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

disallowance of provisions on account of IBNR and IBNER\nclaims charged to P & L account by holding it to be unascertained liability\nand not allowable under section 37(1) of the Act and added back to the\ntotal income under the normal provisions. It is noted that the Id. PCIT\nunder section 263

FAIVELEY TRANSPORT TECHNOLOGIES INDIA PVT. LTD.,HOSUR vs. ACIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

disallowance is not warranted. The assessee vide letters dated 5th, 21st January and 4th March, 2021 submitted details sought by the Department. Based on the enquiry and after ITA No.1598 /Chny/2024 considering the responses filed by the Appellant, the scrutiny assessment was concluded by passing an order section 143(3) read with section

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

disallowance of provisions on account of IBNR and IBNER\nclaims charged to P & L account by holding it to be unascertained liability\nand not allowable under section 37(1) of the Act and added back to the\ntotal income under the normal provisions. It is noted that the Id. PCIT\nunder section 263

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

disallowance of provisions on account of IBNR and IBNER\nclaims charged to P & L account by holding it to be unascertained liability\nand not allowable under section 37(1) of the Act and added back to the\ntotal income under the normal provisions. It is noted that the Id. PCIT\nunder section 263

SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-1, ERODE

263 or section 264 shall be made within\nthe time specified in sub-section (3).\"\nThe respectful submission of the Appellant is that even as per\nthe Order of this Hon'ble ITAT dated 15/02/2023, there is\nnothing in respect of any verification of any issue by way of\nsubmission of any document by the assessee or any other\nperson

VANAVIL ESTATE,CHENNAI vs. PCIT CENTRAL, CHENNAI

In the result, the appeal for both AYs 2017

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 263 of the Act cannot be exercised. In the decided case, the In the decided case, the assessee had originally filed the return of income disclosing long term lly filed the return of income disclosing long term lly filed the return of income disclosing long term capital gain and had claimed the entire sum as exempt

VANAVIL ESTATE,CHENNAI vs. PCIT(CENTRAL), CHENNAI

In the result, the appeal for both AYs 2017

Bench: Shri Aby T. Varkey & Shri Jagadishआयकरअपीलसं./Ita Nos.925 & 926/Chny/2024 िनधा"रणवष"/Assessment Years: 2017-18 & 2018-19 V. Vanavil Estate, The Pcit (Central), 4/20, Duraiswamy Reddy Street, Chennai-1. West Tambaram, Chennai-600 045. [Pan: Aalfv 0770 H] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 263 of the Act cannot be exercised. In the decided case, the In the decided case, the assessee had originally filed the return of income disclosing long term lly filed the return of income disclosing long term lly filed the return of income disclosing long term capital gain and had claimed the entire sum as exempt

SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-I,, ERODE

The appeal of the assessee is allowed for statistical\npurposes

263 or section 264 shall be made within\nthe time specified in sub-section (3).\"\nThe respectful submission of the Appellant is that even as per\nthe Order of this Hon'ble ITAT dated 15/02/2023, there is\nnothing in respect of any verification of any issue by way of\nsubmission of any document by the assessee or any other\nperson

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

disallowance of provisions on account of IBNR and IBNER\nclaims charged to P & L account by holding it to be unascertained liability\nand not allowable under section 37(1) of the Act and added back to the\ntotal income under the normal provisions. It is noted that the Id. PCIT\nunder section 263

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Section 263 of the Act are fulfilled in its letter\nand spirit.\n28. Notably, the ITAT, while making a categorical finding that the CIT had\nfailed to point out any definite or specific error in the assessment order, has\nsatisfactorily explained both the claims in question in Paragraph 8.2 of its\norder, which reads as under:-\n18\nITA Nos.1618

ST.JOSEPH'S INSTITUTE OF SCIENCE AND TECHNOLOGY TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

Section 263 of the Act are fulfilled in its letter and spirit. 28. Notably, the ITAT, while making a categorical finding that the CIT had failed to point out any definite or specific error in the assessment order, has satisfactorily explained both the claims in question in Paragraph 8.2 of its order, which reads as under:- “8.2 In the Impugned

ST.JOSEPH'S EDUCATIONAL TRUST,CHENNAI vs. PCIT CENTRAL CHENNAI - 1, CHENNAI

In the result, all the three appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Jagadishआयकरअपील सं./ Ita Nos.1618 & 1619 /Chny/2024 (िनधा"रणवष" / Assessment Years: 2018-19 & 2020-2021) St. Joseph’S Institute Of Science & Vs. The Principal Commissioner Of Income Technology Trust, Tax, No.56C, Old Mahabalipuram Road, Central, Chennai -1 Sholinganallur, Chennai 600 119. [Pan: Aahts 9943B] आयकरअपील सं./ Ita No.1620 /Chny/2024 (िनधा"रणवष" / Assessment Year: 2020-2021) St. Joseph’S Educational Trust, Vs The Principal Commissioner Of Income No.56C, Old Mahabalipuram Road, Tax, Sholinganallur, Chennai 600 119. Central, Chennai -1 [Pan: Aamts 3888G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri K.R. Vasudevan, Advocate ""यथ" क" ओर से /Respondent By : Shri Nilay Baran Som, Irs, Cit.

Section 263 of the Act are fulfilled in its letter and spirit. 28. Notably, the ITAT, while making a categorical finding that the CIT had failed to point out any definite or specific error in the assessment order, has satisfactorily explained both the claims in question in Paragraph 8.2 of its order, which reads as under:- “8.2 In the Impugned

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

263 of the Act, ie. the order of the Ld. AO shall be 'erroneous' and 'prejudicial to the interests of the revenue', are not satisfied. 2.2. The Id. CIT erred in concluding that the reassessment order passed under section 143(3) read with section 147 for the impugned AY is erroneous and prejudicial to the interests of the revenue, without

INDIA JAPAN LIGHTING PRIVATE LIMITED,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 4, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1427/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 V. M/S. India Japan Lighting Pvt. Ltd., The Pcit-4, No.1, Tiruvallur High Road, Chennai. Puduchatram B.O., Thirumazhisai, Tiruvallur-600 124. [Pan: Aaaci 2673 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallow the royalty payments to KMC, Japan being capital expenditure. However, appropriate depreciation is to be allowed in respect of this expenditure on account of royalty. 07. In view of the aforesaid discussion, the assessment order passed under section u/s 143(3) r.w.s. 144B dated 05.12.2022 by the Assessing Officer for the assessment year 2021-22 is considered

UCAL LIMITED,CHENNAI vs. PCIT, CHENNAI-3,, CHENNAI

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

Section 263 of the Act by the ld.PCIT was very much examined by the Assessing Officer during the course of assessment proceedings by way of issuance of notice u/s.142(1) of the Act and the reply filed by the assessee thereon inasmuch the assumption of jurisdiction u/s.263 of the Act on the facts of the present case would result

CT. RAMANATHAN (HUF),PUDUKKOTTAI vs. PCIT 1, MADURAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S.R. Raghunathaआयकर अपील सं./Ita No.761/Chny/2025 Assessment Years: 2020-21 C.T.Ramanathan(Huf), Income Tax Officer, No.7/45, Ct.Rm.S.House, M.St.S. Street Ward-1, Kulipirai, Pudukottai Dist, Pudukottai. Tamil Nadu-622 402. [Pan: Aaahc0701L] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.V.Subbarayan, Dcit(Retd.) प्रत्यर्थी की ओर से /Revenue By : Mr.M.K.Biju, Cir Dr By Virtual. सुनवाई की तारीख/Date Of Hearing : 03.06.2025 घोषणा की तारीख /Date Of Pronouncement : 25.06.2025 आदेश / O R D E R

Section 263 of the Act are fulfilled in its letter and spirit. 28. Notably, the ITAT, while making a categorical finding that the CIT had failed to point out any definite or specific error in the assessment order, has satisfactorily explained both the claims in question in Paragraph 8.2 of its order, which reads as under:- “8.2 In the Impugned

MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

disallow the claim\nof deduction under Section 80P of the Act to the tune of Rs.10,91,802/- forming\npart of the return of income filed in response to notice under Section 148 of the\nAct without assigning proper reasons and justification.\n9) The PCIT failed to appreciate that there was complete scrutiny of facts referred\nto in the revision

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

disallowance u/s.40(a)(i) should not be\nupheld by this Tribunal. The summary of the arguments of Ld.AR\nbefore us is as below:\n\n- The services rendered by the non-resident vendors would fall\nwithin the purview of the exclusionary clause provided in\nsection 9(1)(vi)(b) of the Act, as the payments made by the\nassessee

INTERNATIONAL SEAPORT DREDGING PRIVATE LIMITED,CHENNAI vs. PCIT - 1, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI MANU KUMAR GIRI (Judicial Member)

Section 263 of the Act are fulfilled in its letter and spirit. 28. Notably, the ITAT, while making a categorical finding that the CIT had failed to point out any definite or specific error in the assessment order, has satisfactorily explained both the claims in question in Paragraph 8.2 of its order, which reads as under:- ‘’8.2 In the Impugned