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

section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

Section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income earned

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income earned

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

Section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income earned

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

section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income earned

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

section 14A of the Act read\nwith Rule 8D shall be made where there is no exempt income earned\nduring the year.\n7. We have heard both the parties and perused the records. We\nnote that it is now a settled principle that the disallowance u/s.14A\nof the Act shall not be made where there is no exempt income earned

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)

section 14A of the Act read with Rule 8D shall be made where there is no exempt income earned during the year. 7. We have heard both the parties and perused the records. We note that it is now a settled principle that the disallowance u/s.14A of the Act shall not be made where there is no exempt income earned

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)

section 14A of the Act read with Rule 8D shall be made where there is no exempt income earned during the year. 7. We have heard both the parties and perused the records. We note that it is now a settled principle that the disallowance u/s.14A of the Act shall not be made where there is no exempt income earned

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)

250 of the Income Tax Act, 1961 [hereinafter called ‘the Act’] (All the orders are dated 10.10.2024). The IT(TP)A Nos.105 to 107/Chny/2024 & ITA No. 3113 & 3251/Chny/24 relevant assessment years are 2011-12, 2012-13, 2013-14 and 2014-15. The Revenue has also preferred cross appeal for the assessment year 2012-13 (ITA No. 3251/Chny/2024). 2. Common issues

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)

250 of the Income Tax Act, 1961 [hereinafter called ‘the Act’] (All the orders are dated 10.10.2024). The IT(TP)A Nos.105 to 107/Chny/2024 & ITA No. 3113 & 3251/Chny/24 relevant assessment years are 2011-12, 2012-13, 2013-14 and 2014-15. The Revenue has also preferred cross appeal for the assessment year 2012-13 (ITA No. 3251/Chny/2024). 2. Common issues

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 8 1 (INCHARGE), HYDERABAD vs. VIRTUSA CONSULTING SERVICES PRIVATE LIMITED, TAMIL NADU

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

section 250 of the Income-tax Act, 1961 (‘the Act’) is not in accordance with the law, contrary to the facts and circumstances of the case. Disallowance

VIRTUSA CONSULTING SERVICES PVT. LTD.,CHENNAI vs. DCIT, CC-5(2), CHENNAI

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

section 250 of the Income-tax Act, 1961 (‘the Act’) is not in accordance with the law, contrary to the facts and circumstances of the case. Disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, HYDERABAD vs. VIRTUSA CONSULTING SERVICES PRIVATE LIMITED, CHENNAI TAMIL NADU

In the result, the ground of appeal in Ground No 2-4 in IT(TP)A No

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathait (Tp) A No.:42/Chny/2024 & आयकर अपील सं./ Ita No.2262/Chny/2024 "नधा%रण वष% / Assessment Year: 2013-14 & 2012-13

section 250 of the Income-tax Act, 1961 (‘the Act’) is not in accordance with the law, contrary to the facts and circumstances of the case. Disallowance

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

disallowance made by the Assessing Officer in view of the provisions of section 14A of the Act read with Rule 8D was completely contrary to the provisions of that section as Rule 8D only provides for a method to determine the amount of expenditure incurred in relation to income, which does not form part of total income of the assessee

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

disallowance made by the Assessing Officer in view of the provisions of section 14A of the Act read with Rule 8D was completely contrary to the provisions of that section as Rule 8D only provides for a method to determine the amount of expenditure incurred in relation to income, which does not form part of total income of the assessee

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

disallowance made by the Assessing Officer in view of the provisions of section 14A of the Act read with Rule 8D was completely contrary to the provisions of that section as Rule 8D only provides for a method to determine the amount of expenditure incurred in relation to income, which does not form part of total income of the assessee

M/S DHARANI DEVELOPERS PRIVATE LIMITED,ALWARPET, CHENNAI vs. ACIT, COMPANY CIRCLE 1(4), NUNGAMBAKKAM CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

disallowance made by the Assessing Officer in view of the provisions of section 14A of the Act read with Rule 8D was completely contrary to the provisions of that section as Rule 8D only provides for a method to determine the amount of expenditure incurred in relation to income, which does not form part of total income of the assessee