TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance under section 14A of the Act are that in the investment portfolio of the assessee as on 31.03.2012 stands at an aggregate value of ₹.375,57

TAMIL NADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee in I

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

disallowance under section 14A of the Act are that in the investment portfolio of the assessee as on 31.03.2012 stands at an aggregate value of ₹.375,57

SMT. D. SAILAJA,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes in the manner indicated above

Bench: Shri Ramit Kochar & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 2350/Chny/2016 िनधा"रण वष"/Assessment Year: 2012-13 Mrs. D. Sailaja, The Deputy Commissioner Of No. 4, 10Th Street, Nandanam Vs. Income Tax, Extension, Nandanam, Non Corporate Circle Ii, Chennai 600 035. Chennai 600 034. [Pan:Aaops2743J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri J. Purshothaman, C.A. Shri Guru Bashyam, Addl. Cit ""थ" की ओर से/Respondent By : सुनवाई की तारीख/ Date Of Hearing : 26.11.2019 घोषणा की तारीख /Date Of Pronouncement : 23.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy:

disallowance made under section 14A r.w. Rule 8D. 2 I.T.A. No. 2350/Chny/16 2. Brief facts of the case are that the assessee has filed the return of income for the assessment year 2012-13 admitting total income of ₹.57

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

57 and directed that AO to restrict the disallowance at 0.5% of the guarantee value. 3.2 After hearing both the parties and going through the facts and circumstances of the case, we concur with the TPO's order that this is an international transaction, but upward adjustment is now covered in favour of the assessee by the decision

HANSA VISION INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 3443/Chny/2019 िनधा"रण वष"/Assessment Year:2014-15 M/S. Hansa Vision India P. Ltd., The Deputy Commissioner Of No. 19, Wheatcroft Road, Vs. Income Tax, Nungambakkam, Chennai 600 034. Corporate Circle 2(2), [Pan:Aabct3770E] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 06.04.2022 घोषणा की तारीख /Date Of Pronouncement : 05.05.2022 आदेश /O R D E R Per V. Durga Rao,: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai, Dated 29.11.2019 Relevant To The Assessment Year 2014-15. 2. The First Ground & Ground No. 12 Raised In The Appeal Are General In Nature & Requires No Adjudication.

57,077/- which are exempt income yielding investments. By applying section 14A r.w. Rule 8D, the Assessing Officer determined the expenditure attributable to earning of exempt income under section 14A of the Act r.w. Rule 8D of ₹.31,75,285/- and disallowed

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)

section 144C(3) r.w.s. 92CA of the Act dated 29.05.2015, the Assessing Officer disallowed a sum of ₹. 7,35,900/- as TP adjustment. On appeal, the CIT(A) confirmed the above TP adjustment. The assessee contended that Tribunal is consistently holding that TP adjustment in respect of guarantee given to AE shall be at 0.5% and prayed to restrict

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 144C(3) r.w.s. 92CA of the Act dated 29.05.2015, the Assessing Officer disallowed a sum of ₹. 7,35,900/- as TP adjustment. On appeal, the CIT(A) confirmed the above TP adjustment. The assessee contended that Tribunal is consistently holding that TP adjustment in respect of guarantee given to AE shall be at 0.5% and prayed to restrict

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

ACIT CORPORATE CIRCLE 1, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

ACIT, MADURAI vs. J.K.FENNER (INDIA) LIMITED, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. ACIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

J.K.FENNER (INDIA) LIMITED,CHENNAI vs. JCIT, MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt

ACIT, MADURAI vs. J.K.FENNER (INDIA) LTD., MADURAI

Appeal stand dismissed whereas the assessee’s appeal stands partly allowed for statistical purposes

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

57,99,631/- u/s 14A while determining the Book Profits u/s 115JB. The grounds raised by the revenue read as under 2.1 The CIT(A) ought to have seen that as per Board’s Circular No.5/2014 dt. 11.12.2014 when the expenditure is incurred in relation to exempt income, it has to suffer disallowance irrespective of the fact whether any exempt