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)

10. assailing the orders of the lower authorities submitted that there was an imperfect understanding of the control structure of the assessee and M/s. RNAIPL. According to him, the share holding structure of the group was as under:- As per the ld. Authorised Representative, Renault group had only 30% holding in M/s. RNAIPL and balance 70% was held

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 adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex- ITA No.672/Chny/201 /Chny/2017 (AY 2012-13) M/s.TVS Motor Co. Ltd. M/s.TVS Motor Co. Ltd. :: 16 :: factory sale at Rs.2,15,56,000/ factory

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

10. Shri M. Swaminathan, Ld. Sr.Standing Counsel for the Revenue, submitted that the assessee made donation to M/s Public & Political Awareness Trust and claimed deduction under Section 80GGB of the Act. Referring to the provisions of Section 29A of the Representation of the People Act, 1951, the Ld. Sr. Standing Counsel submitted that the assessee being a multinational corporation

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

10. Shri M. Swaminathan, Ld. Sr.Standing Counsel for the Revenue, submitted that the assessee made donation to M/s Public & Political Awareness Trust and claimed deduction under Section 80GGB of the Act. Referring to the provisions of Section 29A of the Representation of the People Act, 1951, the Ld. Sr. Standing Counsel submitted that the assessee being a multinational corporation

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

10. Shri M. Swaminathan, Ld. Sr.Standing Counsel for the Revenue, submitted that the assessee made donation to M/s Public & Political Awareness Trust and claimed deduction under Section 80GGB of the Act. Referring to the provisions of Section 29A of the Representation of the People Act, 1951, the Ld. Sr. Standing Counsel submitted that the assessee being a multinational corporation

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

10. Shri M. Swaminathan, Ld. Sr.Standing Counsel for the Revenue, submitted that the assessee made donation to M/s Public & Political Awareness Trust and claimed deduction under Section 80GGB of the Act. Referring to the provisions of Section 29A of the Representation of the People Act, 1951, the Ld. Sr. Standing Counsel submitted that the assessee being a multinational corporation

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

10. Shri M. Swaminathan, Ld. Sr.Standing Counsel for the Revenue, submitted that the assessee made donation to M/s Public & Political Awareness Trust and claimed deduction under Section 80GGB of the Act. Referring to the provisions of Section 29A of the Representation of the People Act, 1951, the Ld. Sr. Standing Counsel submitted that the assessee being a multinational corporation

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

10. Shri M. Swaminathan, Ld. Sr.Standing Counsel for the Revenue, submitted that the assessee made donation to M/s Public & Political Awareness Trust and claimed deduction under Section 80GGB of the Act. Referring to the provisions of Section 29A of the Representation of the People Act, 1951, the Ld. Sr. Standing Counsel submitted that the assessee being a multinational corporation

ANTHIAH PANCRAS,TIRUVANNAMALAI vs. ITO WARD 1, THIRUVANNAMALAI

In the result, the appeal filed by the assessee for ay: 2008-09 shall

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

10(37) of the 1961 Act and the assessee claimed that even provisions of Section 68 of the 1961 Act cannot be invoked for cash deposits in the bank account. The assessee filed certificate from Panchayat office to support its contention. The assessee contended that he received Rs.1,91,50,575/- from buyers for sale of acre 25.36 and half

ANTHIAH PANCRAS,TIRUVANNAMALAI vs. ITO WARD 1, THIRUVANNAMALAI

In the result, the appeal filed by the assessee for ay: 2008-09 shall

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar

10(37) of the 1961 Act and the assessee claimed that even provisions of Section 68 of the 1961 Act cannot be invoked for cash deposits in the bank account. The assessee filed certificate from Panchayat office to support its contention. The assessee contended that he received Rs.1,91,50,575/- from buyers for sale of acre 25.36 and half

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

10 years. On a reference to the Transfer Pricing Officer (‘TPO”) , in an order made under section 92CA(3) in which the learned TPO adopted 6.31% (LIBOR of 4.41 percent plus 1.9 percent) as the arm’s length price and directed an adjustment of 4.31% (6.31 percent minus 2 percent) at INR 1,48,48,492. Further, during the year

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

10 years. On a reference to the Transfer Pricing Officer (‘TPO”) , in an order made under section 92CA(3) in which the learned TPO adopted 6.31% (LIBOR of 4.41 percent plus 1.9 percent) as the arm’s length price and directed an adjustment of 4.31% (6.31 percent minus 2 percent) at INR 1,48,48,492. Further, during the year

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

10 years. On a reference to the Transfer Pricing Officer (‘TPO”) , in an order made under section 92CA(3) in which the learned TPO adopted 6.31% (LIBOR of 4.41 percent plus 1.9 percent) as the arm’s length price and directed an adjustment of 4.31% (6.31 percent minus 2 percent) at INR 1,48,48,492. Further, during the year

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

10 years. On a reference to the Transfer Pricing Officer (‘TPO”) , in an order made under section 92CA(3) in which the learned TPO adopted 6.31% (LIBOR of 4.41 percent plus 1.9 percent) as the arm’s length price and directed an adjustment of 4.31% (6.31 percent minus 2 percent) at INR 1,48,48,492. Further, during the year

COOK INDIA MEDICAL DEVICES PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

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

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita No.3137/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14

transfer pricing adjustment amounting to Rs.1,05,28,594/-. 4.1. The Ld. AO/TPO/ DRP have erred, in law and in facts, by rejecting the foreign AEs as the tested party and selecting the Appellant as the tested party. 4.2. The Ld. AO/TPO/DRP has erred, in laws and facts, by rejecting transaction net margin method as the most appropriate method

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

10 :: (i) the price that such goods or services would ordinarily fetch in the open market; or (ii) the arm's length price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA.” 18. As regards the above, the Ld.AR submitted that the explanation

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

10. “43………... Interestingly, much water has been flown after A.Y.2017-18 by way of insertion of the Explanation to Section 80IA(8) of the Act whereby the decision of the market value has been provided by the assessee. In view of the above, none of the judgments relied upon by the assessee are applicable to the facts of the present case

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)

37 of the 1961 Act. However, the High Court has failed to notice the "reversal" which constituted part of the data systematically maintained by the assessee over last decade. 18. For the above reasons, we set aside the impugned judgment of the Madras High Court dated 5.2.07 and accordingly the civil appeals stand allowed in favour of the assessee with

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

Section 46 of the Foreign Exchange Management Act, 1999 (42 of 1999) and in consultation with the Reserve Bank, the Central Government, having considered it necessary in the public interest, hereby makes the following further amendment in the Foreign Exchange Management (Current Account Transactions) Rules, 2000, namely: 1. (1) These rules may be called the Foreign Exchange Management (Current Account