ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

price whichever is lower. The appellant\ncontended that the stand of the AO is not correct also the statement recorded\nduring the survey has no evidentiary value. The appellant also submitted that\nthis component of stock difference does not represent the value of any\nexcess quantity of stock found during the course of survey in relation to the\nstock register

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)

3). Hence the arms length price has been calculated as per culated as per the provision of sub-sections (1) and (2) of 92C and determined as Rs. sections (1) and (2) of 92C and determined as Rs. sections (1) and (2) of 92C and determined as Rs. 9,72,301 and Rs. 78,70,058 towards reimbursement of excess

ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

10 or clause (ii) or clause (iii) of sub-section (4) of section 12AB, as the\ncase may be, is received by the Assessing Officer,]\nshall be excluded:\nProvided that where immediately after the exclusion of the aforesaid period, the period of\nlimitation referred to in sub-sections (1), 32[(1A),] (2), (3) and sub-section (8) available

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

3. The PCIT failed to appreciate that revision order was passed out of time, invalid, passed without jurisdiction and not sustainable both on facts and in law. 4. The PCIT failed to appreciate that the twin conditions prescribed for assuming jurisdiction under Section 263 of the Act were not satisfied concurrently on the facts and in the circumstances

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

section 92C(3) of the Income-tax Act, 1961 ('the Act').\n3 Rejection of Transfer pricing analysis undertaken by the Appellant\n3.1 The TPO erred in rejecting the benchmarking analysis performed by the Appellant\nand incorrectly undertook a fresh benchmarking analysis.\n3.2. The TPO has erred in rejecting the benchmarking analysis prepared by the\nAppellant without appreciating the fact that

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 order u/s.92CA(3) of the Act for the AY 2013-14 was completed after the conclusion of the search, wherein the TPO proposed TP downward adjustment of Rs.407.25 crores on the imports from MIPP. The TPO did not propose any adjustment on the receipt of share capital reported in the Form 3CEB. The assessee had filed appeal against

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

section 92C(3) of the Income-tax Act, 1961 ('the Act').\n3 Rejection of Transfer pricing analysis undertaken by the Appellant\n3.1 The TPO erred in rejecting the benchmarking analysis performed by the Appellant\nand incorrectly undertook a fresh benchmarking analysis.\n3.2. The TPO has erred in rejecting the benchmarking analysis prepared by the\nAppellant without appreciating the fact that

TITAN COMPANY LIMITED,HOSUR vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.393/Chny/2018 & आयकर अपील सं./ It(Tp)A No.89/Chny/2018 िनधा>रण वष> /Assessment Years: 2013-14 & 2014-15 Titan Company Ltd., The Dy. Commissioner Of Income No.3, Spicot Industrial Complex, Vs. Tax, Hosur, Krishnagiri – 635 126. Ltu-2, [Pan: Aaact 5131A] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 92C(3) of the Act proceeded to make adjustment to the inter-unit transfer of semi-finished products.. h. The Hon'ble DRP/learned AO/ TPO ought to have accepted the economic analysis performed in the TP report in support of arm's length price of Inter-unit transfer of Jewellery and watch units

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

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

Transfer Pricing order\nu/s.92CA(3) of the Act for the AY 2013-14 was completed after\nthe conclusion of the search, wherein the TPO proposed TP\ndownward adjustment of Rs.407.25 crores on the imports from\nMIPP. The TPO did not propose any adjustment on the receipt of\nshare capital reported in the Form 3CEB. The assessee had filed\nappeal against

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

section 92C(3) of the Income-tax Act, 1961 ('the Act').\n3 Rejection of Transfer pricing analysis undertaken by the Appellant\n3.1 The TPO erred in rejecting the benchmarking analysis performed by the Appellant\nand incorrectly undertook a fresh benchmarking analysis.\n3.2. The TPO has erred in rejecting the benchmarking analysis prepared by the\nAppellant without appreciating the fact that

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

transfer of power instead of ALP of ₹19,62,69,902/- as computed by the assessee and thereafter, the assessment was completed u/s.143(3) r.w.s.144C(3) dated 30.04.2021 determining the total assessed income at ₹10,02,63,323/-. 4. Aggrieved, the assessee preferred an appeal before the Ld.CIT(A) who was pleased to allow the appeal by citing the decision

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

3,77,36,616 VIII/2011-12 Total 10,69,94,336 5. The TPO thus determined the Arm’s Length Price (ALP) of electricity transferred from section

EATON POWER QUALITY PRIVATE LIMITED,PONDICHERRY vs. DCIT, PONDICHERRY

In the result, appeal filed by the assessee is treated as allowed for statistical purposes

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1010/Chny/2017 िनधा"रण वष" / Assessment Year: 2012-13 Eaton Power Quality Private The Deputy Commissioner Of Limited, V. Income Tax, No.2, Evr Street Sedarapet, Pondicherry Circle, Puducherry 605 111, Pondicherry. Puducherry (Ut). [Pan: Aacc-6943-R] आयकर अपील सं./It(Tp)A No.: 35/Chny/2021 िनधा"रण वष" / Assessment Year: 2016-17 Eaton Power Quality Private The Assessing Officer, Limited, V. National E-Assessment Centre, No.2, Evr Street Sedarapet, Delhi. Puducherry 605 111, Puducherry (Ut). [Pan: Aacc-6943-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vishal Kalra, Advocate : Shri. S. Maruthu Pandian, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 01.05.2023 घोषणा क" तारीख/Date Of Pronouncement : 03.05.2023 आदेश /O R D E R

Section 153 expires’. Excluding 31.12.2019, the period of 60 days would expire on 01.11.2019 and the transfer pricing orders thus ought to have been passed on 31.10.2019 or any date prior thereto. Incidentally, the Board, in the Central Action Plan also indicates the date by which the Transfer Pricing orders are to be passed as 31.10.2019. The impugned orders

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE LTU-1, CHENNAI, NUNGAMBAKKAM vs. ORIENT GREEN POWER COMPANY LIMITED , CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunatha

Transfer Pricing Officer (TPO) for determination of ALP of these domestic transactions as per Section 92BA(i) of the Act. The impugned assessment order passed u/s 143(3) r.w.s. 144C(3) of the Act on 26/12/2019 after following the order of the TPO u/s 92CA(3) of the Act and income of the 7 assessee was determined at Rs.7

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

10. Under Section 80-IA(8) of the Act, one of the pre-requisites for the AO to not grant the deduction as claimed by the Assessee in his return is where the AO finds that the consideration at which transfers were made of goods and services of the eligible business as recorded in its accounts "does not correspond

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

10. Under Section 80-IA(8) of the Act, one of the pre-requisites for the AO to not grant the deduction as claimed by the Assessee in his return is where the AO finds that the consideration at which transfers were made of goods and services of the eligible business as recorded in its accounts "does not correspond

GOKULAKRISHNA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the stay\napplication is dismissed

10,06,350/-. Subsequently, the\nreturn of income was revised on 15.03.2019 declaring the total income at\n₹.9,98,850/-. On the basis of information collected during the course of\nassessment proceedings in the case of CRCL, where the assessee is a\npartner, the Assessing Office reopened the assessment for AY 2017-18\nunder section

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

transfer pricing adjustment in respect of guarantee given for AE to 0.5% of the amount guaranteed. 3.5 The Second issue is regarding the disallowance under Section 14A. The Assessing Officer has disallowed under Section 14A read with Rule 8D @ rate of 1% of the annual average of monthly averages of the opening and closing balances of the value of investment