DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

disallowance was that in the prior assessment years no such payment was made. However, the undisputed fact is that the logo and the words 9 I.T.A. Nos.942-945 & 953/Chny/23 "Shriram Chits” is owned by M/s, Shriram Chits and Investments (Private) Limited. Assessee had used the logo and the above words while carrying on its business. ......... 27. We are in respectful agreement

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

disallowance was that in the prior assessment years no such payment was made. However, the undisputed fact is that the logo and the words 9 I.T.A. Nos.942-945 & 953/Chny/23 "Shriram Chits” is owned by M/s, Shriram Chits and Investments (Private) Limited. Assessee had used the logo and the above words while carrying on its business. ......... 27. We are in respectful agreement

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

disallowance was that in the prior assessment years no such payment was made. However, the undisputed fact is that the logo and the words 9 I.T.A. Nos.942-945 & 953/Chny/23 "Shriram Chits” is owned by M/s, Shriram Chits and Investments (Private) Limited. Assessee had used the logo and the above words while carrying on its business. ......... 27. We are in respectful agreement

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), CHENNAI, CHENNAI vs. SHRIRAM CHITS PRIVATE LIMITED, HYDERABAD

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.942, 943, 944, 945 & 953/Chny/2023 िनधा"रण वष"/Assessment Years: 2015-16, 2017-18, 2018-19 & 2020-21 The Deputy Commissioner Of Vs. Shriram Chits Private Limited, Income Tax, Central Circle 1(4), 3-6-478, Iii Floor, Anand Estates, Chennai -600 034. Opp. Indian Bank, Liberty Road, Himayat Nagar, Hyderabad 500 029. [Pan:Aafcs44916D] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri A. Sasi Kumar, Cit : ""थ" की ओर से/Respondent By Shri R. Sivaraman, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.01.2024 : घोषणा की तारीख /Date Of Pronouncement : 21.02.2024 आदेश /O R D E R Per V. Durga Rao: The Four Appeals In Ita Nos. 942 To 945/Chny/2023 Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 18, Chennai, Dated 28.06.2023 Relevant The Assessment Years 2015-16, 20-17-18, 2018-19 & 2020-21. The Common Grounds Raised In The Appeals Of The Revenue Are Reproduced As Under: 1. The Order Of The Ld. Commissioner Of I.T. (Appeals) Is Opposed To Law & Facts Of The Case.

disallowance was that in the prior assessment years no such payment was made. However, the undisputed fact is that the logo and the words 9 I.T.A. Nos.942-945 & 953/Chny/23 "Shriram Chits” is owned by M/s, Shriram Chits and Investments (Private) Limited. Assessee had used the logo and the above words while carrying on its business. ......... 27. We are in respectful agreement

JANET CHRISTINE DEPENNING,CHENNAI vs. ITO, INTERNATIONAL TAXATION WARD-1(1),, CHENNAI

In the result, the appeal of the Revenue is allowed for statistical purpose

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1319, 1320, 1321, 1322 & 1323/Chny/2024 िनधा<रण वष< /Assessment Years:2014-15, 2015-16, 2016-17, 2017-18 & 2020-21 Janet Christine Depenning, The Income Tax Officer, 120, Velachery Main Road, Vs. International Taxation Ward-1(1), Guindy,Chennai – 600 032. Chennai. [Pan: Aebpd 2408L]

XVII-B and such tax has not been deducted. Accordingly, the assessee cannot be faulted for not deducting TDS and consequently, the deletion of disallowance by CIT(A) is confirmed. This common issue of all the three appeals of revenue is dismissed.” 14. From the foregoing findings of the Tribunal, it is quite evident that the Tribunal had upheld

IDFC LIMITED,CHENNAI vs. JCIT-RANGE-II, CHENNAI

In the result, the appeal of the assessee in ITA No

36(1)(viia) (c)\nof the Act.\n2.2 The learned CIT(A) has erred in stating that deduction under section\n36(1)(via) of the Act is not applicable to Appellant, being Non-Banking\nFinancial Company, without appreciating the fact that the Appellant is a\nPublic Financial Institution under section 4A of the Companies Act,\n1956.\nAnd as noted, this

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

XVII of the IT Act. In the instant transaction made by the assessee for the F.Y.2007-08, the assessee failed to comply the provisions of section 194J and such failure attracts the consequential non-deductibility of the amounts as per section 40(a)(ia) of the IT Act. The payments mentioned supra have been made by the assessee M/s Royal Sundaram

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

XVII of the IT Act. In the instant transaction made by the assessee for the F.Y.2007-08, the assessee failed to comply the provisions of section 194J and such failure attracts the consequential non-deductibility of the amounts as per section 40(a)(ia) of the IT Act. The payments mentioned supra have been made by the assessee M/s Royal Sundaram

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

XVII of the IT Act. In the instant transaction made by the assessee for the F.Y.2007-08, the assessee failed to comply the provisions of section 194J and such failure attracts the consequential non-deductibility of the amounts as per section 40(a)(ia) of the IT Act. The payments mentioned supra have been made by the assessee M/s Royal Sundaram

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

XVII of the IT Act. In\nthe instant transaction made by the assessee for the F.Y.2007-08, the assessee\nfailed to comply the provisions of section 194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

36,544/-. Accordingly, this ground of appeal is allowed.” 3.7 We find that the above view of the Ld. CIT(A) is supported by the decision of this Tribunal in assessee’s own case for AY 2010-11 in ITA No. 361 & 482/Chny/2024 dated 25.09.2024 wherein it was held that the disallowance worked out under Section 14A read with Rule

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1(1), NUNGAMBAKKAM vs. IDFC LIMITED, TEYNAMPET

In the result, the appeal of the assessee in ITA No

36(1)(viia) (c)\nof the Act.\n2.2 The learned CIT(A) has erred in stating that deduction under section\n36(1)(via) of the Act is not applicable to Appellant, being Non-Banking\nFinancial Company, without appreciating the fact that the Appellant is a\nPublic Financial Institution under section 4A of the Companies Act,\n1956.\nAnd as noted, this