COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

6 to 10 (b) Payments towards license to use software (‘Software License’) Assessment Appeal by Ground Year No. AY 2010-11 Assessee (ITA No. 1193/CHNY/2024) 12 to 17 AY 2011-12 Assessee (ITA No. 1194/Chny/2024) 12 to 17 AY 2012-13 Assessee (ITA No. 1205/CHNY/2024) 11 to 16 8.1 During the AY 2010-11, the assessee had made payments

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

6 to 10 (b) Payments towards license to use software (‘Software License’) Assessment Appeal by Ground Year No. AY 2010-11 Assessee (ITA No. 1193/CHNY/2024) 12 to 17 AY 2011-12 Assessee (ITA No. 1194/Chny/2024) 12 to 17 AY 2012-13 Assessee (ITA No. 1205/CHNY/2024) 11 to 16 8.1 During the AY 2010-11, the assessee had made payments

SHRIRAM RETAIL HOLDINGS PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Section 14A read with Rule 8D and ld. Assessing Officer computed the disallowances and after adjustment of disallowance which the assessee company has already disallowed "51,220/- has worked out to "6

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

ACIT CORPORATE CIRCLE 1, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,MADURAI vs. ACIT CORPORATE CIRCLE 1, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. ACIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

ACIT, MADURAI vs. J.K.FENNER (INDIA) LIMITED, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

220 of 2017 dated 30.09.2020). Similar is the view of Hon’ble Delhi High Court in Joint Investments Private Ltd. V/s CIT (59 Taxmann.com 295) wherein it was held that where assessee declared tax exempt income and voluntarily disallowed certain expenditure under section 14A, in absence of reason why assessee's claim for disallowance under section

TAMILNADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeals in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

section he has disallowed the expense. 5. The CIT(A) erred in confirming the disallowance of Interest paid on Ways and Means Advance amounting to Rs. 37,80,822/- 5.1 The CIT(A) ought to have appreciated that the interest was payable on Ways and Means Advance of Rs. 50 crores received from the Government of Tamilnadu. The Government

TAMILNADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeals in ITA Nos

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

section he has disallowed the expense. 5. The CIT(A) erred in confirming the disallowance of Interest paid on Ways and Means Advance amounting to Rs. 37,80,822/- 5.1 The CIT(A) ought to have appreciated that the interest was payable on Ways and Means Advance of Rs. 50 crores received from the Government of Tamilnadu. The Government

ARUSUVAI FOOD PROCESSORS PVT. LTD.,SALEM vs. DCIT, CIRCLE-1(1), SALEM

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

220/- as deemed profits chargeable to tax under the head “Profits and Gains of Business or Profession, without giving any direction for levy of penalty u/s.270A of the Act. We find that the AO has not recorded his satisfaction/direction in the course of assessment proceedings or in the assessment order dated 31.03.2022 that he was satisfied that the assessee