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

147 of the Act.\n8.\nPer contra, the Ld. AR of the assessee submitted his arguments\nto the grounds raised in the appeal by the department.\n9.\nThis ground of revenue is ill-conceived there is no excess claim\nof expenditure, incorrect to say it was not matching with the audited\nbooks of accounts of the assessee. In this connection

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

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

147, on or before the\nexpiry of twelve months from the end of the month in which the assessment order in\nthe case of the firm is passed.\n(7) Where effect to any order, finding or direction referred to in sub-section (5) or sub-section\n(6) is to be given by the Assessing Officer, within the time

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

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

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

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\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