SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section

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

73,61,893. The assessee claimed a Tax deducted at source (“TDS”) credit of Rs. 77,93,486 and accordingly claimed a refund of Rs. 4,31,593. A survey was conducted in the premises of the assessee on July 02, 2010. During the survey, original agreements relating to a financial transaction with (“SICCL”) viz, Facility agreement dated December

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

73,61,893. The assessee claimed a Tax deducted at source (“TDS”) credit of Rs. 77,93,486 and accordingly claimed a refund of Rs. 4,31,593. A survey was conducted in the premises of the assessee on July 02, 2010. During the survey, original agreements relating to a financial transaction with (“SICCL”) viz, Facility agreement dated December

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

73,61,893. The assessee claimed a Tax deducted at source (“TDS”) credit of Rs. 77,93,486 and accordingly claimed a refund of Rs. 4,31,593. A survey was conducted in the premises of the assessee on July 02, 2010. During the survey, original agreements relating to a financial transaction with (“SICCL”) viz, Facility agreement dated December

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

73,61,893. The assessee claimed a Tax deducted at source (“TDS”) credit of Rs. 77,93,486 and accordingly claimed a refund of Rs. 4,31,593. A survey was conducted in the premises of the assessee on July 02, 2010. During the survey, original agreements relating to a financial transaction with (“SICCL”) viz, Facility agreement dated December

DCIT CORPORATE CIRCLE 1(1), CHENNAI vs. A.V.THOMAS LEATHER AND ALLIED PRODUCTS PVT. LTD., CHENNAI

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

Bench: Shri Ramit Kochar & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A. No. 2309/Chny/2018 िनधा"रण वष"/Assessment Year: 2014-15 The Deputy Commissioner Of M/S. A.V. Thomas Leather & Allied Income Tax, Vs. Products Pvt. Ltd., No. 22, Marshalls Corporate Circle 1(1), Road, Egmore, Chennai 600 008. Chennai 600 034. [Pan:Aaaca6246K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Guru Bashyam, Addl. Cit ""थ" की ओर से/Respondent By : Shri Sanjeev Aditya, C.A. सुनवाई की तारीख/ Date Of Hearing : 28.11.2019 घोषणा की तारीख /Date Of Pronouncement : 05.12.2019 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 1, Chennai, Dated 21.05.2018 Relevant To The Assessment Year 2014-15. The Effective Ground Raised In The Appeal Of The Revenue Is That The Ld. Cit(A) Has Erred In Deleting The Disallowance Under Section 14A R.W. Rule 8D While Computing Book Profit Under Section 115Jb Of The Income Tax Act, 1961 [“Act” In Short].

disallowance under section 14A was ₹.14,73,715/-, whereas, the Assessing Officer determined the disallowance under section 14A r.w. Rule

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 35(2AB). The appellant had claimed weighted deduction in respect of revenue expenditure incurred to the extent of ₹5,53,99,191 but the DSIR has restricted the revenue expenditure to ₹466.26 lakhs for the purpose of weighted deduction. The AO disallowed the entire claim of ₹7,73

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry

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

disallowance u/s 14A. 3. The issue of unabsorbed depreciation as raised in revenue’s appealwas remitted back by Hon’ble Court to Tribunal with following observations: - 6. The second substantial question of law raised by the Revenue is regarding unabsorbed depreciation for the previous years. 7. The Revenue contends before us that the eight years limitation in respect of carry