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

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

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

THIRU AROORAN SUGARS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeals for ay 2005-06 & 2006-07

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5A cane price the CIT(A) held that there was no addition made on this account . Since, the AO himself has mentioned that the appellant can makea claim in assessment year 2003-04, the CIT(A) held that any adjudication on the assessee’s grounds are only academic in nature and hence, treated them as dismissed, upheld the disallowances; made

THIRU AROORAN SUGARS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeals for ay 2005-06 & 2006-07

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5A cane price the CIT(A) held that there was no addition made on this account . Since, the AO himself has mentioned that the appellant can makea claim in assessment year 2003-04, the CIT(A) held that any adjudication on the assessee’s grounds are only academic in nature and hence, treated them as dismissed, upheld the disallowances; made

SELVA GOLD COVERING P LTD.,CHENNAI vs. DCIT, COIMBATORE

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

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita No.3262/Mds/2016 "नधा"रण वष" / Assessment Year : 2012-13 M/S Selva Gold Covering Pvt. Ltd., C/O Shri S. Sridhar, The Deputy Commissioner Of Sh. A.S. Sriraman, Advocate , V. Income Tax, New No.14, Old No.82, Flat No.5, Corporate Circle – 2, 1St Avenue, Indira Nagar, Adyar, Coimbatore. Chennai - 600 020. Pan : Aadcs 0688 Q (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance of `5,43,708/- under Section 40A(2)(a) of the Act. 8. The question now arises for consideration is when the survey team found that there was suppression of sales, and the assessee has filed revised return under Section 139(5) of the Act, whether there was concealment of income or the assessee has furnished inaccurate particulars

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

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

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

M/S. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

ACIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD.,CHENNAI vs. ACIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED,CHENNAI vs. DCIT, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

DCIT, CHENNAI vs. M/S. CHOLAMANDALAM MS GENERAL INSURANCE CO. LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

ACIT LTU 2 , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

ACIT LTU 2 , CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LIMITED, CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

DCIT, CHENNAI vs. CHOLAMANDALAM MS GENERAL INSURANCE COMPANY LTD., CHENNAI

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other

M/S CHOLAMANDALAM MS GENERAL INSUSRANCE COMPANY LIMITED,CHENNAI vs. DCIT, PARGE TAX PAYER UNIT 2

Bench: Shri V.Durga Rao & Shri G. Manjunatha(अपीलाथ"/Appellant) (""यथ"/Respondent) S.

disallowed by the Assessing Officer is only provision created for the relevant assessment year, but there was no discussion on the spending in respect of IBNR & IBNER. In ITA Nos. 40/Chny/2009, 1759 & 1676/Chny/2011, 1366/Chny/2013 & 949 to 951/Chny/2018 case, the assessee has made actual utilization towards IBNR & IBNER, then same needs to be allowed as deduction on payment basis. In other