SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 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 Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section 14A

SHRIRAM CAPITAL LTD,CHENNAI vs. DCIT, CORP CIR-6(1), CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 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 Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section 14A

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 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 Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section 14A

DCIT, CORP CIR-6(1), CHENNAI vs. SHRIRAM CAPITAL LTD, CHENNAI

In the result, both the appeals filed by the assessee are allowed and the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.3168 & 3255/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 M/S. Shriram Capital Limited, The Deputy Commissioner Of Vs. Shriram House, 1St Floor, No. 4, Income Tax, Burkit Road, T. Nagar, Corporate Circle 6(1), Chennai 600 017. Chennai 600 034. [Pan:Aabcs2726B] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. Nos.3216 & 3217/Chny/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2014-15 The Deputy Commissioner Of Vs. M/S. Shriram Capital Limited, Shriram House, 1St Floor, No. 4, Income Tax, Corporate Circle 6(1), Burkit Road, T. Nagar, Chennai 600 034. Chennai 600 017. (अपीलाथ"/Appellant) (""थ"/Respondent) Assessee By : Shri R. Sivaraman, Advocate Department By Shri Darzakhum Songate, Cit : सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 18.02.2022 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 Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai Dated 29.08.2018 Relevant To The 2

68,173/- and the assessee has disallowed ₹.73,037/- towards expenses incurred for earning the exempt income. However, the Assessing Officer disallowed additional amount of ₹.11,40,06,138/- under section 14A

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

14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued by its subsidiaries aggregating

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

14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued by its subsidiaries aggregating

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

14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued by its subsidiaries aggregating

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

14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued by its subsidiaries aggregating

UNIPRES INDIA PVT. LTD.,KANCHEEPURAM vs. ITO, CORPORATE WARD - 3 (2),, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा'रण वष' /Assessment Year: 2014-15

68,865/- (iii) One half per cent of average value of investment, income from which does not or shall not form part of the total income, as appearing in the Balance Sheet of the assessee, on the first day and the last day of the previous year Rs.2,32,260/- Disallowance under section 14A

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

section 14A is applicable prospectively from with effect from 1.4.2022 and not for the year under appeal. 3.3. Without prejudice to above grounds, even if Rule 8D is held as applicable, investments from which no dividend income is earned should not be considered while applying Rule 8D as held in Appellant's own case

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nआयकर अपील सं./ITA No.1402/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nM/s. Ashok Leyland Ltd.,\nNo.1, Sardar Patel Road,\nGuindy, Chennai-600 032.\n[PAN: AAAСА 4651 L]\n(अपीलार्थी/Appellant)\nv.\nThe DCIT,\nNCC-8(1),\nLTU-II,\nChennai.\n(प्रत्यर्थी/Respondent)\nआयकर अपील सं./ITA No.1663/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nThe DCIT,\nNCC-8,\nChennai.\n(अपीलार्थी/Appellant)\nv.\nM/s. Ashok Leyl

14A is applicable prospectively from with effect from 1.4.2022\nand not for the year under appeal.\n3. 3. Without prejudice to above grounds, even if Rule 8D is held as\napplicable, investments from which no dividend income is earned should\nnot be considered while applying Rule 8D as held in Appellant's own\ncase

DCIT, TRICHY vs. M/S. THE KARUR VYSYA BANK. LTD., KARUR

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

Section 14A of the Act for the impugned assessment year also. 61. Ground No.2 is allowed. 62. Grounds Nos.3 and 4 of the assessee are similar to the grounds 3 & 4 raised by the assessee for assessment year 2010-11. Accordingly for the same reasons mentioned at para 17 & 18 above, we remit the issue raised by the assessee

THE KARUR VYSYA BANK LTD.,KARUR vs. JCIT, TRICHY

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

Section 14A of the Act for the impugned assessment year also. 61. Ground No.2 is allowed. 62. Grounds Nos.3 and 4 of the assessee are similar to the grounds 3 & 4 raised by the assessee for assessment year 2010-11. Accordingly for the same reasons mentioned at para 17 & 18 above, we remit the issue raised by the assessee

DCIT, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

Section 14A of the Act for the impugned assessment year also. 61. Ground No.2 is allowed. 62. Grounds Nos.3 and 4 of the assessee are similar to the grounds 3 & 4 raised by the assessee for assessment year 2010-11. Accordingly for the same reasons mentioned at para 17 & 18 above, we remit the issue raised by the assessee

THE KARUR VYSYA BANK LTD.,KARUR vs. JCIT, TRICHY

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

Section 14A of the Act for the impugned assessment year also. 61. Ground No.2 is allowed. 62. Grounds Nos.3 and 4 of the assessee are similar to the grounds 3 & 4 raised by the assessee for assessment year 2010-11. Accordingly for the same reasons mentioned at para 17 & 18 above, we remit the issue raised by the assessee

M/S. XS REAL PROPERTIES PVT LTD. ,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal in I

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 41 & 42/Chny/2019 िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15 M/S. Xs Real Properties P. Ltd., The Assistant Commissioner Of No. 12, South Mada Street, Vs. Income Tax, Corporate Circle 3(2), Srinagar Colony, Saidapet, Chennai. Chennai 600 015. [Pan:Aaacx0030G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj, C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 7, Chennai, Both Dated 28.09.2018 Relevant To The Assessment Years 2013-14 & 2014-15. Since The Assessee Has Raised Common Grounds, Both The Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

section 14A r.w. Rule 8D, the Assessing Officer determined the expenditure attributable for earning such exempt income by applying Rule 8D(2)(ii) at ₹.77,02,566/- and Rule 8D(2)(iii) at ₹.14,68

M/S. XS REAL PROPERTIES PVT LTD. ,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal in I

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos. 41 & 42/Chny/2019 िनधा"रण वष"/Assessment Years: 2013-14 & 2014-15 M/S. Xs Real Properties P. Ltd., The Assistant Commissioner Of No. 12, South Mada Street, Vs. Income Tax, Corporate Circle 3(2), Srinagar Colony, Saidapet, Chennai. Chennai 600 015. [Pan:Aaacx0030G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjunraj, C.A. For Shri S. Sridhar, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 02.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 7, Chennai, Both Dated 28.09.2018 Relevant To The Assessment Years 2013-14 & 2014-15. Since The Assessee Has Raised Common Grounds, Both The Appeals Were Heard Together & Are Being Disposed Of By This Common Order.

section 14A r.w. Rule 8D, the Assessing Officer determined the expenditure attributable for earning such exempt income by applying Rule 8D(2)(ii) at ₹.77,02,566/- and Rule 8D(2)(iii) at ₹.14,68

K.BADAL BAI L/H OF LATE SRI A.KEWALCHAND,GUDIYATHAM vs. ACIT, VELLORE

In the result, the assessee’s appeal is allowed/ treated as allowed

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

section 40A (3), 14A and the gross agricultural income treated as income from other sources was confirmed by the learned CIT(A). 2. Ground No. 2.1 and 2.2 of the appeal deals with the addition of Rs.28,68