Welfare Trust from the employees by using the funds advanced by the assessee- company is for the benefit of employees, therefore, it is allowable under Section 37 of the Act. 8. On the contrary, Shri Arun C. Bharat, the Ld. Departmental Representative, submitted that the assessee

DCIT, CHENNAI vs. EMERALD RESILIENT TYRE MANUFACTURES PVT LTD., CHENNAI

In the result, the Revenue appeal is allowed

Bench: Shri Chandra Poojari & Shri. G. Pavan Kumar

disallowed by revenue authorities by invoking provisions of section 43(5) - Held, yes Similarly, the Mumbai Bench of ITAT in the case of DCIT V. Intergold (I) Ltd., (124 TTJ 337)(Mum) has held that profits from cancellation of forward exchange contracts are business profits and not speculative profits. The relevant decision is as under: :- 6 -: Section 80HHC

THE INDIA CEMENTS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1) CHENNAI, CHENNAI

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

disallowed the provision for leave encashment, both while computing income under normal provisions as well as the book profit u/s 115JB of the Act. On appeal the Ld. CIT(A) confirmed the action of the AO. Being aggrieved the assessee is now in appeal before us. 8.1 The Ld. AR argued before us that, though in view of the decision

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

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

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance of Rs 49,63,29,426 aggrieved by which the assessee is in appeal before us. 73. We have heard the rival contentions, perused the material on record and duly considered facts of the case in the light of the applicable legal position. 74. We find that the issue in appeal is squarely covered by a coordinate bench decision