VODAFONE SOUTH LIMITED,CHENNAI vs. ITO TDS, CHENNAI

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

68,29,295/- 2009-10 2010-11 ₹. 2,96,96,493/- Vodafone Mobile Services Limited 2011-12 2012-13 ₹. 67,72,18,080/- 2013-14 2014-15 ₹. 38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

68,29,295/- 2009-10 2010-11 ₹. 2,96,96,493/- Vodafone Mobile Services Limited 2011-12 2012-13 ₹. 67,72,18,080/- 2013-14 2014-15 ₹. 38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

68,29,295/- 2009-10 2010-11 ₹. 2,96,96,493/- Vodafone Mobile Services Limited 2011-12 2012-13 ₹. 67,72,18,080/- 2013-14 2014-15 ₹. 38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

68,29,295/- 2009-10 2010-11 ₹. 2,96,96,493/- Vodafone Mobile Services Limited 2011-12 2012-13 ₹. 67,72,18,080/- 2013-14 2014-15 ₹. 38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section

VODAFONE MOBILE SERVICES LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

68,29,295/- 2009-10 2010-11 ₹. 2,96,96,493/- Vodafone Mobile Services Limited 2011-12 2012-13 ₹. 67,72,18,080/- 2013-14 2014-15 ₹. 38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section

VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

68,29,295/- 2009-10 2010-11 ₹. 2,96,96,493/- Vodafone Mobile Services Limited 2011-12 2012-13 ₹. 67,72,18,080/- 2013-14 2014-15 ₹. 38,81,04,344/- By holding that the discount offered by the assessee to their distributors as commission, the Assessing Officer held that the assessee was in default under section

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

194J and such failure attracts the consequential non-deductibility of the amounts as per section 40(a)(ia) of the IT Act. The payments mentioned supra have been made by the assessee M/s Royal Sundaram Alliance Insurance Company Limited to various Hospital/Insured person of the time of credit of the said sum and payment failed to deduct

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

194J and such failure attracts the consequential non-deductibility of the amounts as per section 40(a)(ia) of the IT Act. The payments mentioned supra have been made by the assessee M/s Royal Sundaram Alliance Insurance Company Limited to various Hospital/Insured person of the time of credit of the said sum and payment failed to deduct

ROYAL SUNDARAM GENERAL INSURANCE COMPANY LTD,CHENNAI vs. DCIT, LTU, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

In the result, the appeals of the assesse and Revenue are dealt as under:-

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.86, 87, 88, 89, 90, 91, 92 & 93 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2009-10, 2010-11, 2011-12, 2011-12, 2012-13, 2013-14, 2014-15, M/S.Royal Sundaram General Dy. Commissioner Of Income Tax, Insurance Company Limited, Large Tax Payer Unit, Vishranthi Melaram Towers, Chennai. No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] आयकर अपील सं./Ita Nos.491, 492, 493, 494, 495 & 496 /Chny/2018 निर्धारण वर्ा /Assessment Years: 2008-09, 2010-11, 2011-12, 2012-13, 2013-14, 2014-15 Dy. Commissioner Of Income Tax, M/S.Royal Sundaram General Large Tax Payer Unit, Insurance Company Limited, Chennai. Vishranthi Melaram Towers, No.2/319, Rajiv Gandhi Salai(Omr), Karapakkam, Chennai-600 097. [Pan: Aabcr7106G] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : Shri Vikaram Vijayaraghavan, Advocate अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By : Shri A.Sanjay For Ms V.Pushpa, Sr.Standing Counsel For It Dept. सुनवाई की तारीख/Date Of Hearing : 15.10.2024 घोषणा की तारीख /Date Of Pronouncement : 08.01.2025

194J and such failure attracts the consequential non-deductibility of the amounts as per section 40(a)(ia) of the IT Act. The payments mentioned supra have been made by the assessee M/s Royal Sundaram Alliance Insurance Company Limited to various Hospital/Insured person of the time of credit of the said sum and payment failed to deduct

DCIT LTU 1, CHENNAI vs. M/S ROYAL SUNDARAM GENERAL INSURANCE COMPANY LIMITED, CHENNAI

194J and such failure attracts the\nconsequential non-deductibility of the amounts as per section 40(a)(ia) of the IT\nAct.\nThe payments mentioned supra have been made by the assessee M/s Royal\nSundaram Alliance Insurance Company Limited to various Hospital/Insured person\nof the time of credit of the said sum and payment failed to deduct

JCIT (OSD), CHENNAI vs. SIFY TECHNOLOGIES LIMITED, CHENNAI

In the result, the Revenue’s appeals in ITA Nos

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं/.I.T.A. No. 1650/Chny/2017 "नधा"रण वष"/Assessment Year : 2010-11 Deputy Commissioner Of Income M/S. Sify Technologies Ltd., Tidel Park, 2Nd Floor, Tax, Vs. Large Taxpayer Unit – 1, No.4, Canal Bank Road, Chennai – 600 101. Taramani, Chennai – 600 113. [Pan: Aaacs 9032R] (%&यथ'/Respondent) (अपीलाथ"/Appellant) आयकर अपील सं/.I.T.A. Nos. 1793, 1794 & 1795/Chny/2016 "नधा"रण वष"/Assessment Years : 2009-10, 2010-11 & 2011-12 Joint Commissioner Of Income Tax Vs. M/S. Sify Technologies Ltd., Tidel Park, 2Nd Floor, (Osd), Large Taxpayer Unit – 1, No.4, Canal Bank Road, Chennai – 600 034 Taramani, Chennai – 600 113. [Pan: Aaacs 9032R] (%&यथ'/Respondent) (अपीलाथ"/Appellant)

194J and therefore, the disallowance u/s 40(a)(ia) was justified. 4.3 It is submitted that the decision of the CIT(A) for the AY 2005-06 in assessee’s own case on a similar issue was taken up in appeal before the ITAT and against the adverse decision of the ITAT, the matter has been taken in appeal