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

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

5A to section 271(1)(c) is not applicable.\nAccordingly, we delete the penalty confirmed by ld. CIT (A).\"\nii). The Mumbai Bench of this Tribunal in Financial Technologies\n(I) Ltd v. ACIT, [2015] 61 taxmann.com 406 (Mum) has held as\nunder:\n“23. When we analyse the expressions used in clause (i) to Explanation\n5A, we find that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

5A to section 271(1)(c) is not applicable.\nAccordingly, we delete the penalty confirmed by ld. CIT (A).”\nii). The Mumbai Bench of this Tribunal in Financial Technologies\n(I) Ltd v. ACIT, [2015] 61 taxmann.com 406 (Mum) has held as\nunder:\n“23. When we analyse the expressions used in clause (i) to Explanation\n5A, we find that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

5A to section 271(1)(c) is not applicable.\nAccordingly, we delete the penalty confirmed by ld. CIT (A).”\nii). The Mumbai Bench of this Tribunal in Financial Technologies\n(I) Ltd v. ACIT, [2015] 61 taxmann.com 406 (Mum) has held as\nunder:\n“23. When we analyse the expressions used in clause (i) to Explanation\n5A, we find that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

5A to section 271(1)(c) is not applicable.\nAccordingly, we delete the penalty confirmed by ld. CIT (A).”\nii). The Mumbai Bench of this Tribunal in Financial Technologies\n(I) Ltd v. ACIT, [2015] 61 taxmann.com 406 (Mum) has held as\nunder:\n“23. When we analyse the expressions used in clause (i) to Explanation\n5A, we find that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

5A to section 271(1)(c) is not applicable.\nAccordingly, we delete the penalty confirmed by ld. CIT (A).”\nii). The Mumbai Bench of this Tribunal in Financial Technologies\n(I) Ltd v. ACIT, [2015] 61 taxmann.com 406 (Mum) has held as\nunder:\n“23. When we analyse the expressions used in clause (i) to Explanation\n5A, we find that

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

5A to section 271(1)(c) is not applicable.\nAccordingly, we delete the penalty confirmed by ld. CIT (A).”\nii). The Mumbai Bench of this Tribunal in Financial Technologies\n(I) Ltd v. ACIT, [2015] 61 taxmann.com 406 (Mum) has held as\nunder:\n“23. When we analyse the expressions used in clause (i) to Explanation\n5A, we find that

SOUTHERN PETROCHEMICAL INDUSTRIES CORPORATION LTD.,CHENNAI vs. ITO, CHENNAI

Appeal stands dismissed

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.84/Chny/2023 (िनधा)रण वष) / Assessment Year: 2008-09) M/S. Southern Petrochemical Income Tax Officer बनाम Industries Corporation Limited Corporate Ward-3(1) 88, Spic House, Mount Road, Guindy, Chennai-600 034. / Vs. Chennai-600 032. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacs-4668-K (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Vijayaraghavan & Shri Saroj Kumar Parida (Advocates)-Ld. Ars " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit) & Shri Ar V Sreenivasan (Addl. Cit)-Ld. Drs सुनवाईकीतारीख/Date Of Hearing : 16-10-2023 घोषणाकीतारीख /Date Of Pronouncement : 10-01-2024 आदेश / O R D E R

section 115 JB (Para .6.1 at Page 50). As is evident, the additions / disallowance which forms the subject matter of this appeal are i.e., (i) Disallowance u/s 14A; (ii) Disallowance of proportionate interest expenditure; (iii) Disallowance of Bad debts written-off; (iv) Disallowance of 50% expenditure towards R&D facility: (v) Disallowance of Electricity Tax u/s 43B as well

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed\nfor statistical purposes

disallowance and the Id. CIT(A) to\nconfirm the same.\n10.9 The Bangalore Benches of the Tribunal in the case of M/s. Mahindra\nElectric Mobility Ltd. v. ACIT in ITA No.641/Bang/2017 vide order dated\n14.09.2018 had held that prior to 01.07.2016 Form No.3CL has no legal\nsanctity and it is only w.e.f. 01.07.2016 with the amendment to Rule

JCIT (OSD), CORPORATE CIRCLE - 2 (2),, CHENNAI vs. M/S INDIAN POTASH LTD., CHENNAI

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Inturi Rama Rao & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2580/Chny/2019 िनधा"रण वष"/Assessment Year: 2014-15 The Joint Commissioner Of Vs. M/S. Indian Potash Ltd., Income Tax (Osd), No. 727, Ambal Building, Corporate Circle 2(2), Anna Salai, Chennai. Chennai 600 006. [Pan: Aaaci0888H] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sudarshan, Jcit ""थ" की ओर से/Respondent By : Shri Vikram Vijayaraghavan, Advocate सुनवाई की तारीख/ Date Of Hearing : 27.01.2026 घोषणा की तारीख /Date Of Pronouncement 10.03.2026 : आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 06.05.2019 Passed By The Ld. Commissioner Of Income Tax (Appeals) 6, Chennai For The Assessment Year 2014-15. 2. The Appellant-Revenue Raised 3 Grounds Of Appeal Amongst Which The Only Issue Emanates For Our Consideration As To Whether The Ld. Cit(A) Is Justified In Allowing Claim Under Section 80Ib Of The Income Tax Act, 1961 [“Act” In Short] In The Facts & Circumstances Of The Case.

section shall not apply to an undertaking engaged in the business of processing, preservation and packaging of meat or meat products or poultry or marine or dairy products, if it begins to operate such business before 01.04.2009. 5. The ld. AR Shri Vikram Vijayaraghavan, Advocate relied on the order of the ld. CIT(A). 6. Heard both the parties

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP CIRCLE 8, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed….” It is noted that the Hon’ble Coordinate Bench has considered the ratios laid down by Hon’ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon’ble Calcutta High Court. 13.4 Further we have noted that Hon’ble Delhi High Court

DEPUTY COMMISSIONER OF INCOME TAX OFFICER , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed….” It is noted that the Hon’ble Coordinate Bench has considered the ratios laid down by Hon’ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon’ble Calcutta High Court. 13.4 Further we have noted that Hon’ble Delhi High Court

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed….” It is noted that the Hon’ble Coordinate Bench has considered the ratios laid down by Hon’ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon’ble Calcutta High Court. 13.4 Further we have noted that Hon’ble Delhi High Court

DEPUTY COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed….” It is noted that the Hon’ble Coordinate Bench has considered the ratios laid down by Hon’ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon’ble Calcutta High Court. 13.4 Further we have noted that Hon’ble Delhi High Court

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, NON CORP WARD 8, CHENNAI

In the result, Revenue Appeal for AY 2012-13 stands dismissed

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

section 37(1) of the Act. Accordingly, the ground no.1 of the appeal is dismissed….” It is noted that the Hon’ble Coordinate Bench has considered the ratios laid down by Hon’ble Coordinate Bench of Kolkata Tribunal as well as the decision of Hon’ble Calcutta High Court. 13.4 Further we have noted that Hon’ble Delhi High Court

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

disallowance and the ld. CIT(A) to confirm the same. 10.9 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

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

disallowance and the ld. CIT(A) to confirm the same. 10.9 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

CARBORUNDUM UNIVERSAL LIMITED,CHENNAI vs. ACIT LTU-1, CHENNAI

In the result, appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Manu Kumar Giri & Shri Amitabh Shukla

disallowance and the ld. CIT(A) to confirm the same. 10.9 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

TAMILNADU INDUSTRIAL DEVELOPMENT CORPORATION LIMITED,CHENNAI vs. DCIT CORP CIRCLE 3(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1036/Chny/2024 िनधा"रणवष" / Assessment Year: 2018-19 M/S. Tamilnadu Industrial The Deputy Commissioner Of Development Corporation Limited, V. Income Tax, 19-A, Rukminilakshmipathy Road, Corporate Circle 3(1), Egmore, Chennai – 600 008. Chennai – 600 034. [Pan:Aaact-3409-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. R. Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Shri. Clement Ramesh Kumar, Cit सुनवाईकीतारीख/Date Of Hearing : 23.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 18.09.2024

disallowance of interest tax payment of Rs. 9,98,46,515/- during the A.Y 2018-19 by holding as under: “6.2.2 It is noted that there is no dispute about the fact that the liability to pay the impugned interest tax arose and was actually paid by the appellant in the FY 2017-18 (AY 2018-19). There is also