ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

244A, this proviso shall also apply accordingly:\n41[Provided also that where the assessee exercises the option to withdraw the application\nunder sub-section (1) of section 245M, the period of limitation available under this section to\nthe Assessing Officer for making an order of assessment, reassessment

THE MADRAS SEVA SADAN,CHENNAI vs. ACIT, EXEMPTION,, CHENNAI

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

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1246/Chny/2025 Assessment Years: 2022-23 The Madras Seva Sadan, The Assistant Commissioner Of No.7, Shenstone Park, Income Tax (Exemption), Harrington Road, Chetpet, Chennai. Chennai-600 031. [Pan: Aaatt2871J] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri R.Venkatanarayanan, Advocate प्रत्यर्थी की ओर से /Revenue By : Ms.R.Anitha, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 07.08.2025 घोषणा की तारीख /Date Of Pronouncement : 08.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

reassessment are pending in respect of an assessee, in computing the period for determining the additional interest payable to such assessee under this sub-section, the period beginning from the date on which such refund is withheld by the Assessing Officer in accordance with and subject to provisions of sub-section (2) of section 245 and ending 4[with

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

reassessment proceedings initiated after a notice under Section 148, leading to additions and demands.", "held": "The Tribunal noted that the assessee was not given an adequate opportunity of being heard by the CIT(A) and that the CIT(A) did not specifically address the assessee's reliance on the Supreme Court's decision in Engineering Analysis. Therefore, the impugned order

M/S. REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

244A\n(Rs.46,69,244).\n5. On the facts and in the circumstances of the case and in law, the Hon'ble\nCIT(A) erred in upholding the levy of tax @41.6% on interest on income tax\nrefund considering the same to be attributable to alleged PE in India without\nappreciating that the same is taxable @ 15% in terms

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

244A\n(Rs.46,69,244).\n5. On the facts and in the circumstances of the case and in law, the Hon'ble\nCIT(A) erred in upholding the levy of tax @41.6% on interest on income tax\nrefund considering the same to be attributable to alleged PE in India without\nappreciating that the same is taxable @ 15% in terms

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

reassessment proceedings were concluded with an order dated\n25.11.2019, passed under Sections 143(3) read with 147 and 144C(13)\nof the Act. In this order, an addition of Rs.17,61,12,836/- was made\ntowards profits allegedly attributable to a Permanent Establishment (PE)\nin India, resulting in a tax demand of Rs.20,82,31,507.\n\nProceedings under

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

reassessment proceedings were concluded with an order dated\n25.11.2019, passed under Sections 143(3) read with 147 and 144C(13)\nof the Act. In this order, an addition of Rs.17,61,12,836/- was made\ntowards profits allegedly attributable to a Permanent Establishment (PE)\nin India, resulting in a tax demand of Rs.20,82,31,507.\nProceedings under MAP\nPage

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

244A\n(Rs.46,69,244).\n5. On the facts and in the circumstances of the case and in law, the Hon'ble\nCIT(A) erred in upholding the levy of tax @41.6% on interest on income tax\nrefund considering the same to be attributable to alleged PE in India without\nappreciating that the same is taxable @ 15% in terms

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

reassessment proceedings were concluded with an order dated\n25.11.2019, passed under Sections 143(3) read with 147 and 144C(13)\nof the Act. In this order, an addition of Rs.17,61,12,836/- was made\ntowards profits allegedly attributable to a Permanent Establishment (PE)\nin India, resulting in a tax demand of Rs.20,82,31,507.\nProceedings under MAP\nITA

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

reassessment proceedings were concluded with an order dated\n25.11.2019, passed under Sections 143(3) read with 147 and 144C(13)\nof the Act. In this order, an addition of Rs.17,61,12,836/- was made\ntowards profits allegedly attributable to a Permanent Establishment (PE)\nin India, resulting in a tax demand of Rs.20,82,31,507.\nProceedings under MAP\nWhile

REDINGTON DISTRIBUTION PTE LTD.,SINGAPORE vs. DCIT, INTERNATIONAL TAX CIRCLE-2(1), CHENNAI

In the result, all the captioned appeals (ITA Nos

244A\n(Rs.46,69,244).\n5. On the facts and in the circumstances of the case and in law, the Hon'ble\nCIT(A) erred in upholding the levy of tax @41.6% on interest on income tax\nrefund considering the same to be attributable to alleged PE in India without\nappreciating that the same is taxable @ 15% in terms

DEPUTY COMMISSIONER (EXEMPTIONS), CHENNAI, INCOME TAX vs. HINDUSTAN INSTITUTE OF TECHNOLOGY AND SCIENCE, CHENNAI

In the result the appeal of the Revenue is dismissed

reassessment the Ld.AO did not make any findings\ncontrary to the facts & evidence brought out in Respondents\nrepresentation in their letter dt 09/02/20215 (Enclosed in Pages 37-46\nof PB) in making additions except repeating the reasons and on his\nunilateral conclusions. The findings of the then Ld.AO in the original\nassessment is clear.\n:- 10 -:\nITA No.611/Chny/2024\n10. Further