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

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, JUDICIAL MEMBER

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

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, JUDICIAL MEMBER

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

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, JUDICIAL MEMBER

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

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, JUDICIAL MEMBER

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, COIMBATORE vs. M/S. RP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

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

section 80IA of the Act. 44. The AO has referred to the percentage completion method being followed by the appellant and has cited as one of the reasons for the refusal to grant the impugned disallowance. This reasoning is untenable inasmuch as it is not the case of the AO that the appellant has not followed this method of account

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

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

section 80IA of the Act. 44. The AO has referred to the percentage completion method being followed by the appellant and has cited as one of the reasons for the refusal to grant the impugned disallowance. This reasoning is untenable inasmuch as it is not the case of the AO that the appellant has not followed this method of account

DCIT , COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED , ERODE

In the result, all these four appeals filed by the Revenue are\ndismissed

section 80IA of the Act.\n44. The AO has referred to the percentage completion method being\nfollowed by the appellant and has cited as one of the reasons for the\nrefusal to grant the impugned disallowance. This reasoning is\nuntenable inasmuch as it is not the case of the AO that the appellant\nhas not followed this method of account

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are\ndismissed

section 80IA of the Act.\n44. The AO has referred to the percentage completion method being\nfollowed by the appellant and has cited as one of the reasons for the\nrefusal to grant the impugned disallowance. This reasoning is\nuntenable inasmuch as it is not the case of the AO that the appellant\nhas not followed this method of account

ALBERT & CO. P. LTD.,CHENNAI vs. ITO CORPORATE WARD 6(1), CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

4 to 10 pertain to disallowance under Section 40(a)(ia). The connected grounds are taken up together hereinafter. Ground Nos.2 & 3: 9. The brief facts relevant for adjudication of the issue are that during the assessment proceedings the assessing officer noticed that while on one hand the Appellant has claimed deduction for interest expenses incurred on borrowed funds

ALBERT & CO. P. LTD.,CHENNAI vs. ITO CORPORATE WARD 6(1), CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

4 to 10 pertain to disallowance under Section 40(a)(ia). The connected grounds are taken up together hereinafter. Ground Nos.2 & 3: 9. The brief facts relevant for adjudication of the issue are that during the assessment proceedings the assessing officer noticed that while on one hand the Appellant has claimed deduction for interest expenses incurred on borrowed funds

ALBERT & CO. P LTD. ,CHENNAI vs. ITO CORPORATE WARD 6(1) , CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

4 to 10 pertain to disallowance under Section 40(a)(ia). The connected grounds are taken up together hereinafter. Ground Nos.2 & 3: 9. The brief facts relevant for adjudication of the issue are that during the assessment proceedings the assessing officer noticed that while on one hand the Appellant has claimed deduction for interest expenses incurred on borrowed funds

M/S.NLC INDCOSERVE,CUDDALORE vs. INCOME TAX OFFICER,WARD-2,, CUDDALORE

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

Bench: Shri Mahavir Singhand Shri Girish Agrawal

disallowing Rs.68,45,885/- being interest received from TAICO Bank claimed as deduction u/s 80P(2)(d) of the Act. 3. For that the Learned Commissioner of Income Tax (Appeals) erred in not considering the provisions of Section 80P(2)(a)vi) of the income Tax Act, 1961 which provides for deduction of the whole amount of profit and gains

DCIT, CHENNAI vs. KHIVRAJ AUTOMOBILES & INFRASTRUCTURE P LTD., CHENNAI

In the result, the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1176, 1177 & 1178/Mds/2015 "नधा+रण वष+ /Assessment Years: 2008-09, 2010-11 & 2011-12

D E R PER D.S.SUNDER SINGH, ACCOUNTANT MEMBER: This is an appeal filed by the Revenue against the Orders of Commissioner of Income Tax (Appeals)-, Chennai, in ITA No.724 /CIT(A)- 2013-14 fror the AY 2008 –09 and708/2013-14 & 170/2014-15 for the A.Y.210-11 and 2011-12. Since the common issues are involved in all the ITA Nos.1176 to 1178/Mds/2016

DCIT, CHENNAI vs. K.A.INFRASTRUCTURE P LTD., CHENNAI

In the result, the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1176, 1177 & 1178/Mds/2015 "नधा+रण वष+ /Assessment Years: 2008-09, 2010-11 & 2011-12

D E R PER D.S.SUNDER SINGH, ACCOUNTANT MEMBER: This is an appeal filed by the Revenue against the Orders of Commissioner of Income Tax (Appeals)-, Chennai, in ITA No.724 /CIT(A)- 2013-14 fror the AY 2008 –09 and708/2013-14 & 170/2014-15 for the A.Y.210-11 and 2011-12. Since the common issues are involved in all the ITA Nos.1176 to 1178/Mds/2016

DCIT, CHENNAI vs. KHIVRAJ AUTOMOBILES & INFRASTRUCTURE P LTD., CHENNAI

In the result, the appeals of the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.1176, 1177 & 1178/Mds/2015 "नधा+रण वष+ /Assessment Years: 2008-09, 2010-11 & 2011-12

D E R PER D.S.SUNDER SINGH, ACCOUNTANT MEMBER: This is an appeal filed by the Revenue against the Orders of Commissioner of Income Tax (Appeals)-, Chennai, in ITA No.724 /CIT(A)- 2013-14 fror the AY 2008 –09 and708/2013-14 & 170/2014-15 for the A.Y.210-11 and 2011-12. Since the common issues are involved in all the ITA Nos.1176 to 1178/Mds/2016

THE IKKARAIBOLUVAMPATTI PACCS 33,COIMBATORE vs. ITO,NCW 4(2), COIMBATORE

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.461/Chny/2021 िनधा"रण वष" /Assessment Year: 2017-18 M/S.Ikkaraiboluvampatti Paccs, V. The Income Tax Officer, 33, Rajaji Street, Non-Corporate Ward-4(2), Coimbatore. Coimbatore. [Pan: Aaaai 3699 A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.J.Saravanan, Adv. ""यथ" क" ओर से /Respondent By : Mr.P.Sajit Kumar, Jcit सुनवाई क" तारीख/Date Of Hearing : 19.10.2022 घोषणा क" तारीख /Date Of Pronouncement : 02.11.2022

disallowing the deduction under section 80P(2)(a) / 80P(2)(d) is confirmed. Thus, all grounds of Appeal stand dismissed. 4. The Ld.AR

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued