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

method found that arithmetic mean of the rates of bank guarantee was 2.01% but added in the case of the Assessee a conservative figure of 1% of the value of the loans guaranteed. In view of the same, the CIT(A) confirmed the addition of Rs.1.85 crores made by the TPO and adopted by the Assessing Officer. On further appeal

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)

TP study an attempt is made to find out the guarantee commission rates charged by Bank which issued Loc/guarantee. The State Bank of India, Chennai charged 1% along with service tax against the assessee for issue of LOC. The same along with 0.5% of Risk may be considered as ALP and CUP is considered as Most Appropriate Method. 7. Based

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)

TP study an attempt is made to find out the guarantee commission rates charged by Bank which issued Loc/guarantee. The State Bank of India, Chennai charged 1% along with service tax against the assessee for issue of LOC. The same along with 0.5% of Risk may be considered as ALP and CUP is considered as Most Appropriate Method. 7. Based

TRIMEX INDUSTRIES PRIVATE LIMITED,CHENNAI vs. ACIT, CENTRAL CIRCLE-IV(3), CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallow the interest expenditure because it is incurred for the purpose of business. Hence, we allow the interest and direct the AO accordingly. The appeal of the assessee is allowed. Revenue’s Appeal in ITA No.1035/CHNY/2022, AY 2009-10 15. The first issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the addition

DCIT, CENTRAL CIRCLE-1 (3), CHENNAI vs. TRIMEX INDUSTRIES PRIVATE LIMITED, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallow the interest expenditure because it is incurred for the purpose of business. Hence, we allow the interest and direct the AO accordingly. The appeal of the assessee is allowed. Revenue’s Appeal in ITA No.1035/CHNY/2022, AY 2009-10 15. The first issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the addition

DCIT, CENTRAL CIRCLE-1 (3), CHENNAI vs. TRIMEX INDUSTRIES PRIVATE LIMITED, CHENNAI

In the result, the appeals filed by the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

disallow the interest expenditure because it is incurred for the purpose of business. Hence, we allow the interest and direct the AO accordingly. The appeal of the assessee is allowed. Revenue’s Appeal in ITA No.1035/CHNY/2022, AY 2009-10 15. The first issue in this appeal of Revenue is as regards to the order of CIT(A) deleting the addition

THE INDIA CEMENTS LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

The appeal of the assessee is allowed

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2663/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

disallowance of gratuity and superannuation amounting to Rs.20,45,39,511/- claimed u/s 43B of the Income-tax Act, 1961, by incorrectly applying the due date specified under the relevant welfare Acts. The said amounts represent the employer's contribution, which, as per the provisions of Section 43B(b), is allowable as a deduction if actually paid on or before

AMBATTUR CLOTHING LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 1(1), CHENNAI

In the result the appeal of the assessee is allowed

method\nand the supplementary ground of application of internal TNMM in favour of the\nAssessee, adjudication of other grounds on TP becomes academic and we refrain to\ndeal with the same.\n6.6 Accordingly, grounds of appeal 2.2 to 2.5 and 2.6 to 2.8 & 2.11 & 2.12 are\nallowed.\n7. Gr No. 2.2 to 2.5: Disallowance

NVH INDIA AUTO PARTS PRIVATE LIMITED,KANCHEEPURAM vs. DCIT CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 2773/Chny/2017 िनधा"रण वष" / Assessment Year: 2013-14 Nvh India Auto Parts Private Deputy Commissioner Of Limited, V. Income-Tax, B-68, Sipcot Industrial Park, Corporate Circle -4(2), Irungattukottai, Sriperumbadur Nungambakkam, Taluk, Kancheepuram – 602 105. Chennai – 600 034. [Pan: Aaccn-2857-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. S.P. Chidambaram, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 08.08.2023 घोषणा क" तारीख/Date Of Pronouncement : 31.10.2023

TP adjustment of Rs. 3,01,14,249/- to international transactions of the assessee with its AE. The Assessing Officer, had also proposed additions towards disallowance of provision for warranty of Rs. 1,41,29,858/-, on the ground that provision for warranty claim is unascertained liability and there is no scientific basis for provision for warranty expenses. Similarly

CONFERENCECALL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ACIT, CHENNAI

In the result, appeals filed by the assessee for assessment years 2010-11 & 2012-13 are allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 584/Chny/2015 & 529/Chny/2017 िनधा"रण वष" / Assessment Year: 2010-11 & 2012-13 Conferencecall Services India Assistant Commissioner Of Private Ltd V. Income Tax, Rmz Titanium, No. 135, Corporate Circle -1(2), 1St Floor, Chennai – 34. Old Airport Road, Bangalore – 560 017. [Pan: Aaccc-6574-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Soumen Adak, Ca & Shri. Ashish Poddar, Ca ""यथ" क" ओर से/Respondent By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 20.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 15.09.2023 आदेश /O R D E R

TP adjustment as suggested by the TPO and also disallowance of payment made to AE u/s. 40(a)(i) of the Act. The DRP, had also directed the TPO to exclude certain comparables selected by the TPO while making adjustment towards software development services. Thereafter, the Assessing Officer has passed final assessment order u/s. 143(3) r.w.s. 144C

CONFERENCECALL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT,

In the result, appeals filed by the assessee for assessment years 2010-11 & 2012-13 are allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 584/Chny/2015 & 529/Chny/2017 िनधा"रण वष" / Assessment Year: 2010-11 & 2012-13 Conferencecall Services India Assistant Commissioner Of Private Ltd V. Income Tax, Rmz Titanium, No. 135, Corporate Circle -1(2), 1St Floor, Chennai – 34. Old Airport Road, Bangalore – 560 017. [Pan: Aaccc-6574-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Soumen Adak, Ca & Shri. Ashish Poddar, Ca ""यथ" क" ओर से/Respondent By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 20.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 15.09.2023 आदेश /O R D E R

TP adjustment as suggested by the TPO and also disallowance of payment made to AE u/s. 40(a)(i) of the Act. The DRP, had also directed the TPO to exclude certain comparables selected by the TPO while making adjustment towards software development services. Thereafter, the Assessing Officer has passed final assessment order u/s. 143(3) r.w.s. 144C

MOS METRO INDIA PRIVATE LIMITED,CHENNAI vs. ACIT CORPORATE CIRCLE 4(1), CHENNAI

In the result, the appeals filed by the assessee in IT(TP)A No

Bench: Shri Mahavir Singhand Shri Manjunatha.G

method for selection of comparables. Here, we agree with the ld.CIT-DR but we noted that there is no discussion by the TPO except the financials of the tunnel digging machine of the assessee the TPO has not discussed the nature of these two companies i.e., KNR Constructions Ltd., and Patel Infrastructure Pvt. Ltd., whether they are in tunnel boring

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. INDIAN ADDITIVES LTD., CHENNAI

In the result, appeals filed by the assessee for A

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./It(Tp)A Nos.9, 10 & 11/Chny/2018 िनधा)रण वष) /Assessment Years: 2011-12, 2012-13 & 2013-14

TP)A No.9/Chny/2018 for A.Y 2011-12: “The order of the Hon'ble Commissioner of Income Tax (Appeal) is against facts and circumstances of the case. Both the CIT (A) and the Assessing Officer has failed to appreciate the various submissions made in the current perspective. 1. Download Adjustment of Rs.5,59,73,812/-: The Appellant has adopted different methods

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. INDIAN ADDITIVES LTD., CHENNAI

In the result, appeals filed by the assessee for A

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./It(Tp)A Nos.9, 10 & 11/Chny/2018 िनधा)रण वष) /Assessment Years: 2011-12, 2012-13 & 2013-14

TP)A No.9/Chny/2018 for A.Y 2011-12: “The order of the Hon'ble Commissioner of Income Tax (Appeal) is against facts and circumstances of the case. Both the CIT (A) and the Assessing Officer has failed to appreciate the various submissions made in the current perspective. 1. Download Adjustment of Rs.5,59,73,812/-: The Appellant has adopted different methods

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. INDIAN ADDITIVES LTD., CHENNAI

In the result, appeals filed by the assessee for A

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./It(Tp)A Nos.9, 10 & 11/Chny/2018 िनधा)रण वष) /Assessment Years: 2011-12, 2012-13 & 2013-14

TP)A No.9/Chny/2018 for A.Y 2011-12: “The order of the Hon'ble Commissioner of Income Tax (Appeal) is against facts and circumstances of the case. Both the CIT (A) and the Assessing Officer has failed to appreciate the various submissions made in the current perspective. 1. Download Adjustment of Rs.5,59,73,812/-: The Appellant has adopted different methods

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. INDIAN ADDITIVES LTD., CHENNAI

In the result, appeals filed by the assessee for A

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./It(Tp)A Nos.9, 10 & 11/Chny/2018 िनधा)रण वष) /Assessment Years: 2011-12, 2012-13 & 2013-14

TP)A No.9/Chny/2018 for A.Y 2011-12: “The order of the Hon'ble Commissioner of Income Tax (Appeal) is against facts and circumstances of the case. Both the CIT (A) and the Assessing Officer has failed to appreciate the various submissions made in the current perspective. 1. Download Adjustment of Rs.5,59,73,812/-: The Appellant has adopted different methods

YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

TP transactions the paper book 2 (B) Other than Transfer Pricing Adjustment 1 Disallowance of deduction under 5,72,73,875 AO Order – Page 38 of the section 10AA of the Act paper book 2 Total 10,93,81,054 The TPO in his order u/s.92CA(3) of the Act dated 29.01.2016 has recommended downward adjustment of Rs.5

TITAN COMPANY LIMITED,HOSUR vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.393/Chny/2018 & आयकर अपील सं./ It(Tp)A No.89/Chny/2018 िनधा>रण वष> /Assessment Years: 2013-14 & 2014-15 Titan Company Ltd., The Dy. Commissioner Of Income No.3, Spicot Industrial Complex, Vs. Tax, Hosur, Krishnagiri – 635 126. Ltu-2, [Pan: Aaact 5131A] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

disallowance under section 14A, and (iii) transfer pricing (TP) adjustment related to the claim u/s. 80IC ITA No.393/Chny/2015 & IT(TP)A No.89/Chny/2018 Titan Company Ltd. :- 3 -: of the Act. For the first two issues, the assessee placed reliance on the order of the Co-ordinate Bench of the Tribunal in the Assessee’s own case for earlier assessment years, vide