M/S. CASTLEWICK FZE,DUBAI vs. ACIT,INTERNATIONAL TAXATION, CIRCLE-1(1), CHENNAI

In the result, the appeal filed by the assessee is allowed

68 SOT 178\n(Mumbai) [13-02-2015] discussed herein supra. Under section 90(2),\nwhere the government has entered into a tax treaty with any tax\njurisdiction, the provisions of Income Tax Act shall apply to the extent they\nare more beneficial to such assesses to whom such treaty applies. In my\nconsidered view, where there

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

144C of the Income-tax Act, 1961 (“Act”) is not in accordance with the law, contrary to the facts and circumstances of the present case and is in violation of principle of equity and natural justice. Validity of the Assessment Proceedings 2. The AO erred in passing the assessment order in the name of a non-existent company and hence

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

144C of the Income-tax Act, 1961 (“Act”) is not in accordance with the law, contrary to the facts and circumstances of the present case and is in violation of principle of equity and natural justice. Validity of the Assessment Proceedings 2. The AO erred in passing the assessment order in the name of a non-existent company and hence

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

144C of the Income-tax Act, 1961 (“Act”) is not in accordance with the law, contrary to the facts and circumstances of the present case and is in violation of principle of equity and natural justice. Validity of the Assessment Proceedings 2. The AO erred in passing the assessment order in the name of a non-existent company and hence

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

144C of the Income-tax Act, 1961 (“Act”) is not in accordance with the law, contrary to the facts and circumstances of the present case and is in violation of principle of equity and natural justice. Validity of the Assessment Proceedings 2. The AO erred in passing the assessment order in the name of a non-existent company and hence

M/S. STANADYNE INDIA PVT. LTD.,TIRUVALLUR vs. ACIT, CC-IV(4), CHENNA

In the result, the appeal filed by the assessee is allowed

144C(3) of the Income-tax\nAct, 1961 (hereinafter “the Act”) on 28.01.2011.\n2. The grounds of appeal raised by the assessee are as under:\n1. The order of the Commissioner of Income Tax (Appeals)\n[“CIT(A)"] is contrary to law, facts and circumstances of the case.\n2. Set off of unabsorbed depreciation before allowing deduction\nunder Section

MUTHUKRISHNAN KUMARESAN,CHENNAI vs. ITO, INTERATIONAL TAXATION WARD-1(2), CHENNAI

The appeal stand allowed for statistical purposes

sections": ["68", "143(3)", "144C"], "issues": "Whether to condone the delay in filing the appeal and whether to grant

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE LTU-1, CHENNAI, NUNGAMBAKKAM vs. ORIENT GREEN POWER COMPANY LIMITED , CHENNAI

In the result, appeal filed by the assessee is allowed

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

68,141/-. During the course of assessment proceedings, the AO made reference to TPO for determining arm’s length price of specified domestic transaction. The TPO, Chennai passed an order u/s.92CA(3) on 30.10.2017 disallowing Rs.4,04,49,600/-. Subsequently, the AO has completed the assessment u/s.143(3) r.w.s 92CA r.w.s 144C(1) on 29.01.2018 by making following additions

COASTAL ENERGY PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2305/Chny/2012 िनधा"रण वष"/Assessment Year: 2008-09 Coastal Energy Private Limited, Vs. The Assistant Commissioner Of 5, Buhari Buildings, Moores Road, Income Tax, Thousand Lights, Chennai 600 006. Company Circle I(3), Chennai. [Pan: Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 06.02.2026 आदेश /O R D E R

144C(13) and 92CA(3) of the Act dated 19.10.2012, made an addition of ₹6,05,31,118/- on account of transfer pricing adjustment for international transactions. 28. The ld. AR submits that the assessee had entered into international transactions involving the purchase of coal from its Associated Enterprise (AE). In the course of the transfer pricing assessment

PRODAPT SOLUTIONS PVT LTD.,CHENNAI vs. DCIT, CHENNAI

In the result the appeal of the assessee is allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./Ita Nos.: 1015/Mds/2015 िनधा"रण वष" / Assessment Years : 2010-11 M/S. Prodapt Solutions Pvt Ltd., The Deputy Commissioner Of No.9, Seshadri Road, V. Income Tax, Alwarpet, Corporate Circle –5(2), Chennai – 600 018. Chennai – 600 034. Pan : Aaacz0985G (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri Vikram Vijayaraghavan, Advocate ""यथ" क" ओर से/Respondent By : Shri Vivekanandan, Cit सुनवाई क" तार"ख/Date Of Hearing : 24.10.2016 घोषणा क" तार"ख/Date Of Pronouncement : 16.01.2017

144C(13) of the Act passed in pursuance to the directions of the DRP, Chennai in F.No.DRP/CHE/81/2014-15 dated 15.12.2014. 2. The assessee has raised the grounds on CIT(Appeals), 2.1 The Ld. Assessing Officer erred is not considering the fact that the assessee is eligible for deduction under Section 10A of the Income Tax Act, 1961 (in short

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

In the result, all the captioned appeals (ITA Nos

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 MAP\n\nWhile the Assessee challenged the said assessment order before the\nHon'ble Income Tax Appellate Tribunal (ITAT

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

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 4 of 10\nITA Nos.1519, 1520, 1521, 1522, 1523, 1524, 1525, 1526 & 1527/CHNY/2025\nAYs

ITO INT TAXN WARD, , TUTICORIN CHENNAI vs. SHRI ABDUL RAHMAN VISWA ABDUL SALAM, CHENNAI

In the result appeal of the Revenue is dismissed

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.654/Chny/2023 निर्धारण वर्ा /Assessment Years: 2014-15 Income-Tax Officer, Shri Abdul Rahman Viswas Abdul International Taxation Ward, Salam, No.64/114, Kalvath Nayagam Tuticorin, Tamil Nadu Street, Kadayanallur, Tenkasi Dist, Tn-627751 [Pan: Apppa9666L] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Mr.Abhishek Murali, Ca प्रत्यर्थी की ओर से /Respondent By : Shri Arv Srinivasan, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 04.06.2024 घोषणा की तारीख /Date Of Pronouncement : 12.06.2024

144C(3) dated 30.05.2022 was passed by the assessing officer determining total income of the assesse at Rs.1,85, 36,283/- against returned income of :- 2 -: Rs.12,96,620/- after making an addition of Rs.1,68,12,289/- under the head salary and Rs.4,27,374/- as income from other sources. 3.0 Brief factual matrix of the case as available

H S I AUTOMOTIVES PRIVATE LIMITED,KANCHEEPURAM vs. DCIT CORPORATE CIRCLE 2(2), CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपील सं./I.T.A No.:276/Chny/2017 िनधा"रण वष"/Assessment Year: 2012 - 2013 & आयकर अपील सं./I.T.A No.:3011/Chny/2017 िनधा"रण वष"/Assessment Year: 2013 - 2014

144C(13) of the Act. Both the orders are pursuant from the orders of the learned Dispute Resolution Panel-2, Bengaluru passed u/s.144C(5) of the Act (in brevity “The DRP”). Both the orders are the same and are having the same kind of issues and hence we are clubbing all the issues together and disposing off the issues accordingly

HSI AUTOMOTIVES PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeals of the Assessee in I

Bench: Shri G. Manjunatha & Shri Anikesh Banerjeeआयकर अपील सं./I.T.A No.:276/Chny/2017 िनधा"रण वष"/Assessment Year: 2012 - 2013 & आयकर अपील सं./I.T.A No.:3011/Chny/2017 िनधा"रण वष"/Assessment Year: 2013 - 2014

144C(13) of the Act. Both the orders are pursuant from the orders of the learned Dispute Resolution Panel-2, Bengaluru passed u/s.144C(5) of the Act (in brevity “The DRP”). Both the orders are the same and are having the same kind of issues and hence we are clubbing all the issues together and disposing off the issues accordingly

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

In the result, all the appeals filed by the assessee stands allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 144C (1) of the Income Tax Act, 1961 (in short 'Act). This order has been passed consequent upon a remand by the Income Tax Appellate Tribunal (in short "Tribunal/ITAT) on 16.11.2022. The Tribunal has, therein, confirmed the findings of the Assessing Officer to the effect that the petitioner has a Permanent Establishment (PE) in India. However, the question

M/S.REDINGTON DISTRIBUTORS PTE LTD.,SINGAPORE vs. ACIT, INTL TAXATION CIRCLE-2(1), CHENNAI

In the result, all the appeals filed by the assessee stands allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 144C (1) of the Income Tax Act, 1961 (in short 'Act). This order has been passed consequent upon a remand by the Income Tax Appellate Tribunal (in short "Tribunal/ITAT) on 16.11.2022. The Tribunal has, therein, confirmed the findings of the Assessing Officer to the effect that the petitioner has a Permanent Establishment (PE) in India. However, the question

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

In the result, all the appeals filed by the assessee stands allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 144C (1) of the Income Tax Act, 1961 (in short 'Act). This order has been passed consequent upon a remand by the Income Tax Appellate Tribunal (in short "Tribunal/ITAT) on 16.11.2022. The Tribunal has, therein, confirmed the findings of the Assessing Officer to the effect that the petitioner has a Permanent Establishment (PE) in India. However, the question

M/S.REDINGTON DISTRIBUTIONS PTE LTD.,SINGAPORE vs. ACIT, INTLTAXATION CIRCLE-2(1), CHENNAI

In the result, all the appeals filed by the assessee stands allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 144C (1) of the Income Tax Act, 1961 (in short 'Act). This order has been passed consequent upon a remand by the Income Tax Appellate Tribunal (in short "Tribunal/ITAT) on 16.11.2022. The Tribunal has, therein, confirmed the findings of the Assessing Officer to the effect that the petitioner has a Permanent Establishment (PE) in India. However, the question