ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

6) of the Act do not affect this claim as the goodwill arises for the first time post-amalgamation. The Tribunal also dismissed the grounds related to Section 14A disallowance and transfer pricing issues.", "result": "Allowed", "sections": [ "Sec 14A", "Sec 92CA(3)", "Sec 92C(3)", "Sec 43

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

section 143(3) of the I.T.Act. Based on the reliance placed\nby the Appellant on the above judicial precedents in Appellant's own case, по\nadjustment in respect of the subject issue has been made to the total income\nof the Appellant for the AY 2011-12.\n\n3.3.6 I have carefully considered the facts of the case

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

section 143(3) of the I.T.Act. Based on the reliance placed\nby the Appellant on the above judicial precedents in Appellant's own case, по\nadjustment in respect of the subject issue has been made to the total income\nof the Appellant for the AY 2011-12.\n\n3.3.6 I have carefully considered the facts of the case

M/S ENRIA ENTERPRISES PVT. LTD,CHENNAI vs. DCIT. CENTRAL CIRCLE - 3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

6 March, 2022 passed by Respondent No.1 under Section 270AA (4) of the Act is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 7. This Court is of the opinion that the only addition in the assessment order framed by Respondent No.1 is in respect of disallowance under section

M/S ENRICE ENTERPRISES PVT. LTD,CHENNAI vs. DCIT,CENTRAL CIRCLE-3(4), CHENNAI

In the result, appeal filed by the assessee in ITA

Bench: Shri Manjunatha. G & Shri Manomohan Das

6 March, 2022 passed by Respondent No.1 under Section 270AA (4) of the Act is set aside and Respondent No.1 is directed to grant immunity under Section 270AA of the Act to the Petitioner.” 7. This Court is of the opinion that the only addition in the assessment order framed by Respondent No.1 is in respect of disallowance under section

ACIT CORPORATE CIRCLE-6(2), CHENNAI vs. M/S SUN EDISON SOLAR POWER INDIA PVT LTD, CHENNAI

In the result, the appeals filed by the assessee for the assessment years 2013-14, 2014-15 and 2015-16 are allowed and the appeal filed by the Revenue for the assessment year 2015-16 is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation on such ‘goodwill’ recorded just for balancing purpose in the books of accounts cannot be allowed as deduction u/s 32 of IT Act for computing taxable income. In respect of appeal filed

M/S SUN EDISON SOLAR POWER INDIA PVT LTD,CHENNAI vs. ITO, CORPORATE WARD - 6 (3),, CHENNAI

In the result, the appeals filed by the assessee for the assessment years 2013-14, 2014-15 and 2015-16 are allowed and the appeal filed by the Revenue for the assessment year 2015-16 is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation on such ‘goodwill’ recorded just for balancing purpose in the books of accounts cannot be allowed as deduction u/s 32 of IT Act for computing taxable income. In respect of appeal filed

M/S SUN EDISON SOLAR POWER INDIA PVT LTD,CHENNAI vs. DCIT CORPORATE CIRCLE 6 (2), CHENNAI

In the result, the appeals filed by the assessee for the assessment years 2013-14, 2014-15 and 2015-16 are allowed and the appeal filed by the Revenue for the assessment year 2015-16 is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation on such ‘goodwill’ recorded just for balancing purpose in the books of accounts cannot be allowed as deduction u/s 32 of IT Act for computing taxable income. In respect of appeal filed

M/S. SUN EDITION SOLAR POWER INDIA PVT. LTD.,,CHENNAI vs. DCIT, CORPORATE CIRCLE - 6 (2),, CHENNAI

In the result, the appeals filed by the assessee for the assessment years 2013-14, 2014-15 and 2015-16 are allowed and the appeal filed by the Revenue for the assessment year 2015-16 is dismissed

Bench: Shri V. Durga Rao & Shri G. Manjunatha

section 43(1) & Explanation 2B to Sec 43(6)(c), I concur with the finding of the Addl. CIT that the claim of depreciation on such ‘goodwill’ recorded just for balancing purpose in the books of accounts cannot be allowed as deduction u/s 32 of IT Act for computing taxable income. In respect of appeal filed

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. M/S CHOLAMANDALAM INVESTMENT & FINANCE COMPANY LTD, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

6,27,10,303/- treating as 'speculative' in nature: 1.1 On the facts and circumstances of the case, and in law, the Hon'ble CIT(A) and the learned AO has erred in disallowing a sum of INR 6.27,10,303 treating as 'speculative' in nature as laid down under section 43

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED, CHENNAI

In the result, the appeal of the Revenue is partly allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Ble

6,27,10,303/- treating as 'speculative' in nature: 1.1 On the facts and circumstances of the case, and in law, the Hon'ble CIT(A) and the learned AO has erred in disallowing a sum of INR 6.27,10,303 treating as 'speculative' in nature as laid down under section 43

CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED,CHENNAI, TAMIL NADU vs. DEPUTY COMMISSIONER OF INCOME-TAX (DCIT), CHENNAI-1, CHENNAI, TAMIL NADU

In the result, the appeal of the Revenue is partly allowed

sections": [ "43(5) of the Income-tax Act, 1961" ], "issues": "Whether the disallowance of foreign exchange loss of Rs. 6

CHOLAMANDALAM INVESTMENT AND FIANANCE CO. LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

6,27,10,303/-\ntreating as 'speculative' in nature:\n1.1 On the facts and circumstances of the case, and in law, the Hon'ble\nCIT(A) and the learned AO has erred in disallowing a sum of\nINR 6.27,10,303 treating as 'speculative' in nature as laid down under\nsection 43(5) of the Act.\n1.2 On the facts

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)

disallowance and the ld. CIT(A) to confirm the same. 40. The Bangalore Benches of the Tribunal in the case of M/s. Mahindra Electric Mobility Ltd. v. ACIT in ITA No.641/Bang/2017 vide order dated 14.09.2018 had held that prior to 01.07.2016 Form No.3CL has no legal sanctity and it is only w.e.f. 01.07.2016 with the amendment to Rule 6

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, 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)

disallowance and the ld. CIT(A) to confirm the same. 40. The Bangalore Benches of the Tribunal in the case of M/s. Mahindra Electric Mobility Ltd. v. ACIT in ITA No.641/Bang/2017 vide order dated 14.09.2018 had held that prior to 01.07.2016 Form No.3CL has no legal sanctity and it is only w.e.f. 01.07.2016 with the amendment to Rule 6

ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI vs. M/S CHOLAMANDALAM INVESTMENT AND FINANCE COMPANY LIMITED, CHENNAI

In the result, the appeal of the Revenue is partly allowed

6,27,10,303/-\ntreating as 'speculative' in nature:\n1.1 On the facts and circumstances of the case, and in law, the Hon'ble\nCIT(A) and the learned AO has erred in disallowing a sum of\nINR 6.27,10,303 treating as 'speculative' in nature as laid down under\nsection 43(5) of the Act.\n1.2 On the facts

HAMEED MARINE PRIVATE LIMITED,EDALAKUDY, NAGERCOIL vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, NAGERCOIL, INCOME TAX OFFICE, NAGERCOIL

In the result, Grounds relating to validity of notice u/s 143(2) are dismissed

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

6. We have carefully considered the rival submissions, perused the material placed on record and the orders of the lower authorities. The core issue for adjudication is whether depreciation claimed by the assessee on second-hand machinery amounting to Rs.31,41,044/- was rightly disallowed by invoking Explanation 3 to Section 43

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 80-IA(8) of the Act. According to us, the sale price cannot further be segregated by imputing price attributable to marketing and R&D efforts for the simple reason that there is no such provision contained in law. We agree with the Ld. AR that, the method of computation to be adopted by the assessee, in line with