AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

In the result, the appeal of the assessee is allowed

b)such instructions can be by way of relaxation of any of the provisions of the section specified therein or otherwise; (c)the Board has power inter alia, to tone down the rigour of the law and ensure a fair enforcement of its provisions by issuing circulars in exercise of its statutory powers under section 119

HYUNDAI TRANSYS INC,REPUBLIC OF KOREA vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

Appeal of the assessee is allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.338/Chny/2024 (िनधा"रणवष" / Assessment Year: 2015-2016) Hyundai Transys Inc, Vs. The Deputy Commissioner Of 105, Sindang Income Tax, 1 Ro Seongyeon, International Tax, Myeon, Corporate Circle 1(1) Seosan, Ccn 356851 Chennai. Korea.

Sections 147/148 of the Act are satisfied. It is the appellant's case that the aforesaid conditions are not satisfied inasmuch as in the absence of the Assessing Officer having the original return of income available it would not be possible for him to have a reasonable belief that income chargeable to tax has escaped assessment. This issue

DCIT CORPORATE CIRCLE 5(1), CHENNAI vs. REPCO HOME FINANCE P LTD., CHENNAI

In the result, the appeal of Revenue in ITA no

Bench: Shri George Mathan & Shri Ramit Kochar

section 43B of the Act by virtue of Finance Act, 2003 with effect from 1-4-2004 it agreed with the submission of the learned counsel for the assessee that by virtue of the omission of the second proviso and the omission of clauses (a), (c), (d ), (e) and (f) without any saving clause would mean that the provisions

T1461 KOOTHANALLUR PACB LTD.,THIRUVARUR vs. ITO, WARD-1, THIRUVARUR

In the result, the stay application filed by the assessee is dismissed and the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. No.2195/Chny/2025 िनधा"रण वष"/Assessment Year: 2018-19 & S.A. No. 73/Chny/2025 [In Ita No. 2195/Chny/2025] T1461 Koothanallur Pacb Ltd., Vs. The Income Tax Officer, Rep. By Its Secretary Mr. T. Ward 1, Singaravelu, No. 27, Big Nazaar Street, Thiruvarur. Koothanallur Post, Mannargudi Taluk, Thiruvarur 614 101. [Pan:Aacat6581C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Ms. T.V. Paarkavi, Advocate For Shri J. Ashok, Advocate ""थ" की ओर से/Respondent By : Shri C. Sivakumar, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 19.08.2025 घोषणा की तारीख /Date Of Pronouncement : 22.08.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 11.10.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2018-19. 2

68,66,447/-. 5. Aggrieved by the order of the Assessing Officer, the assessee preferred an appeal before the ld. CIT(A) with delay in filing the appeal. 3 I.T.A. No.2195/Chny/25 & S.A. No. 73/Chny/25 Since the ld. CIT(A) has not satisfied with the reasons stated by the assessee for belated filing of appeal, dismissed the appeal filed

M/S SHRIRAM PROPERTIES LIMITED,CHENNAI vs. PCIT-CENTRAL1, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 431/Chny/2022 िनधा"रण वष" / Assessment Year: 2017-18

68,61,895 equity shares in Shriram Properties & Infrastructure Pvt. Ltd. were pledged with Deutsche Pfandbrief Bank AG against compulsory convertible debenture issued by Shriram Properties & Infrastructure Pvt.Ltd. There is no information as to fair value measurement adopted to these combined financial instruments. As per information in Schedule 15, shares and debenture bonds were pledged with banks to avail certain

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

b) could not be held to be invalid. 5.12. In the case of Markanda Vanaspati Mills Ltd. v. CIT, (2006) 280 ITR 503 (P & H), wherein, the information furnished by the assessee gave no clue to the payment of liability in regard of the sales tax collected in excess. The Assessing Officer was held to be validly initiated the reassessment

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

b) could not be held to be invalid. 5.12. In the case of Markanda Vanaspati Mills Ltd. v. CIT, (2006) 280 ITR 503 (P & H), wherein, the information furnished by the assessee gave no clue to the payment of liability in regard of the sales tax collected in excess. The Assessing Officer was held to be validly initiated the reassessment

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

b) could not be held to be invalid. 5.12. In the case of Markanda Vanaspati Mills Ltd. v. CIT, (2006) 280 ITR 503 (P & H), wherein, the information furnished by the assessee gave no clue to the payment of liability in regard of the sales tax collected in excess. The Assessing Officer was held to be validly initiated the reassessment

APOLLO PHARMACIES LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE 1(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Manjunatha. G, Hon’Ble & Shri Manomohan Das, Hon’Bleआयकर अपील सं./Ita Nos.: 867 & 868/Chny/2023 िनधा"रण वष" / Assessment Years: 2020-21 Apollo Pharmacies Limited, Deputy Commissioner Of 19, Bishop Gardens, V. Income Tax, Raja Annamalaipuram, Corporate Circle -1(1), Chennai – 600 028. Chennai. [Pan: Aapca-5954-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Suraj Nahar, Ca ""यथ" क" ओर से/Respondent By : Shri. Clement Ramesh Kumar, Cit सुनवाई की तारीख/Date Of Hearing : 01.11.2023 घोषणा की तारीख/Date Of Pronouncement : 01.11.2023 आदेश /O R D E R

68,830/-. :-2-: ITA. Nos: 867 & 868/Chny/2023 The return was processed u/s. 143(1) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) by CPC on 14.12.2021 and accepted total income declared by the assessee, with a demand notice of Rs. 5,78,43,140/-, towards interest payable u/s. 234A, 234B and 234C of the Act. Thereafter

APOLLO PHARMACIES LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed for statistical purposes

Bench: Shri Manjunatha. G, Hon’Ble & Shri Manomohan Das, Hon’Bleआयकर अपील सं./Ita Nos.: 867 & 868/Chny/2023 िनधा"रण वष" / Assessment Years: 2020-21 Apollo Pharmacies Limited, Deputy Commissioner Of 19, Bishop Gardens, V. Income Tax, Raja Annamalaipuram, Corporate Circle -1(1), Chennai – 600 028. Chennai. [Pan: Aapca-5954-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Suraj Nahar, Ca ""यथ" क" ओर से/Respondent By : Shri. Clement Ramesh Kumar, Cit सुनवाई की तारीख/Date Of Hearing : 01.11.2023 घोषणा की तारीख/Date Of Pronouncement : 01.11.2023 आदेश /O R D E R

68,830/-. :-2-: ITA. Nos: 867 & 868/Chny/2023 The return was processed u/s. 143(1) of the Income-tax Act, 1961 (hereinafter referred to as “the Act”) by CPC on 14.12.2021 and accepted total income declared by the assessee, with a demand notice of Rs. 5,78,43,140/-, towards interest payable u/s. 234A, 234B and 234C of the Act. Thereafter

INDIA JAPAN LIGHTING PRIVATE LIMITED,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 4, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1427/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 V. M/S. India Japan Lighting Pvt. Ltd., The Pcit-4, No.1, Tiruvallur High Road, Chennai. Puduchatram B.O., Thirumazhisai, Tiruvallur-600 124. [Pan: Aaaci 2673 L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

68,31,19,282 73,55,67,138 MACHINERY Total 5,81,30,811 2,19,49,05,960 2,25,30,36,771 M/s. India Japan Lighting Pvt. Ltd. :: 8 :: The assessee also filed invoices of assets from Page Nos.186-442. 9. The AO second time issued notice u/s.142(1) dated 11.11.2022 for AY 2021-22 asking for the following

M/S. BRITISH AGRO PRODUCTS (INDIA) PVT. LTD.,CHENNAI vs. PCIT-1, CHENNAI

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1146/Chny/2025

b) the order is passed allowing any relief without inquiring into the claim; (c) the order has not been made in accordance with any order, direction or instruction issued by the Board under section 119; or (d) the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High

M/S. HYUNDAI MOTOR INDIA LTD.,KANCHIPURAM vs. PCIT-4, , CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

119 taxmann.com 358 133 Shriram Properties Limited ITAT – Chennai 2023 (4) TMI 375 124 Thanthi Trust ITAT – Chennai 171 taxmann.com 470 154 Rajkumar Impex Pvt. Limited ITAT – Chennai 2023 (6) TMI 812 Keller (M) SDN BHD ITAT – Chennai ITA 1319/CHNY/2023 163 Menzies Bobba Ground ITAT – Hyderabad ITA No. 226/ Hyd/ 2021 181 Handling Services Private Ltd 19. Further, ld.AR relied

SEVUGAN PETHAPERUMAL,MADURAI vs. PCIT, MADURAI-1,, MADURAI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1196/Chny/2025 Assessment Years: 2020-21 Sevugan Pethaperumal, Principal Commissioner Of Income No.41, First Main Street, Tax, Narayanapuram West, Madurai-1, Madurai, Madurai. Tamil Nadu-625 014. [Pan: Afjpp5984J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri G.Tarun, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख /Date Of Pronouncement : 25.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

b) the order is passed allowing any relief without inquiring into the claim; (c) the order has not been made in accordance with any order, direction or instruction issued by the Board under section 119; or (d) the order has not been passed in accordance with any decision which is prejudicial to the assessee, rendered by the jurisdictional High

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...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

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...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

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...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

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...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench

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...

section 40(a)(i), it is to be further shown as to how the interest income belongs to the PE. The mere existence of the PE cannot by itself lead to the conclusion that the interest income belongs to the PE. While on this issue, we may usefully refer to the following observations made by a coordinate bench