RENAULT INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No. 1078/Mds/2017 "नधा"रण वष" /Assessment Year : 2012-2013. M/S. Renault India Private Vs. The Deputy Commissioner Of Limited, Income Tax, No.37 & 38, Asv Ramana Corporate Circle 5(1) Towers, Chennai. 4Th Floor, Venkatnarayana Road, T.N Agar, Chennai 600 017. [Pan Aadcr 2042M ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

68,89,614 When a proposal on the above lines was put by the ld. 8. Assessing Officer to the assessee, assessee preferred to move to ld. DRP. Contention of the assessee before the ld. DRP with regard to the above issue were as under:- ‘’Objection 1 - The order of the Ld. TPO/AO are contrary to the law, facts

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...

92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets

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...

92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets

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...

92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets

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...

92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets

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...

92C, 92D and 92E, "international transaction'' means a transaction between two or more associated enterprises, either or both of whom are non-residents, in the nature of purchase, sale or lease of tangible or intangible property, or provision of services, or lending or borrowing money, or any other transaction having a bearing on the profits, income, losses or assets

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

92C(2) of the Act. 29. The DRP in its direction to Assessing Officer dated 31.08.2012, allowed the benefit of the credit notes except in one case where the credit note was erroneously dated before the date of invoice. In this regard, the ld. AR submits that the DRP/Assessing Officer has erred both in law and on facts by disregarding

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,TIRUPPUR, TIRUPPUR vs. PRABHU SPINNING MILLS PRIVATE LIMITED, TIRUPPUR

In the result all the grounds raised by the revenue for the A

68,67,372/- for the whole of the year.\n6. It may be noted that the assessee claimed a deduction u/s.80-IA of the Act to\nthe tune of Rs.18,41,58,470/- and the AO vide assessment order passed\nu/s.143(3)r.w.s.144C(3)r.w.s.144B dated 11.06.2021 in accordance with the value\ndetermined by TPO determined the ALP of the inter

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPUR vs. SRI SHANMUGAVEL MILLS PRIVATE LIMITED, TIRUPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

92C of the Act and therefore, also, this judgment is not applicable to the facts of the case." 7. The Ld.DR based on the above decision submitted that the Hyderabad Bench of the Tribunal has taken into account the change in law and held that the ALP is to be determined u/s.92F by the mechanism prescribed u/s.92C and Rule

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

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

section 92C(4) of the Act. 3.2 On appeal, it was the submission before the ld. CIT(A) that the assessee company's transactions with Associate Enterprise (AE) had not resulted in any adjustment of income between the assessee company and the AE. Further, it was submitted that the entire income /expenditure of the AE had been passed

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

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

section 92C(4) of the Act. 3.2 On appeal, it was the submission before the ld. CIT(A) that the assessee company's transactions with Associate Enterprise (AE) had not resulted in any adjustment of income between the assessee company and the AE. Further, it was submitted that the entire income /expenditure of the AE had been passed

DCIT, CHENNAI vs. THE OFFICIAL LIQUIDATOR M/S. MASCON GLOBAL LTD. (IN LIQUIDATION), CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

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

section 92C(4) of the Act. 3.2 On appeal, it was the submission before the ld. CIT(A) that the assessee company's transactions with Associate Enterprise (AE) had not resulted in any adjustment of income between the assessee company and the AE. Further, it was submitted that the entire income /expenditure of the AE had been passed

ACIT, CHENNAI vs. M/S. MASCON GLOBAL LTD., CHENNAI

Accordingly, the ground raised by the Revenue is dismissed

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

section 92C(4) of the Act. 3.2 On appeal, it was the submission before the ld. CIT(A) that the assessee company's transactions with Associate Enterprise (AE) had not resulted in any adjustment of income between the assessee company and the AE. Further, it was submitted that the entire income /expenditure of the AE had been passed

EVERSENDAI CONSTRUCTION PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1), CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2084/Chny/2017 िनधा"रण वष" /Assessment Year: 2013-14 M/S.Eversendai Construction- V. The Dy. Commissioner- Pvt. Ltd., Of Income Tax, Plot No.1 & 2, The Lords, Corporate Circle-2(1), Block-1, 5Th Floor, Chennai. Thiru-Vi-Ka Industrial Estate, Jawaharlal Nehru Road, Ekkaduthangal, Guindy, Chennai.

68,80,440108.96/103.35=16,53,96,156 +3% range = Rs.15,21,740,268 to Rs.16,15,86,853. Adjustment to be made is Rs.85,15,716 16. The ALP for the sales calculated on an international transaction of EPC segment has not been determined by the assessee company in accordance with section 92C

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 3(3), CHENNAI., CHENNAI vs. M/S. CATERPILLAR INDIA PVT. LTD , CHENNAI

Appeal is dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपीलसं./It(Tp)A No.: 42/Chny/2023 िनधा"रण वष" / Assessment Year: 2014-15 M/S.Caterpillar India Private Limited, The Deputy Commissioner Of 7Th Floor, International Tech Park, Income Tax, Taramani Road, Vs. Central Circle- 3(3), Chennai – 600 113. Chennai – 600 034. [Pan:Aabcc-4615-K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपीलसं./Ita No.: 717/Chny/2023 िनधा"रण वष" / Assessment Year: 2014-15 The Deputy Commissioner Of Income M/S.Caterpillar India Private Tax, Limited, 7Th Floor, International Tech Park, Central Circle- 3(3), V. Chennai – 600 034. Taramani Road, Chennai – 600 113. [Pan:Aabcc-4615-K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Assessee By : Shri Harish Ramanathan, C.A. By Virtual ""थ" की ओर से/Department By : Shri A. Sasikumar, C.I.T. सुनवाई की तारीख/Date Of Hearing : 12.03.2025 घोषणा की तारीख/Date Of Pronouncement : 06.06.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: These Cross Appeals Filed By The Assessee & The Revenue Are Arising Out Of Order Of Commissioner Of Income Tax (Appeals)-18, Chennai U/S. 143(3) R.W.S. 92Ca (3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) For The Assessment Year 2014-15 Dated 07.03.2023. Since, Facts Are Identical & Issues Are Common, For :-2-: It(Tp) A. No:42 /Chny/2023 & The Sake Of Convenience, The Appeal Filed By The Revenue & Assessee Are Being Heard Together & Disposed Off, By This Consolidated Order.

92C(3) of the Act were satisfied and erroneously disregarded the TP study maintained by the Appellant as per Section 92D of the Act read with rule 10D of the Income-tax Rules, 1962 (‘the Rules). On the facts and in the circumstances of the case and in law, the Ld. CIT(A) / Ld. TPO / Ld. AO erred

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPPUR vs. PRABHU SPINNING MILLS PRIVATE LIMITED, TIRUPPUR

In the result all the grounds raised by the revenue for the A

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 Prabhu Spining Mills Private 121, Adarns Plaza, Vs. Limited, 60, Feet Road, No. 207 – 86, Mangalam Road, Tiruppur – 641 602. Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. (अपीलाथी/Appellant) [Pan:Aabcp-0750-E] (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यथी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

68,67,372/- for the whole of the year. 6. It may be noted that the assessee claimed a deduction u/s.80-IA of the Act to the tune of Rs.18,41,58,470/- and the AO vide assessment order passed u/s.143(3)r.w.s.144C(3)r.w.s.144B dated 11.06.2021 in accordance with the value determined by TPO determined the ALP of the inter

DAESEUNG AUTOPARTS INDIA PRIVATE LIMITED,KANCHEEPURAM vs. ACIT (OSD), CHENNAI

The appeal stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.752/Chny/2017 (िनधा;रणवष; / Assessment Year: 2012-13) M/S. Daeseung Autoparts India Pvt. Ltd. Acit (Osd) Plot No,474, Mannur Village, Corporate Range-1, बनाम/ Vs. Valarpuram Post, Sriperumpudhur Taluk Chennai. Kanchipuram- 602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccd-5629-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Vikram Vijayaraghavan (Advocate)- Ld. Ar " थ"कीओरसे/Respondent By : Shri G. Suresh (Jcit)- Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 28-05-2024 घोषणा की तारीख /Date Of Pronouncement : 04-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

68,09,336 to the arm's length price of the international transactions undertaken by the Appellant. Economic analysis 3. The Learned TPO/AO and the DRP erred, in law and in facts by rejecting the detailed transfer pricing documentation prepared by the Appellant in accordance with the provisions of the Income tax Act, 1961 (the Act) and proceeded to undertake

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

Section 92C(2) of the Act, the standard deduction of +/- 5% should be allowed. 3. In Corporate Tax, the following issues were added, such as payment of Provident Fund and Employees State Insurance, Guarantee Fee payment and applicability of TDS and other expenses. The learned Transfer Pricing Officer [TPO] made a downward adjustment of Rs.35,78.19,630/-. Subsequently