TITAN INDUSTRIES LIMITED,HOSUR vs. JCIT, CHENNAI

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Section 92A(1) or 92A (2) of the Act; and e. In determining the royalty income and consequently making an adjustment computation of tax. B. Non-transfer pricing adjustments Ground 2: Disallowance

ORCHID PHARMA LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is partly allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.73/Chny/2017 निर्ाारण वर्ा /Assessment Years: 2012-13

92A(2)(i) I.T.A. No. 771/CHNY/2016 Assessment year: 2011-12 requires this expression to be read as a dominant influence in the sense of control by one enterprise over the other. Given the fact that the assessee's exports through the distribution part constitutes less than 5% of its entire exports, and less than 6% of its entire sales, Northstar

PHILIPS FOODS INDIA PRIVATE LIMITED,TUTICORIN vs. PCIT-1, MADURAI

In the result, the appeal of the assesse is allowed

92A to 92F of the Income Tax Act, 1961. The return of\nincome was selected for assessment under section 143(3) of the Act\nand a corresponding reference was made to the Transfer Pricing Officer\n('TPO') under Section 92CA of the Act. Accordingly several notices\nunder section 92CA(2) and 92D(3) read with section 129 were issued

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

92A(2)(g) and, being a transaction between the AEs, the transaction will cease to be a valid input. For the sake of completeness, we may mention that, for the purposes of sub-section (1), two enterprises shall be deemed to be associated enterprises if, at any time during the previous year, if, inter alia, “the manufacture or processing

FAURECIA EMISSIONS CONTROL TECHNOLOGIES INDIA PRIVATE LIMITED,CHENNAI vs. ASSISTANT / DEPUTY COMMISSIONER OF INCOME TAX - CORPORATE CIRCLE 1(1) CHE, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.1223/Chny/2025 Assessment Years: 2023-24 Faurecia Emissions Control Assistant Commissioner Of Technologies India Pvt Ltd, Income Tax, 1St Floor, No.634, Karumuthu Center, Corporate Circle-1(1), Anna Salai, Nandanam, Chennai. Chennai-600 035 [Pan: Aaaca8450F] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Mr.Siddhesh Chaugula, C.A. प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 04.09.2025 घोषणा की तारीख /Date Of Pronouncement : 14.11.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

92a [ (iia) any such inconsistency in the return, with respect to the information in the return of any preceding previous year, as may be prescribed;] 93[(iii) disallowance of loss claimed, if return of the previous year for which set off of loss is claimed was furnished beyond the due date specified under sub-section (1) of section

TITAN INDUSTRIES LIMITED,HOSUR vs. JCIT, CHENNAI

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

section 37 of the Act. Ground 7: Short grant of Tax deducted at source (TDS) amount: Rs. 93,683 The learned AO has erred in granting short credit of TDS amounting to Rs. 93,683/- while passing the assessment order. Ground 8: Calculation of Interest on resulting adjustment a. The learned AO/DRP erred in confirming the order

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT NON CORP CIRCLE 8(1), , CHENNAI

In the result, appeal filed by the assessee is dismissed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 609/Chny/2024 िनधा"रणवष" / Assessment Year: 2016-17 Deputy Commissioner Of Income M/S. Hyundai Motor India V. Tax, Limited, Non Corporate Circle – 8(1), Plot No. H-1, Sipcot Chennai – 600 034. Industrial Park, Irungatukottai, Sriperumbudurtaluk, Kancheepuram District, Tamil Nadu – 602 117. [Pan: Aaach-2364-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nanda Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 घोषणा क" तार"ख/Date Of Pronouncement : 21.08.2024 आदेश /O R D E R

2. The sole issue involved in this appeal is as regards to ld.CIT(A) erred in upholding the giving effect order of the Assessing Officer in treating the Investment Promotion Subsidy (IPS) in the form of refund of output VAT amounting to Rs.90,95,09,568/-as a revenue receipt chargeable to tax. The assessee has also raised various other

PAR FORMULATIONS PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.1009/Chny/2017 िनधा%रण वष% /Assessment Year: 2012-13

2 above, the lower authorities also erred in law by failing to obtain an alternative expert opinion and accordingly, the entire order of the Ld. TPO, issued based on erroneous presumptions relating to the facts and future income stream is liable to be quashed. 3. That the lower authorities erred in rejecting/ disallowing the methodologies originally considered by the independent

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT NON CORP CIRCLE 8(1), , CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 608/Chny/2024 िनधा"रणवष" / Assessment Year: 2013-14 Deputy Commissioner Of Income M/S. Hyundai Motor India V. Tax, Limited, Non Corporate Circle – 8(1), Plot No. H-1, Sipcot Chennai – 600 034. Industrial Park, Irungatukottai, Sriperumbudurtaluk, Kancheepuram District, Tamil Nadu – 602 117. [Pan: Aaach-2364-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ"क"ओरसे/Respondent By : Shri. V. Nanda Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 06.06.2024 घोषणा क" तार"ख/Date Of Pronouncement : 21.08.2024 आदेश /O R D E R

2. The sole issue involved in this appeal is as regards to ld.CIT(A) erred in upholding the giving effect order of the Assessing Officer in treating the Investment Promotion Subsidy (IPS) in the form of refund of output VAT amounting to Rs.32,75,56,192/- as a revenue receipt chargeable to tax. The assessee has raised various other grounds

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT NON CORP CIRCLE 8(1), CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 589/Chny/2024 िनधा"रणवष" / Assessment Year: 2015-16 The Deputy Commissioner Of M/S. Hyundai Motor India V. Income Tax, Limited, Non Corporate Circle -8(1), Plot No. H-1, Sipcot Chennai – 600 034. Industrial Park, Irungatukottai, Sriperumbudurtaluk, Kancheepuram District, Tamil Nadu – 602 117. [Pan: Aaach-2364-M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S.P. Chidambaram, Advocate ""यथ"क"ओरसे/Respondent By : Shri. Nanda Kumar, Cit सुनवाई क" तार"ख/Date Of Hearing : 05.06.2024 घोषणा क" तार"ख/Date Of Pronouncement : 21.08.2024 आदेश /O R D E R

2. The sole issue involved in this appeal is as regards to ld.CIT(A) erred in upholding the giving effect order of the Assessing Officer in treating the Investment Promotion Subsidy (IPS) in the form of refund of output VAT amounting to Rs.58,40,12,807/- as a revenue receipt chargeable to tax. The assessee has also raised various other

J RAY MCDERMOTT ENGINEERING SERVICES PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(2), CHENNAI

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

Bench: Shri Mahavir Singh, Vice- & Shri G.Manjunathaआयकरअपीलसं./I.T.A.No.3239/Chny/2017 ("नधा"रणवष" / Assessment Year: 2013-14) Vs The Deputy Commissioner Of M/S. J Ray Mcdermott Engineering Income Tax, Services Pvt. Ltd. Rmz Millenia Business Park, 6Th Corporate Circle-2(2) 512, Wanaparthy Block, Floor, Campus 3B, No.143, Chennai-34. Dr.Mgr Road, Kandanchavady, Chennai-600 096. Pan: Aabcj 6787H (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 92, 92A to 92F of the Income Tax Act, 1961. The assessee has aggregated all transactions with its AEs and substantiated international transactions by using TNMM as most appropriate method. Further, 4 international transactions in the nature of reimbursement of expenses received were justified for arm’s length price by using CUP method. The assessee had operating margin

TECHMAT ENTERPRISES (INDIA) PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

Bench: Shri N.R.S. Ganesanआयकर अपील सं./Ita No.1125/Mds/2016 "नधा"रण वष" / Assessment Year : 2003-04

92A, SIDCO, Industrial Estate, Company Circle III(2), Ambattur, Chennai - 600 098. Chennai - 600 034. PAN : AAACT 7635 H (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant by : Shri V.S. Jayakumar, Advocate ""यथ" क" ओर से/Respondent by : Sh. P. Radhakrishnan, JCIT सुनवाई क" तार"ख/Date of Hearing : 14.06.2016 घोषणा क" तार"ख/Date of Pronouncement : 18.08.2016 आदेश