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

In the result, all the five appeals of the Revenue are dismissed

50 Taxman 213 (Allahabad), the Tribunal observed that the\nexpression 'may presume' appearing in section 132(4A) does convey the\nsame meaning as in section 4 of the Evidence Act and the expression gives\nlegal sanction for drawing such inferences as are possible but the discretion\nhas to be exercised in a judicious manner. It should not be stretched without

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

In the result, all the five appeals of the Revenue are dismissed

50 Taxman 213 (Allahabad), the Tribunal observed that the\nexpression 'may presume' appearing in section 132(4A) does convey the\nsame meaning as in section 4 of the Evidence Act and the expression gives\nlegal sanction for drawing such inferences as are possible but the discretion\nhas to be exercised in a judicious manner. It should not be stretched without

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

In the result, all the five appeals of the Revenue are dismissed

50 Taxman 213 (Allahabad), the Tribunal observed that the\nexpression 'may presume' appearing in section 132(4A) does convey the\nsame meaning as in section 4 of the Evidence Act and the expression gives\nlegal sanction for drawing such inferences as are possible but the discretion\nhas to be exercised in a judicious manner. It should not be stretched without

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

In the result, all the five appeals of the Revenue are dismissed

50 Taxman 213 (Allahabad), the Tribunal observed that the\nexpression 'may presume' appearing in section 132(4A) does convey the\nsame meaning as in section 4 of the Evidence Act and the expression gives\nlegal sanction for drawing such inferences as are possible but the discretion\nhas to be exercised in a judicious manner. It should not be stretched without

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

3,40,000/- per acre. It was also seen that the company has paid Rs. 14,70,655/- as cash to Sri K Srinivasan, While raising a specific question in this aspect Shri D. Kabilan, vide his sworn statement in answer 6 has stated that the amount of Rs.14.70.655/- is the difference between the actual sale consideration agreed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

3,40,000/- per acre. It was also seen that the company has paid Rs. 14,70,655/- as cash to Sri K Srinivasan, While raising a specific question in this aspect Shri D. Kabilan, vide his sworn statement in answer 6 has stated that the amount of Rs.14.70.655/- is the difference between the actual sale consideration agreed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

3,40,000/- per acre. It was also seen that the company has paid Rs. 14,70,655/- as cash to Sri K Srinivasan, While raising a specific question in this aspect Shri D. Kabilan, vide his sworn statement in answer 6 has stated that the amount of Rs.14.70.655/- is the difference between the actual sale consideration agreed

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

3,40,000/- per acre. It was also seen that the company has paid Rs. 14,70,655/- as cash to Sri K Srinivasan, While raising a specific question in this aspect Shri D. Kabilan, vide his sworn statement in answer 6 has stated that the amount of Rs.14.70.655/- is the difference between the actual sale consideration agreed

SIVAKARTHIKEYAN TRANSPORTS,KARUR vs. INCOME TAX OFFICER, WARD - 2 KARUR, KARUR

In the result the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey & Shri S.R. Raghunathaआयकर अपील सं./Ita No.970/Chny/2023 िनधा"रण वष" /Assessment Year: 2014-15 Sivakarthikeyan Transports, The Income Tax Officer, 23, Pasuapthypuram, Vs. Ward-2, Karur – 639001. Karur. Tamil Nadu. [Pan: Aaias 3396N] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" की ओर से/ Assessee By : Shri S. Sridhar, Advocate ""थ" की ओर से /Revenue By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/Date Of Hearing : 19.06.2024 घोषणा की तारीख /Date Of Pronouncement : 04.09.2024 आदेश / O R D E R Per S.R. Raghunatha, A.M : This Appeal By The Assessee Is Arising Out Of The Order Of The Commissioner Of Income Tax (Appeals), [Nfac], Delhi [Hereinafter “Cit(A)] In Din & Order No.Itba/Nfac/S/250/2023- 24/1054458891(1), Dated 19.07.2023. 2. The Grounds Of Appeal Raised By The Assessee Are As Under: (A) The Order Passed By The Learned Cit(A) Is Against The Probabilities & Evidence Of Facts Put Forth Before It & Also Contrary To Settled Principles With Regard To The Law On Taxation. :- 2 -:

50,000/-. The :- 3 -: assessee’s Case was selected for scrutiny under CASS and the assessment was concluded on 26/12/2016 by disallowing an expenditure of Hire charges of Rs.9,03,290/-, Repairs and maintenance of Rs.25,03,866/- and Over dimensional charges of Rs.3,08,761/-, altogether to the tune of Rs.37,15,915/- for the reason that these payments

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2150, 2151 & 2152/Chny/2018 िनधा"रण वष"/Assessment Years: 2010-11, 2011-12 & 2012-13 The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 16.04.2018 Relevant To The Assessment Years 2010-11, 2011-12 & 2012-13. 2. The Appeals Filed By The Revenue Are Delayed By Three Days, For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which The Ld. Counsel For The Assessee Has Not Raised Any Serious Objection.

disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed for all the assessment years under appeal. 10. With regard to the addition on brought notes ₹.3,00,000/-, in the assessment order for the assessment year 2011-12, the Assessing Officer has noted that during the search under section

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2150, 2151 & 2152/Chny/2018 िनधा"रण वष"/Assessment Years: 2010-11, 2011-12 & 2012-13 The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 16.04.2018 Relevant To The Assessment Years 2010-11, 2011-12 & 2012-13. 2. The Appeals Filed By The Revenue Are Delayed By Three Days, For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which The Ld. Counsel For The Assessee Has Not Raised Any Serious Objection.

disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed for all the assessment years under appeal. 10. With regard to the addition on brought notes ₹.3,00,000/-, in the assessment order for the assessment year 2011-12, the Assessing Officer has noted that during the search under section

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2150, 2151 & 2152/Chny/2018 िनधा"रण वष"/Assessment Years: 2010-11, 2011-12 & 2012-13 The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Three Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 16.04.2018 Relevant To The Assessment Years 2010-11, 2011-12 & 2012-13. 2. The Appeals Filed By The Revenue Are Delayed By Three Days, For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which The Ld. Counsel For The Assessee Has Not Raised Any Serious Objection.

disallowance made under section 40(a)(ia) of the Act and thus, the ground raised by the Revenue is dismissed for all the assessment years under appeal. 10. With regard to the addition on brought notes ₹.3,00,000/-, in the assessment order for the assessment year 2011-12, the Assessing Officer has noted that during the search under section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. AADHITYA FINCORP PVT LTD, CHENNAI

The appeal of the revenue is dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

section does not automatically negate the addition itself, as long as the underlying facts and evidence support the addition based on the correct legal provisions which would be unexplained investment u/s 69A of the Act. 3 For these grounds and any other ground including amendment of grounds that may be raised during the course of the appeal proceedings, the Order

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

3\n| AY 2011-12 | Department (ITA No. 1263/CHNY/2024)\n| 5\n| AY 2012-13 | Department (ITA No. 1264/CHNY/2024)\n| 5\n| AY 2013-14 | Department (ITA No. 1265/CHNY/2024)\n| 4\n| AY 2014-15 | Department (ITA No. 1266/CHNY/2024)\n| 4\n\n36. The facts relating to the issue of Disallowance under section\n14A read with rule 8D in computing

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 143(3) if proof of payment is furnished. Proof of payment of the amounts in time is furnished by way of Audit Report and pointing out of the mistakes made therein in respect of dates of payment of Employees' contribution. In view of the CBDT Circular, the AO is directed to give an opportunity to the Assessee to give

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

3. 6. 5. The relevant finding\nof Id.CIT(A) in para 3.6.5 reads as under:\n\n3.6.5 Further, the Appellant also placed reliance on a recent decision of the\nHonourable Chennai Income-tax Appellate Tribunal in the Appellant's own\ncase vide order dated 29.12.2023 in ITA No.160/Chny/2022 wherein the\nissue has been decided in favour of the Appellant

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

50,900/-, is in the nature of\nGoodwill and is eligible for tax depreciation on intangible assets.\n15. Adverting to the finding of the AO that the goodwill cannot be self-\ngenerated and that the claim of the assessee is on account of self-generated\ngoodwill is not correct. The AO has relied upon Explanation 7 to section

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)

section 32(1)(iia) of the Act amounting to ₹.2,58,45,663/- during the year at the rate of 10% (50% of 20%) in respect of second-half additions made to plant and machinery during the preceding assessment year 2011-12. However, by following the decision of the Tribunal in the case of Wheels India