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

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

In the result the appeal of the Revenue is dismissed

1) and (2) of Schedule 6, Notes on Accounts of the Annual\nAccounts of the Appellant society. These are also reflected in the Padur\nCampus of HCE, as may be seen from the copy of the Fixed Assets\nSchedule of M/s HCE unit of HETC enclosed.\ne. In the Schedule of the Fixed Assets in HCE for the year ended

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

In the result, all the captioned appeals (ITA Nos

1), CHE (hereinafter referred to as the\n\"AO\") dated 30.03.2024 for AYs 2011-12, 2012-13, 2013-14, 2014-15,\n2015-16, 2016-17 and dated 11.07.2024 for AYs 2017-18, 2018-19 &\n2021-22 under the Income-tax Act, 1961 (hereinafter \"the Act\").\n2. The assessee has raised somewhat similar grounds in all the captioned\nappeals. For adjudication

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

In the result, all the captioned appeals (ITA Nos

1), CHE (hereinafter referred to as the\n\"AO\") dated 30.03.2024 for AYs 2011-12, 2012-13, 2013-14, 2014-15,\n2015-16, 2016-17 and dated 11.07.2024 for AYs 2017-18, 2018-19 &\n2021-22 under the Income-tax Act, 1961 (hereinafter \"the Act\").\n2. The assessee has raised somewhat similar grounds in all the captioned\nappeals. For adjudication

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

1), CHE (hereinafter referred to as the\n\"AO\") dated 30.03.2024 for AYs 2011-12, 2012-13, 2013-14, 2014-15,\n2015-16, 2016-17 and dated 11.07.2024 for AYs 2017-18, 2018-19 &\n2021-22 under the Income-tax Act, 1961 (hereinafter \"the Act\").\n2. The assessee has raised somewhat similar grounds in all the captioned\nappeals. For adjudication

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

In the result, all the captioned appeals (ITA Nos

1), CHE (hereinafter referred to as the\n\"AO\") dated 30.03.2024 for AYs 2011-12, 2012-13, 2013-14, 2014-15,\n2015-16, 2016-17 and dated 11.07.2024 for AYs 2017-18, 2018-19 &\n2021-22 under the Income-tax Act, 1961 (hereinafter \"the Act\").\n2. The assessee has raised somewhat similar grounds in all the captioned\nappeals. For adjudication

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

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, 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

1), CHE (hereinafter referred to as the\n\"AO\") dated 30.03.2024 for AYs 2011-12, 2012-13, 2013-14, 2014-15,\n2015-16, 2016-17 and dated 11.07.2024 for AYs 2017-18, 2018-19 &\n2021-22 under the Income-tax Act, 1961 (hereinafter \"the Act').\n2. The assessee has raised somewhat similar grounds in all the captioned\nappeals. For adjudication