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

disallowance under section 144 was not\n\n- 10 -\nITA Nos.1193, 1194, 1205 to 1207,\n1262 to 1266/CHNY/2024\n\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording

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

disallowance under section 144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing

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

disallowance under Section 14A was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing

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

disallowance under section 144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing

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

disallowance under section 144 was not\ncorrect. It will be in those cases where the assessee in his return has himself\napportioned but the AO was not accepting the said apportionment. In that\neventuality, it will have to record its satisfaction to this effect. Further, while\nrecording such a satisfaction, nature of loan taken by the assessee for\npurchasing

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

disallowing consultancy fee of Rs.13,70,90,436/- and Escrow fee of Rs.2,01,663/- paid to standard chartered bank is confirmed. This ground of appeal is dismissed. ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 13 -: ITA Nos.1417 & 1421/Chny/2016 5.6 Additional ground No.7 raised by the appellant is against adjustment of interest

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

disallowing consultancy fee of Rs.13,70,90,436/- and Escrow fee of Rs.2,01,663/- paid to standard chartered bank is confirmed. This ground of appeal is dismissed. ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 13 -: ITA Nos.1417 & 1421/Chny/2016 5.6 Additional ground No.7 raised by the appellant is against adjustment of interest

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

disallowing consultancy fee of Rs.13,70,90,436/- and Escrow fee of Rs.2,01,663/- paid to standard chartered bank is confirmed. This ground of appeal is dismissed. ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 13 -: ITA Nos.1417 & 1421/Chny/2016 5.6 Additional ground No.7 raised by the appellant is against adjustment of interest

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing consultancy fee of Rs.13,70,90,436/- and Escrow fee of Rs.2,01,663/- paid to standard chartered bank is confirmed. This ground of appeal is dismissed. ITA Nos.1040/Chny/2014 & 1392, 1393, 1390, 1391, 1973/Chny/2016 ITA Nos.1075/Chny/2014, 663/Chny/2015 (CO No.51/Chny/2014 in ITA No.1075/Chny/2014) - 13 -: ITA Nos.1417 & 1421/Chny/2016 5.6 Additional ground No.7 raised by the appellant is against adjustment of interest

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

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance under section 14A was not - 10 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024 correct. It will be in those cases where the assessee in his return has himself apportioned but the AO was not accepting the said apportionment. In that eventuality, it will have to record its satisfaction to this effect. Further, while recording such a satisfaction

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

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance under section 14A was not - 10 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024 correct. It will be in those cases where the assessee in his return has himself apportioned but the AO was not accepting the said apportionment. In that eventuality, it will have to record its satisfaction to this effect. Further, while recording such a satisfaction

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)

55,00,000/-. After considering the submissions of the assessee, the CIT(A) confirmed the disallowance of claim of depreciation and the disallowance made under 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)

55,00,000/-. After considering the submissions of the assessee, the CIT(A) confirmed the disallowance of claim of depreciation and the disallowance made under section

M/S. SHRIRAM CONSTRUCTION FINANCE,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.317/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 M/S. Shriram Construction Finance, Vs. The Assistant Commissioner Of Mookambika Complex, No. 4, Income Tax, Lady Desika Road, Mylapore, Non Corporate Circle 2, Chennai 600 004. Chennai. [Pan:Aaafs2597N] आयकर अपील सं./I.T.A. No.343/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Construction Income Tax, Finance, Mookambika Complex, Non Corporate Circle 2(1), No. 4, Lady Desika Road, Chennai. Mylapore, Chennai 600 004. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.03.2022 घोषणा की तारीख /Date Of Pronouncement : 13.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 26.11.2018 Relevant To The Assessment Year 2013-14. The Grounds Raised By The Assessee Are Reproduced As 2

section 14A r.w. Rule 8D of ₹.48,16,523/- and after reducing the disallowance made by the assessee, the balance amount of ₹.35,55

DCIT CORPORATE CIRCLE 2, CHENNAI vs. SHRIRAM CONSTRUCTION FINANCE, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.317/Chny/2019 िनधा"रण वष"/Assessment Year: 2013-14 M/S. Shriram Construction Finance, Vs. The Assistant Commissioner Of Mookambika Complex, No. 4, Income Tax, Lady Desika Road, Mylapore, Non Corporate Circle 2, Chennai 600 004. Chennai. [Pan:Aaafs2597N] आयकर अपील सं./I.T.A. No.343/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Construction Income Tax, Finance, Mookambika Complex, Non Corporate Circle 2(1), No. 4, Lady Desika Road, Chennai. Mylapore, Chennai 600 004. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 30.03.2022 घोषणा की तारीख /Date Of Pronouncement : 13.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee & The Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 2, Chennai Dated 26.11.2018 Relevant To The Assessment Year 2013-14. The Grounds Raised By The Assessee Are Reproduced As 2

section 14A r.w. Rule 8D of ₹.48,16,523/- and after reducing the disallowance made by the assessee, the balance amount of ₹.35,55

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

55,300/- for the assessment year 2011-12 is at very high side. Thus considering the earlier order of the Tribunal on this issue for the assessment year 2008-09 in assessee own case, we are of the opinion that the above entire expenditure cannot be disallowed. However, we cannot rule out the incurring of management expenses by the assessee

SHRIRAM CAPITAL LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Chandra Poojari & Shri Challa Nagendra Prasadआयकर अपील सं./ I.T.A. Nos.512 &513 /Mds/2015 ("नधा"रण वष" / Assessment Year : 2010-2011 & 2011- 2012)

55,300/- for the assessment year 2011-12 is at very high side. Thus considering the earlier order of the Tribunal on this issue for the assessment year 2008-09 in assessee own case, we are of the opinion that the above entire expenditure cannot be disallowed. However, we cannot rule out the incurring of management expenses by the assessee

SQS INDIA BFSI LTD. (FORMERLY KNOWN AS M/S. THINKSOFT GLOBAL SERVICES LTD.),CHENNAI vs. DCIT CORPORATE CIRCLE 6(2), CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes for both the assessment years

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. Nos. 223 & 224/Chny/2019 िनधा"रण वष"/Assessment Years:2012-13 & 2013-14 M/S. Sqs India Bfsi Ltd. (Formerly The Deputy Commissioner Of Known As M/S. Thinksoft Global Vs. Income Tax, Services Ltd.) Door No. 6A, 6Th Floor, Corporate Circle 6(2), Prince Infocity Ii, 283/3 & 283/4, Rajiv Chennai. Gandhi Salai (Omr), Kandanchavadi, Chennai 600 036. [Pan:Aabct0976G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Vikram Vijayaraghavan, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.03.2021 घोषणा की तारीख /Date Of Pronouncement : 03.05.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Same Assessee Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2018 Relevant To The Assessment Years 2012-13 & 2013-14. Besides Challenging Confirmation Of Disallowance Of Export Commission Payment In The Assessment Year 2012-13, The Assessee Also Challenged Confirmation Of Disallowance Towards Payments For Professional Services Rendered For Both The Assessment Years 2012-13 & 2013-14. 2

disallowed the payment of ₹.37,55,687/- under section 40(a) r.w. section 9(1)(vii)(b) and section 195 of the Act and brought