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)

10,77,72,060 TNMM Design services Renault SAS Provision of sourcing 2,65,99,713 TNMM support services RCI Banque Provision of feasibiklty 38,13,118 TNMM serices NML Japan Purchases of capital good- 67,79,83,507 TNMM Dies and Moulds Renault SAS Payment of IT Charges 95,88,015 TNMM NML Japan Payment of IT Charges

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

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

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

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

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

DOOWON AUTOMOTIVE SYSTEMS INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1016/Mds/2015 "नधा"रण वष" / Assessment Year : 2010-11 M/S Doowon Automotive Systems India Pvt. Ltd., The Deputy Commissioner Of Plot No.B-19 & 20, Sipcot V. Income Tax, Industrial Park, Oragadam, Corporate Circle – 1(1), Sriperumbudur Taluk, Chennai - 600 034. Kancheepuram District-602 105. Pan : Aaccd 4172 F (अपीलाथ"/Appellant) (""यथ"/Respondent)

38,756/-. According to the Ld. counsel, the assessee could not localize the purchases, therefore, the assessee was forced to incur an additional liability towards Customs duty. Due to high cost of import, the assessee had to incur a payment of `14,27,43,259/- towards basic Customs duty. The comparable companies taken by the Transfer Pricing Officer

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

38,56,155/- as against the returned income of Rs.3,51,95,750/- computed by the Appellant in its return of income for AY 2013-14. 3. The Ld. AO has erred in law and in fact, in determining a sum of Rs.1,98,87,910/- as the balance tax (including interest) demand payable by the Appellant. Transfer pricing grounds

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

transfer pricing regulation as per which adjustment on account of any international transaction is required to be made as per the method prescribed. The learned CIT (DR) pointed out that the TPO in respect of the nine services not availed by the Assessee has treated the payment as nil since no independent party would make any payment for services

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

transfer pricing regulation as per which adjustment on account of any international transaction is required to be made as per the method prescribed. The learned CIT (DR) pointed out that the TPO in respect of the nine services not availed by the Assessee has treated the payment as nil since no independent party would make any payment for services

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. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business

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. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business

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. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business

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. The Honorable DRP/AO have failed to appreciate that during the relevant financial year the appellant had more interest income than interest expenses and hence, the provisions of section 14A of the Act ought not to apply. 11. The learned AC has erred in making the disallowance merely for the reason that the appellant had interest expenditure in its business

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

38,77,063 VII/2009-10 5. Division 18.08.2011 1,11,31,745 3.39 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

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

SMT. SUDHA EASHWAR,,CHENNAI vs. ITO, NCW - 14 (3),, CHENNAI

In the result, the appeal filed by the assessee in ITA

Bench: Shri George Mathan & Shri Ramit Kocharआयकर अपील सं./Ita No.2342/Chny/2019 "नधा"रण वष" /Assessment Year: 2014-15 V. Smt. Sudha Eashwar, The Income Tax Officer No.23A, P.T.Rajan Salai, Non-Corporate Ward-14(3) K.K.Nagar, Chennai Chennai-600 078. [Pan: Alxps 0601 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : None ""यथ" क" ओर से /Respondent By : Ms.Sumathi Venkatraman, Jcit सुनवाई क" तार"ख/Date Of Hearing : 09.10.2019 घोषणा क" तार"ख /Date Of Pronouncement : 02.01.2020 आदेश / O R D E R Per Ramit Kochar:

transferred to assessee’s DMAT account . The assessee has claimed that during previous year relevant to impugned ay: 2014-15 , the assessee has sold 7900 shares of Turbotech Engineering Limited for Rs. 40,22,940/- , translating into long term capital gains of Rs. 39,77,886/- , which long term capital gains were claimed as an exempt u/s 10(38