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)

234, Dare House, NSC Large Taxpayer Unit -1, Bose Road, Parrys Corner, Chennai. Chennai 600 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri R. Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent by : Shri A. Sasikumar, CIT सुनवाई क" तारीख/Date of Hearing : 20.03.2025 घोषणा क" तारीख/Date of Pronouncement : 21.04.2025 आदेश

JCIT (OSD) LTU 2 , CHENNAI vs. TI FINANCIAL HOLDINGS LIMITED, CHENNAI

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.1974/Chny/2019 िनधा"रण वष"/Assessment Year:2015-16 The Joint Commissioner Of M/S. Ti Financial Holdings Limited, Income Tax (Osd), Vs. Date House, No. 234, Large Taxpayer Unit – 2, Room No. Nsc Bose Road, 711, 7Th Floor, Wanaparthy Block, No. Chennai 600 001. 121, M.G. Road, Chennai 34. [Pan:Aaact1249H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. R. Anita, Jcit ""थ" की ओर से/Respondent By : Shri R. Vijayaraghavan, Advocate सुनवाई की तारीख/ Date Of Hearing : 21.10.2019 घोषणा की तारीख /Date Of Pronouncement : 01.11.2019 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) 9, Chennai Dated 21.03.2019 Relevant To The Assessment Year 2015-16. The Grounds Raised In The Appeal Of The Revenue Are That The Ld. Cit(A) Has Erred In Directing The Assessing Officer To Recomputed The Disallowance Under Section 14A To The Extent Of Investments Which Yield Exempt Income During The Year Under Consideration & The Ld. Cit(A) Has Erred In Holding That The 2

234, Large Taxpayer Unit – 2, Room No. NSC Bose Road, 711, 7th Floor, Wanaparthy Block, No. Chennai 600 001. 121, M.G. Road, Chennai 34. [PAN:AAACT1249H] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant by : Ms. R. Anita, JCIT ""थ" की ओर से/Respondent by : Shri R. Vijayaraghavan, Advocate सुनवाई की तारीख/ Date of hearing : 21.10.2019 घोषणा की तारीख

M/S. ALAGUMALAI IMPEX PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section 10A and 10B of the act including interest income under income from other sources by rejecting the netting of interest received against interest paid and disallowing ₹.6,39,234

ALAGUMALAI IMPEX PVT LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section 10A and 10B of the act including interest income under income from other sources by rejecting the netting of interest received against interest paid and disallowing ₹.6,39,234

DCIT, CHENNAI vs. ALAGUMALAI IMPEX P. LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed and the appeals filed by the assessee for both the assessment years are allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

section 10A and 10B of the act including interest income under income from other sources by rejecting the netting of interest received against interest paid and disallowing ₹.6,39,234

SOUTHERN PETROCHEMICAL INDUSTRIES CORPORATION LTD.,CHENNAI vs. ITO, CHENNAI

Appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.84/Chny/2023 (िनधा)रण वष) / Assessment Year: 2008-09) M/S. Southern Petrochemical Income Tax Officer बनाम Industries Corporation Limited Corporate Ward-3(1) 88, Spic House, Mount Road, Guindy, Chennai-600 034. / Vs. Chennai-600 032. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-4668-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan & Shri Saroj Kumar Parida (Advocates)-Ld. Ars " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) & Shri Ar V Sreenivasan (Addl. Cit)-Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 16-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 10-01-2024 आदेश / O R D E R

section 14A for Rs.5,31,94,788/-. 2.2 The CIT(A) / NFAC ought to have appreciated that the appellant had sufficient own funds to make the investments and hence the NFAC erred in disallowing Rs.4,91,44,803/- under rule 8D(2)(ii). 2.3 The Appellant and relies on the following among other decisions further submission that no disallowance

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 ()

disallowance of Rs.3,78,538/- on account of late fee on TDS payments u/s 234E of the Act. Section 234E of the Income Tax Act reads as under:- Fee for default in furnishing statements - (1) Without prejudice to the provisions of the Act, where a person fails to deliver or cause to be delivered a statement within the time prescribed

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

Section 40(a)(ia) of the Act or not? The Assessing Officer will accordingly allow the claim after verifying the same. Thus, this common issue in all these years is allowed partly as indicated above. 7. The next common issue in all these five appeals of the Assessee is as regards to the order of the Commissioner of Income

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

Section 40(a)(ia) of the Act or not? The Assessing Officer will accordingly allow the claim after verifying the same. Thus, this common issue in all these years is allowed partly as indicated above. 7. The next common issue in all these five appeals of the Assessee is as regards to the order of the Commissioner of Income

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

Section 40(a)(ia) of the Act or not? The Assessing Officer will accordingly allow the claim after verifying the same. Thus, this common issue in all these years is allowed partly as indicated above. 7. The next common issue in all these five appeals of the Assessee is as regards to the order of the Commissioner of Income

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

Section 40(a)(ia) of the Act or not? The Assessing Officer will accordingly allow the claim after verifying the same. Thus, this common issue in all these years is allowed partly as indicated above. 7. The next common issue in all these five appeals of the Assessee is as regards to the order of the Commissioner of Income

SELVA GANESH CONSTRUCTIONS PVT LTD,CHENNAI vs. ITO CORPORATE WARD-6(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A Nos.:1654 To 1658/Chny/2019 Assessment Years : 2012-13, 2013-14, 2014-15, 2015-16 & 2016-17

Section 40(a)(ia) of the Act or not? The Assessing Officer will accordingly allow the claim after verifying the same. Thus, this common issue in all these years is allowed partly as indicated above. 7. The next common issue in all these five appeals of the Assessee is as regards to the order of the Commissioner of Income

SHRIRAM TRANSPORT FINANCE COMPANY LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(1), CHENNAI

In the result, the appeal filed by the assessee in ITA No

Bench: Shri Inturi Rama Rao & Shri Duvvuru Rl Reddy]

234/- and disallowance of statutory reverse of "405,22,21,842/-. Aggrieved by the assessment order, assessee filed appeal before ld. CIT(A). The addition were further contested before the Tribunal on the issue of disallowance u/s.14A r.w.r. 8D. The Tribunal in its order dated 01.05.2017 in ITA No.2407 /Mds/2016 restored the issue to the file of the Assessing Officer

DCIT, CHENNAI vs. THIRUVALLUVAR TEXTILES PRIVATE LIMITED, NAMAKKAL

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

234/-. Thus, total disallowance was computed at ₹3,42,77,243/-. On appeal, the Ld.CIT(A) is noted to have ITA Nos.2110 & 2111/Chny/2025 (AYs 2013-14 & 2014-15) Thiruvalluvar Textiles Pvt. Ltd. :: 5 :: deleted the disallowance made for both the assessment years mainly taking note that the assessee didn’t earn any exempt income and therefore, no disallowance wasn

DCIT, CHENNAI vs. THIRUVALLUVAR TEXTILES PRIVATE LIMITED, NAMAKKAL

In the result, appeals filed by the Revenue are dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

234/-. Thus, total disallowance was computed at ₹3,42,77,243/-. On appeal, the Ld.CIT(A) is noted to have ITA Nos.2110 & 2111/Chny/2025 (AYs 2013-14 & 2014-15) Thiruvalluvar Textiles Pvt. Ltd. :: 5 :: deleted the disallowance made for both the assessment years mainly taking note that the assessee didn’t earn any exempt income and therefore, no disallowance wasn

DCIT, NON-CORPORATE CIRCLE - 2 (1),, CHENNAI vs. M/S. SHRIRAM INVESTMENTS,, CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकर अपील सं./I.T.A.No.2232/Chny/2019 ("नधा"रणवष" / Assessment Year: 2015-16)

section 36(l)(iii) of the Act. 3. The CIT(A) failed to appreciate that the test of commercial expediency as laid down in the case of M/s S A Builders (288 ITR 1) by the Hon’ble Supreme Court has not been satisfied by the assessee in the present case. 4. The CIT(A) has completely overlooked that

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

Disallowance u/s.40A(3) of Rs.5,41,05,184/-;\niii. Unaccounted cash receipts of Rs.16,18,61,715/-; and\niv. Inflated expenses of Rs.16,92,44,747/- (Based on the seized material,\nthe AO discussed in the assessment order that this addition pertained to\nA.Y.2015-16. However, in the computation section of the assessment\norder, the AO inadvertently made the addition

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, MADURAI, MADURAI vs. TRANSWORLD GARNET INDIA PVT LTD.,, CHENNAI

In the result, all the five appeals of the Revenue are dismissed

section of the assessment\norder, the AO inadvertently made the addition in A.Y. 2016-17. This error\nwas subsequently rectified by the Id.CIT(A), who correctly directed the\naddition to A.Y. 2015-16 and accordingly deleted the addition for\nΑ.Υ.2015-16).\n17. Aggrieved of the above additions, assessee carried the matter before the\nId.CIT(A) who vide order

ACIT, COIMBATORE vs. RASI ASSETS CORPORATION, COIMBATORE

In the result, the ground raised in assessee’s cross-objection stand allowed

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Section 53A of the Transfer of Property Act. In this connection, useful reference may be made to the decision of the Apex Court in the case of Alapati Venkataramiah v. CIT reported in 57 ITR 185 and the Special Bench decision of the Chennai Tribunal in the case of C. Vedachala Mudaliar v. ITO [1992] 198 ITR (AT) 18]. Hence