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)

68,54,664 Ld. Assessing Officer referred the Arms Length Price 5. determination to the ld. Transfer Pricing Officer (herein after referred to as ‘’the TPO ‘’) in accordance with Section

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing on the nature of AMP spend holding it to be an international transaction. nature of AMP spend holding it to be an international transaction. 8.2 It is not correct to say that brand promotion expenses have not benefitted .2 It is not correct to say that brand promotion expenses have not benefitted .2 It is not correct

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

M/S. STERLITE INDUSTRIES (INDIA) LTD.,MADURAI vs. ADDITIONAL CIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

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

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

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

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

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

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

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

Transfer Pricing Officer-III, Chennai as required under section 92CA(1) of the Act. The TPO determined the arms length price at ₹. 239.54 crores and shortfall in the operating profit at ₹. 32.63 crores. This shortfall was directed to be brought to tax as per section 92C(4) of the Act. 3.2 On appeal, it was the submission before

DEPUTY COMMISSIONER OF INCOME-TAX, CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. MS DAR PARADISE PVT. LTD., COIMBATORE

In the result, appeal filed by the revenue is dismissed

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1106/Chny/2023 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. Dar Paradise Pvt. Ltd., Income Tax, V. 599, Raja Street, Corporate Circle -1, Coimbatore – 641 001. Coimbatore. [Pan: Aafcd-3066-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. R. Clement Ramesh Kumar, Cit ""यथ" क" ओर से/Respondent By : Shri. N. Arjun Raj, Ca सुनवाई क" तारीख/Date Of Hearing : 05.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 21.03.2024

price. All the trade advance have been transferred to Sales Account and formed part of the profit and loss account and offered for taxation. The moment they were shown as sales and offered as income, onus part is completely discharged. The appellant has further submitted that the total gold advances received before demonetization and which were converted into gold sales

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

Transfer Pricing Orders for Assessment Years 2013-14 and 2014-15 are 01.02.2017 and 20.12.2018 respectively, well after the search.\n8.1 In such cases, it is now settled law by authoritative pronouncements of the hon'ble Supreme Court that any assessments under Sections 153A/153C in respect of unabated assessments must be based on incriminating materials obtained during search proceeding

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

price of the corporate guarantee at 3 percent seems unreasonable. However, in this connection additional evidence furnished by the assessee that IDBI Bank Ltd has charged 1 percent guarantee commission to S Tel Pvt Ltd for the relevant FY 2008-09 appears reasonable. Therefore, the TPO is directed to verify the additional evidence furnished by the assessee. In case

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

price of the corporate guarantee at 3 percent seems unreasonable. However, in this connection additional evidence furnished by the assessee that IDBI Bank Ltd has charged 1 percent guarantee commission to S Tel Pvt Ltd for the relevant FY 2008-09 appears reasonable. Therefore, the TPO is directed to verify the additional evidence furnished by the assessee. In case

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

price of the corporate guarantee at 3 percent seems unreasonable. However, in this connection additional evidence furnished by the assessee that IDBI Bank Ltd has charged 1 percent guarantee commission to S Tel Pvt Ltd for the relevant FY 2008-09 appears reasonable. Therefore, the TPO is directed to verify the additional evidence furnished by the assessee. In case

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

price of the corporate guarantee at 3 percent seems unreasonable. However, in this connection additional evidence furnished by the assessee that IDBI Bank Ltd has charged 1 percent guarantee commission to S Tel Pvt Ltd for the relevant FY 2008-09 appears reasonable. Therefore, the TPO is directed to verify the additional evidence furnished by the assessee. In case

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

transferred from section 80-IA eligible windmill division of the assessee to the textile division of the assessee at Rs.10,69,94,336/-. The assessee on the other hand had taken the selling price of TANGEDCO to any other high tension industrial consumers :-3-: ITA. No: 433 & 435/Chny/2025 being Rs.6.35 per unit of electricity which effectively translated into Rs.27,68