RAMAKRISHNAN PRABHU JYOTHI,,COIMBATORE vs. ACOT, NCC-5, , COIMBATORE

In the result the appeal is dismissed

house property to mean the need for transfer under section\n2(47) of the Act' which is contrary to the case law decided by Hon'ble\nSupreme Court and various High Courts. The term \"purchase' is broad\nterm and cannot be interpreted in the same parlance as 'transfer',\n5.\nThe CIT (Appeals) and AO have incorrectly applied the principles

MAHINDRA RESIDENTIAL DEVELOPERS LTD.,CHENGALPUT vs. ITO, CHENNAI

housing to be allowed in phases of 20% in each phase,\nlinked to occupation in the processing area;\"\n15. Pursuant to the above approval, M/s. MWCDL is noted to have\nentered into a co-developer agreement dated 10.03.2008 with the\nassessee (M/s. MRDL) for development of residential infrastructure in an\nextent of area of 55 acres of land which

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

house for itself.” According to the ld. DR, the transactions can be aggregated only if they are intricately intertwined and cannot be separately analyzed. This is not the case here. Moreover, aggregated approach to transfer pricing analysis is the exception rather than the norm. This issue has been dealt with extensively by the DRP of its order dated

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

house for itself.” According to the ld. DR, the transactions can be aggregated only if they are intricately intertwined and cannot be separately analyzed. This is not the case here. Moreover, aggregated approach to transfer pricing analysis is the exception rather than the norm. This issue has been dealt with extensively by the DRP of its order dated

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...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

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...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

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...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

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...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

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...

property right, exterior design or practical and new design or any other business or commercial rights of similar nature” but even under this, what appears to be, extended definition, the accretion to the value of intangibles is not covered. As we say, we must reiterate that so far as use of brand name under the technology agreement is concerned

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

housing facilities not only for the management and office staff but also for the workers of the Special Economic Zones Units: (11) The Special Economic Zone shall be deemed to be a port, airport, inland container deport, land customs station under section 7 of the Customs Act in accordance with the provisions of section 53 from the date notified

ACIT, CORPORATE CIRCLE-4(2),, CHENNAI vs. KONE ELEVATORS INDIA LTD.,, CHENNAI

In the result, both the appeals of the Assessee as well

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T(Tp)A No.:85/Chny/2019 िनधा"रण वष"/ Assessment Year 2014 – 2015 M/S. Kone Elevator India Private The Deputy Commissioner Of Limited, Vs. Income Tax, Prestige Centre Court, 9Th Floor, Corporate Ward – 4(2), 4Th Floor, Aayakar Bhavan, The Forum Vijaya Mall, Plot No.183, Nsk Salai, Arcot Road, Vadapalani, 121, Nungambakkam High Road, Chennai – 600 026. Chennai – 600 034. Pan : Aaack 2567P (अपीलाथ"/Appellant) (""यथ"/Respondent)

house by Global Software Centre of the assessee which was well equipped in terms of personnel and resources. 2.2 The Ld. CIT(A) erred in assuming that the royalty is for use of brand name and not for technical know-how whereas Royalty payment was :: 3 :: I.T.(TP)A. No.85/Chny2019 AND I.TA No.3405/Chny/ 2019 made by the assessee only

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

In the result the appeal of the assessee is allowed

House: Li & Fung India Pvt Ltd)\nwherein it is apparent that pricing of the product has been directly negotiated and\nfixed by Assessee with its third party customer without the involvement of its AE.\nThus, the contention of the Assessee that the international transaction is undertaken\non the basis of back to back invoicing is explicitly clear and factually found

POLARIS CONSULTING & SERVICES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

House, Chennai - 600 034. Anna Salai, Chennai - 600 006. (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से /Assessee by : Shri N. Venkatraman, Sr. Advocate Shri V. Ubhaya Bharathi, Advocate राज"व क" ओर से /Revenue by : Shri Pathlavath Peerya, CIT सुनवाई क" तार"ख/Date of Hearing : 07.07.2017 घोषणा क" तार"ख/Date of Pronouncement : 18.08.2017 2 I.T.A. No.1218

POLARIS SOFTWARE LAB LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

House, Chennai - 600 034. Anna Salai, Chennai - 600 006. (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से /Assessee by : Shri N. Venkatraman, Sr. Advocate Shri V. Ubhaya Bharathi, Advocate राज"व क" ओर से /Revenue by : Shri Pathlavath Peerya, CIT सुनवाई क" तार"ख/Date of Hearing : 07.07.2017 घोषणा क" तार"ख/Date of Pronouncement : 18.08.2017 2 I.T.A. No.1218

DCIT, CHENNAI vs. POLARIS CONSULTING & SERVICES P LTD., CHENNAI

In the result, the assessee’s appeal for assessment year

Bench: Shri N.R.S. Ganesan & Shri Sanjay Aroraआयकर अपील सं./Ita No.1218/Mds/2016 "नधा"रण वष" / Assessment Year : 2010-11 & आयकर अपील सं./Ita No.615/Mds/2016 "नधा"रण वष" / Assessment Year : 2011-12

House, Chennai - 600 034. Anna Salai, Chennai - 600 006. (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से /Assessee by : Shri N. Venkatraman, Sr. Advocate Shri V. Ubhaya Bharathi, Advocate राज"व क" ओर से /Revenue by : Shri Pathlavath Peerya, CIT सुनवाई क" तार"ख/Date of Hearing : 07.07.2017 घोषणा क" तार"ख/Date of Pronouncement : 18.08.2017 2 I.T.A. No.1218

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

Transfer Pricing Orders for Assessment Years 2013-14 and 2014-15 are 01.02.2017 and 20.12.2018 respectively, well after the search.\n8.1 In such cases, it is now settled law by authoritative pronouncements of the hon'ble Supreme Court that any assessments under Sections 153A/153C in respect of unabated assessments must be based on incriminating materials obtained during search proceeding

DCIT, NCC - 2 (1),, CHENNAI vs. SHRI KEEZHAYUR SOWRIRAJAN SREENIVASAN,, CHENNAI

In the result, appeal filed by the Revenue is dismissed

Bench: Shri G. Manjunatha & Shri Anikesh Banerjee

Housing Projects Chennai Pvt.Ltd.) and claimed deduction u/s.54F of the Income Tax Act, 1961. The Assessing Officer has called upon the assessee to explain with necessary evidences transactions give rise to long term capital gain and consequent deduction claimed u/s.54F of the Income Tax Act, 1961. In response, the assessee submitted that he had entered into Memorandum of Understanding with

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

transfer pricing\nreport.\nTwo crucial facts must be noted:\n1. The assessment for Assessment Years 2013-14 and 2014-15\nwere originally concluded under Section 143(3) on\n31.3.2017 and 21.12.2016 respectively. As such the\nassessments under Section 153C are unabated assessments.\n2. The date of the search is 23.11.2015. The dates of the\nTransfer Pricing Orders for Assessment Years

SHRI RAMASWAMY SHIVARAMAN,,CHENNAI vs. ACIT, CC - 1 (1),, CHENNAI

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकरअपीलसं./Ita No.571/Chny/2020 िनधा"रणवष"/Assessment Year: 2016-17

price of M/s.CL Educate Ltd., when it was allotted to the assessee on 07.09.2015 and subsequent transfer of shares to his mother at a much lesser rate of Rs.179.15 per share, and opined that transaction of purchase of property by transfer of equity shares is nothing but an arranged transaction between two related parties and hence, cannot be considered