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)

35,900/- to be made to the income of the assessee and in conformity with the order passed by the TPO, in the assessment order under section 144C(3) r.w.s. 92CA of the Act dated 29.05.2015, the Assessing Officer disallowed

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

Section 14A read with Rule 8D to 1% of the average investments which have actually yielded exempt income during the year. From such an amount, ₹1,35,650/- disallowed by the assessee in their return should be reduced. If the disallowance computed as above at 1% of IT(TP)A Nos.2, 3

VIRUDHUNAGAR CENTRAL DISTRICT CO-OPERATIVE BANK,VIRUDHUNAGAR vs. ITO, VIRUDHUNAGAR

In the result, the appeals of the assessee for both the years are

Bench: Shri N.R.S. Ganesan, Shri Abraham P. George & Shri A.Mohan Alankamony] आयकर अपील सं./I.T.A. Nos.2055 & 2056/Chny/2014 "नधा"रण वष" /Assessment Years :2012-13 & 2013-2014. The Virudhunagar District Vs. The Income Tax Officer, Central Co-Operative Bank Ltd, Tds Ward, 104/1, Madurai Road, Virudhungar. Virudhunagar 626 001. [Pan Aaaau 0147N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 40(a)(ia) and disallowed the corresponding expenditure with the finding that the assessee was liable to deduct tax in view of specific clause (viia) of 194A(3). This stand has been upheld by Hon‟ble ITAT with following observations: ITA Nos.2055 & 2056/2014. :- 34 -: a) The AO categorically brought out material on record to prove that the assesse bank

VIRUDHUNAGAR CENTRAL DISTRICT CO-OPERATIVE BANK,VIRUDHUNAGAR vs. ITO, VIRUDHUNAGAR

In the result, the appeals of the assessee for both the years are

Bench: Shri N.R.S. Ganesan, Shri Abraham P. George & Shri A.Mohan Alankamony] आयकर अपील सं./I.T.A. Nos.2055 & 2056/Chny/2014 "नधा"रण वष" /Assessment Years :2012-13 & 2013-2014. The Virudhunagar District Vs. The Income Tax Officer, Central Co-Operative Bank Ltd, Tds Ward, 104/1, Madurai Road, Virudhungar. Virudhunagar 626 001. [Pan Aaaau 0147N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 40(a)(ia) and disallowed the corresponding expenditure with the finding that the assessee was liable to deduct tax in view of specific clause (viia) of 194A(3). This stand has been upheld by Hon‟ble ITAT with following observations: ITA Nos.2055 & 2056/2014. :- 34 -: a) The AO categorically brought out material on record to prove that the assesse bank

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

disallowance of the deduction u/s 80IA(4)(iv) of the Act. 21. In this regard, the ld.CIT(A) drew strong support from the judgment of the Hon’ble Madras High Courtin the case of CIT v. Heartland KG Information Ltd [2013] 39 taxmann.com 132 (Madras), wherein the Hon’ble High Court held while interpreting the analogous provision

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

disallowance of claim of weighted deduction should be deleted and also relied on the decision of the Coordinate Benches of the Tribunal in the case of Ashok Leyland in ITA No.362/Chny/2024 dated 25.09.2024. 10.4 On the other hand, the ld. DR has argued that by conjointly reading the provisions of section 35(2AB)(1) and section 35(3

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

disallowance of claim of weighted deduction should be deleted and also relied on the decision of the Coordinate Benches of the Tribunal in the case of Ashok Leyland in ITA No.362/Chny/2024 dated 25.09.2024. 10.4 On the other hand, the ld. DR has argued that by conjointly reading the provisions of section 35(2AB)(1) and section 35(3

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

disallowance of claim of weighted deduction should be deleted and also relied on the decision of the Coordinate Benches of the Tribunal in the case of Ashok Leyland in ITA No.362/Chny/2024 dated 25.09.2024. 10.4 On the other hand, the ld. DR has argued that by conjointly reading the provisions of section 35(2AB)(1) and section 35(3

CLASSIC LINENS INTERNATIONAL PVT. LTD.,,CHENNAI vs. ACIT (OSD), COMPANY RANGE-I,, CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.3341/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 M/S. Classic Linens International Pvt. The Assistant Commissioner Of Ltd., Unit 13 & 14, Sdf, Ii Phase Vs. Income Tax, Osd, Company Range-I, Mepz, Tambaram, Chennai 600 045. Nungambakkam High Road, Chennai 600 034. [Pan: Aabcc3510F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Raghunathan & Shri S. Sankar Narayanan, Advocates ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 09.11.2021 घोषणा की तारीख /Date Of Pronouncement : 23.11.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 4, Chennai, Dated 30.09.2019 Relevant To The Assessment Year 2014-15. The Effective Ground Raised In The Appeal Of The Assessee Relates To Confirmation Of Disallowance Of Deduction Of ₹.52,61,428/- Claimed Under Section 10Aa Of The Income Tax Act, 1961 [“Act” In Short].

disallowed for impugned ay: 2011-12. However, it is matter of record that learned CIT(A) was pleased to allow benefit of deduction u/s 10AA to the assessee for immediately succeeding ay’s: 2012-13 and 2013-14 while adjudicating first appeal of the assessee. This is purely a legal issue which requires interpretation of law applied to as facts

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:1872, 1873, 1875, 1877 & 1878/Chny/2025 निर्धारण वर्ष / Assessment Years: 2013-14, 2014-15, 2015-16, 2016-17 & 2017-18 Acit, Central Circle -2, Madurai. Vs. Transworld Garnet India Pvt. Ltd., 500, Pantheaon Road, Egmore S.O., Chennai - 600 008. [Pan: Aaact-3408-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. R.Venkata Raman, C.A. प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, C.I.T. सुनवाई की तारीख /Date Of Hearing : 24.09.2025 घोषणा की तारीख/Date Of Pronouncement : 23.10.2025 आदेश /Order Per S. R. Raghunatha, Am : These Five Appeals Preferred By The Revenue Are Directed Against The Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-19, Chennai [Hereinafter Referred To As “The Id.Cit(A)”]. The Impugned Orders Of The Id.Cit(A) Arise Out Of The Assessment Orders Framed By The Assistant Commissioner Of Income Tax, Central Circle-2, Madurai [Hereinafter Referred To As “The Ao”], In Respect Of The Assessment Years 2013-14 To 2017-18. The Particulars Of The Respective Appeals Filed By The Revenue Are Set Out Hereinbelow:- S. No

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

CLASSIC LINEN INTERNATIONAL PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, the appeal filed by assessee in iTA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा$रण वष$ /Assessment Year: 2011-12

section 32, the written down value of any asset used for the purposes of the business of the undertaking shall be computed as if the assessee had claimed and been actually allowed the deduction in respect of depreciation for each of the relevant assessment year. (7) The provisions of sub-section (8) and sub-section (10) of section

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

section 40A(3) of the Act. Since the findings recorded by the Id. CIT(A) has not been controverted by the Id. D.R. by bringing any positive material on record, we do not find any reason to interfere with the order of Id. CIT(A) deleting the disallowance made u/s 40A(3) of the Act.” 83. Applying the ratio

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.2865, 2866, 2867 & 2868/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2010-11, 2014-15, 2016-17 & 2018-19) M/S. Carborundum Universal Vs The Assistant Commissioner Of Income-Tax, Limited, No. 43, Vi Floor, Parry House Moore Street,Chennai Gpo Parrys, – 600 001. Pan: Aaacc-2474-P (अपीलार्थी/Appellant) Large Taxpayer Unit-1, Chennai. (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/ Appellant By : Mr.R.Vijayaraghavan, Advocate प्रत्यर्थीकीओरसे/Respondent By : Mrs.Samantha Mullamudi, Addl.Cit सुनवाईकी तारीख/Date Of Hearing : 27.03.2025 घोषणाकीतारीख / Date Of Pronouncement : 05.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)]All Dated10.09.2024 For Assessment Years 2010-11, 2014-15, 2016-17 & 2018-19.Since The Facts & Issues Are Common In These Appeals, They Are Heard Together & Disposed Off By This Common Order.

disallowance of claim of weighted deduction should be deleted and also relied on the decision of the Coordinate Benches of the Tribunal in the case of Ashok Leyland in ITA No.362/Chny/2024 dated 25.09.2024. 10.4 On the other hand, the Id. DR has argued that by conjointly reading the provisions of section 35(2AB)(1) and section 35(3

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

disallowance that is restricted to monetary value of the benefit to the prohibited person(s), or it will lead to complete denial of the exemption claimed by the assessee u/s 11 and 12 of the Act. 10. In the appellant's case it is noticed that it is running educational institutions. During the AY s under consideration, it was noticed

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

disallowance that is restricted to monetary value of the benefit to the prohibited person(s), or it will lead to complete denial of the exemption claimed by the assessee u/s 11 and 12 of the Act. 10. In the appellant's case it is noticed that it is running educational institutions. During the AY s under consideration, it was noticed

M/S JAYA EDUCATIONAL TRUST,THIRUVALLUR vs. DCIT, CC1(2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

disallowance that is restricted to monetary value of the benefit to the prohibited person(s), or it will lead to complete denial of the exemption claimed by the assessee u/s 11 and 12 of the Act. 10. In the appellant's case it is noticed that it is running educational institutions. During the AY s under consideration, it was noticed

JAYA EDUCATIONAL TRUST,CHENNAI vs. DCIT CENTRL CIRCLE 1 (2), CHENNAI

In the result, appeals filed by the assessee for the assessment years 2012-13 & 2013-14 are allowed and for the assessment years

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 2915, 3114, 3115/Chny/2019 & 916/Chny/2020 िनधा"रण वष" / Assessment Years: 2016-17, 2012-13, 2013-14 & 2017-18

disallowance that is restricted to monetary value of the benefit to the prohibited person(s), or it will lead to complete denial of the exemption claimed by the assessee u/s 11 and 12 of the Act. 10. In the appellant's case it is noticed that it is running educational institutions. During the AY s under consideration, it was noticed

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

35) of the Act is disallowed under Section 14A of the Act and is added back to book profit under clause (f) of Section 115JB of the Act, the same would amount to doing violence with the statutory provision viz., Sub-Section (1) and (5) of Section 115JB of the Act. It is also pertinent to mention here that

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

35) of the Act is disallowed under Section 14A of the Act and is added back to book profit under clause (f) of Section 115JB of the Act, the same would amount to doing violence with the statutory provision viz., Sub-Section (1) and (5) of Section 115JB of the Act. It is also pertinent to mention here that