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

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 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

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 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

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

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

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

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

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

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

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

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.690/Chny/2020 निर्धारण वर्ष /Assessment Years: 2016-17 Ramakrishnan Prabhu Jyothi, Race Course, Coimbatore, Tamil Nadu-641018, [Pan: Adjpp4946N] Asst. Commissioner Of Income Tax, Non-Corporate Circle-5, Coimbatore. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Shri N.P.Vijay Kumar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/Date Of Hearing : 27.05.2024 घोषणा की तारीख /Date Of Pronouncement : 23.08.2024 आदेश / Order Per Amitabh Shukla, A.M : This Appeal Is Filed Against The Order Bearing Din & Order No.Itba/Apl/S/250/2029-20/1026334108(1) Dated 09.03.2020 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), For The

house property or not. The requirement to be fulfilled for transaction amount to purchase is payment/investment of consideration for identified property. The CIT Appeals and AO have incorrectly applied test of 'transfer' under Section 2(47) of the Act to 'purchase` and the same cannot be applied to Section 54F. 6. The CIT (Appeals) and AO failed to take note

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

DCIT, CHENNAI vs. ARMSTRONG INERNATIONAL PVT. LTD., CHENGALPUT

In the result, the appeal of the assessee for the A

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

transfer pricing documents page No.39 submitted by the assessee company, it was noticed by the TPO that while computing the margin, a part of expenditure amounting to Rs.7,26,74,144/- was segregated as expenditure towards the market development/Brand promotion expenses. 4.3 The assessee company claimed Rs.8.60 Cr. as operating cost and admitted the operating income of Rs.9.43 Cr. resulting

ARMSTRONG INTERNATIONAL PRIVATE LIMITED,CHENGALPUT vs. DCIT, CHENNAI

In the result, the appeal of the assessee for the A

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

transfer pricing documents page No.39 submitted by the assessee company, it was noticed by the TPO that while computing the margin, a part of expenditure amounting to Rs.7,26,74,144/- was segregated as expenditure towards the market development/Brand promotion expenses. 4.3 The assessee company claimed Rs.8.60 Cr. as operating cost and admitted the operating income of Rs.9.43 Cr. resulting

ARMSTRONG INTERNATIONAL PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee for the A

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

transfer pricing documents page No.39 submitted by the assessee company, it was noticed by the TPO that while computing the margin, a part of expenditure amounting to Rs.7,26,74,144/- was segregated as expenditure towards the market development/Brand promotion expenses. 4.3 The assessee company claimed Rs.8.60 Cr. as operating cost and admitted the operating income of Rs.9.43 Cr. resulting