INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

PHILIPS FOODS INDIA PRIVATE LIMITED,TUTICORIN vs. PCIT-1, MADURAI

In the result, the appeal of the assesse is allowed

additional / joint CIT (Transfer Pricing) 2(2),\nChennai who in turn reports to CIT(Transfer Pricing) Chennai. Further\nCIT(Transfer Pricing) Chennai reports to Chief Commissioner of Income

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)

income, losses of the assessee and therefore could not be regarded as an losses of the assessee and therefore could not be regarded as an losses of the assessee and therefore could not be regarded as an international transaction and be benchmarked international transaction and be benchmarked under the transfer pricing under the transfer pricing provisions. In this regard

M.KIRAN KUMAR,CHENNAI vs. ACIT CENTRAL CIRCLE-1(4), CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunatha

transferred for normal business transaction and hence cannot be treated as deemed dividend in the hands of the appellant u/s.2(22)(e). 13.The Commissioner of Income Tax (Appeals) has erred in upholding, the addition made by the Assessing Officer in adding the long term capital gains of Rs.16,24,68,072/- disallowing the exempt u/s.10(38) as undisclosed income from

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 under Rule 8D(d) of Income-tax Rules, 1962. The addition made by the Assessing Officer was deleted

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 under Rule 8D(d) of Income-tax Rules, 1962. The addition made by the Assessing Officer was deleted

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 under Rule 8D(d) of Income-tax Rules, 1962. The addition made by the Assessing Officer was deleted

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 under Rule 8D(d) of Income-tax Rules, 1962. The addition made by the Assessing Officer was deleted

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 under Rule 8D(d) of Income-tax Rules, 1962. The addition made by the Assessing Officer was deleted

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 under Rule 8D(d) of Income-tax Rules, 1962. The addition made by the Assessing Officer was deleted

THIRU AROORAN SUGARS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeals for ay 2005-06 & 2006-07

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

income if the same amount is not allowed as a deduction for the assessment year 2005-06 when the provision has been made and claimed as a deduction. 3. The Appellant craves leave to file additional grounds at the time of hearing.” 3.2 We heard the rival contentions on the additional grounds and admit them on the merits canvassed above

THIRU AROORAN SUGARS LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, the assessee’s appeals for ay 2005-06 & 2006-07

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

income if the same amount is not allowed as a deduction for the assessment year 2005-06 when the provision has been made and claimed as a deduction. 3. The Appellant craves leave to file additional grounds at the time of hearing.” 3.2 We heard the rival contentions on the additional grounds and admit them on the merits canvassed above

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)

additional request from RIPL (III) major deviation of volume of RIPL versus the Agreement (IV) major unpredicted changes regarding currency rates, prices of international market commodities or inflation, and affecting significantly the price. (b)Regular adjustments RNAIPL shall be entitled to make adjustments of the reference price of the Renault Licensed Vehicle on a quarterly basis and only in accordance

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

income between the appellant and its associates to call for determination of Arm's Length Price. The appellant had submitted to the TPO that the rationale behind the Transfer Pricing Regulations is to prevent shifting out of profit by manipulating prices charged or paid in International transactions thereby eroding the Country's tax base. In the present case there

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

income between the appellant and its associates to call for determination of Arm's Length Price. The appellant had submitted to the TPO that the rationale behind the Transfer Pricing Regulations is to prevent shifting out of profit by manipulating prices charged or paid in International transactions thereby eroding the Country's tax base. In the present case there

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

income between the appellant and its associates to call for determination of Arm's Length Price. The appellant had submitted to the TPO that the rationale behind the Transfer Pricing Regulations is to prevent shifting out of profit by manipulating prices charged or paid in International transactions thereby eroding the Country's tax base. In the present case there

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

income between the appellant and its associates to call for determination of Arm's Length Price. The appellant had submitted to the TPO that the rationale behind the Transfer Pricing Regulations is to prevent shifting out of profit by manipulating prices charged or paid in International transactions thereby eroding the Country's tax base. In the present case there

K.G. DENIM LIMITED,COIMBATORE vs. DCIT, TP-2(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1718/Chny/2024 िनधा"रण वष" / Assessment Year: 2020-21 K G Denim Limited, Dcit, 1, Thenthirumalai, V. Tp-2(1), Jadayampalayam B.O., Chennai. Dhoddabavi, Coimbatore – 641 302. [Pan: Aaack-7940-C] (अपीलाथ"/Assessee) (""यथ"/Respondent) अपीलाथ" क" ओर से/Assessee By : Shri. Arjun Raj, Advocate : Shri. A. Sasikumar, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 11.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.12.2024

Income Tax (Transfer Pricing), Chennai, dated 26.04.2024 and pertains to assessment year 2020-21. 2. The assessee has raised the following grounds of appeal: “1. The revisional order of the CIT,(Transfer Pricing), Chennai dated 26.04.2024 vide DIN & Order No. ITBA/COM/F/17/2024- :-2-: ITA. No: 1718/Chny/2024 25/1064398354(1) for the above mentioned Assessment Year is contrary to law, fact

R.SRINIVASAN,CHENNAI vs. DCIT CENTRAL CIRCLE 1, COIMBATORE

In the result, appeal filed by assessee is partly allowed

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.No.1466/Chny/2018 ("नधा"रणवष" / Assessment Year: 1996-97) Mr.R.Srinivasan Vs The Deputy Commissioner Of 103, Ashok Nagar Main Road Income Tax, Kodambakkam, Corporate Circle-I(2) Chennai-600 024. Chennai. Pan : Aaips 8386H (अपीलाथ"/Appellant) (""यथ"/Respondent)

addition in the hands of the AOP has been made on the basis of total value of goods supplied by the AOP to TNTC. This amount has been determined by estimating the gross profits earned by the suppliers in respect of different items such as School Uniform, Sarees, Dhotis supplied by them 30 after taking into account the supply price