DCIT, CHENNAI vs. EMERALD RESILIENT TYRE MANUFACTURES PVT LTD., CHENNAI

In the result, the Revenue appeal is allowed

Bench: Shri Chandra Poojari & Shri. G. Pavan Kumar

35A; or (iv) the amount of expenditure a/a capital nature referred to in clause (ix) ofsubsection (I) of section 36: or (v) the cost of acquisition of a capital asset (not being a capital asset referred to in section 50)for the pumposes of section 48, and the amount arrived at after such addition or deduction shall be takemz

ACIT, CHENNAI vs. NARMADA INFRASTRUCTURE CONSTRUCTION ENTERPRISES LIMITED, CHENNAI

In the result both appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

disallowance of "2,16,70,381/- was made for the foreign exchange loss on account of interest payment. Argument of the assessee, in its appeal before ld. CIT(A) is 4. that key condition of Sec. 43A of the Act was that loan taken should have been for acquiring a foreign asset. As per assessee it had not imported

ACIT, CHENNAI vs. NARMADA INFRASTRUCTURE CONSTRUCTION ENTERPRISES LIMITED, CHENNAI

In the result both appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George]

disallowance of "2,16,70,381/- was made for the foreign exchange loss on account of interest payment. Argument of the assessee, in its appeal before ld. CIT(A) is 4. that key condition of Sec. 43A of the Act was that loan taken should have been for acquiring a foreign asset. As per assessee it had not imported

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

In the result , the appeal filed by the Revenue is dismissed

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

35A; or (iv) the amount of expenditure of a capital nature referred to in clause (ix) of subsection (1) of section 36; or (v) the cost of acquisition of a capital asset (not being a capital asset referred to in section 50) for the purposes of section 48, and the amount arrived at after such addition or deduction shall

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

In the result , the appeal filed by the Revenue is dismissed

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

35A; or (iv) the amount of expenditure of a capital nature referred to in clause (ix) of subsection (1) of section 36; or (v) the cost of acquisition of a capital asset (not being a capital asset referred to in section 50) for the purposes of section 48, and the amount arrived at after such addition or deduction shall

SIVAKARTHICK RAMAN,MADURAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE MADURAI

In the result, the appeal of the assessee is allowed in terms of our above order

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:281/Chny/2025 िनधा"रण वष" / Assessment Year: 2022-23 Sivakarthick Raman, The Assistant Commissioner Of 5/200, 2Nd Street, Alagupillai Nagar, Vs. Income Tax, T.Pudukudi, International Taxation Circle, Achampathu, Madurai. Madurai – 625 019. [Pan: Ajnpr-3214-R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Appellant By : Ms. Preeti Goel, Advocate ""थ" की ओर से/Respondent By : Ms. Anitha, Addl. C.I.T. सुनवाई की तारीख/Date Of Hearing : 21.04.2025 घोषणा की तारीख/Date Of Pronouncement : 07.07.2025 आदेश /O R D E R Per S. R. Raghunatha, Am:

Section 90 of the Act:  The person should be a Resident of China; and  The salary and other remuneration should be earned in respect of employment exercised in China. 7. During the FY 2021-22, the assessee duly qualified as a Non-Resident of India and as a Tax Resident of China for the Calendar Year

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

disallowance under section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

disallowance under section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

disallowance under section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

disallowance under section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

disallowance under section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench