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

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 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

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

8 I.T.A. No.2305/Chny/12 to the sale of goods to end customers, such risks cannot be automatically passed on to the AE, and there is no obligation or commercial basis to raise a corresponding debit note for every debit note issued by a customer. Accordingly, the debit note of ₹2.34 crores raised on the AE reflects only those cases where

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.

144C(13) of the Income-tax Act, 1961 ('the Act') is bad in law and is contrary to the facts and circumstances of the present case. The detailed grounds of appeal being independent and without prejudice to one another, including the position in law and facts is set out in the ensuing paragraphs. 2. Ground 2 Addition of Guarantee Fees

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

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

144C(13) of the Income Tax Act, 1961 (hereinafter called 'the Act'). The relevant Assessment Year is 2018-19. 2. Brief facts of the case are as follows: The assessee is a company incorporated in UAE. During the assessment year 2018-19, the assessee was in receipt of income of Rs.90 lakhs from an Indian customer named M/s. Gannon Dunkerley

COASTAL ENERGY PVT LTD.,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

In the result, both the appeals filed by the assessee as well as Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1337/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 M/S. Coastal Energy Pvt. Ltd., Vs. The Deputy Commissioner Of No. 4, Buharia Towers, 5Th Floor, Income Tax, Moores Road, Chennai 600 006. Corporate Circle 1(2), Chennai. [Pan:Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1354/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. M/S. Coastal Energy Pvt. Ltd., No. 4, Buharia Towers, 5Th Floor, Income Tax, Central Circle 1(1), Moores Road, Chennai 600 006. Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Department By : Shri R. Mohan Reddy, Cit सुनवाई की तारीख/ Date Of Hearing : 26.06.2023 घोषणा की तारीख /Date Of Pronouncement : 06.09.2023 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax

144C(5) dated 31. 08.2012 revised the adjustments made in the TPO. Consequently, the TPO, in its order dated 07.09.2012 made a revision to the downward adjustment of Rs.3,07,39,105/- to the purchases. Finally, the total income Was assessed u/s. 143(3) r.w.s. 92CA(3) on 19.10.2013, assessing the total income as Rs.29,52,99,177/-. On verification

DCIT CENTRAL CIRCLE 1(1), CHENNAI vs. COASTAL ENERGY PVT LTD., CHENNAI

In the result, both the appeals filed by the assessee as well as Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1337/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 M/S. Coastal Energy Pvt. Ltd., Vs. The Deputy Commissioner Of No. 4, Buharia Towers, 5Th Floor, Income Tax, Moores Road, Chennai 600 006. Corporate Circle 1(2), Chennai. [Pan:Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No.1354/Chny/2018 िनधा"रण वष"/Assessment Year: 2009-10 The Deputy Commissioner Of Vs. M/S. Coastal Energy Pvt. Ltd., No. 4, Buharia Towers, 5Th Floor, Income Tax, Central Circle 1(1), Moores Road, Chennai 600 006. Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri B. Ramakrishnan, Fca Department By : Shri R. Mohan Reddy, Cit सुनवाई की तारीख/ Date Of Hearing : 26.06.2023 घोषणा की तारीख /Date Of Pronouncement : 06.09.2023 आदेश /O R D E R Per V. Durga Rao: Both The Cross Appeals Filed By The Assessee As Well As Revenue Are Directed Against The Order Of The Ld. Commissioner Of Income Tax

144C(5) dated 31. 08.2012 revised the adjustments made in the TPO. Consequently, the TPO, in its order dated 07.09.2012 made a revision to the downward adjustment of Rs.3,07,39,105/- to the purchases. Finally, the total income Was assessed u/s. 143(3) r.w.s. 92CA(3) on 19.10.2013, assessing the total income as Rs.29,52,99,177/-. On verification

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 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 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 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

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

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

Section 144C(2) of the Income-tax Act, 1961, On receipt of the draft order, the eligible assessee shall, within thirty days of the receipt by him of the draft order,- (a) File his acceptance of the variations to the Assessing Officer; or (b) File his objections, if any, to such variation with,- (i) the Dispute Resolution Panel

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