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

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 PER MANJUNATHA. G, ACCOUNTANT MEMBER: These two appeals

HARLAND CLARKE HOLDING SOFTWARE INDIA PRIVATE LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 2(2), CHENN

In the result, the appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri S.Jayaraman

sections 234B & 234C of the Act and Ground No.15 was against the initiation of penalty u/s.271(1)(c) of the Act. The grounds Nos.14 & 15 were not argued by ld.A.R. Consequently, the same is dismissed as not pressed. 5. In regard to the transfer pricing issues, it was submitted by ld.A.R that the assessee has three lines of business

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

HYUNDAI MOTOR INDIA LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

DCIT, CHENNAI vs. HYUNDAI MOTORS INDIA LTD., KANCHEEPURAM

In the result, while CO of the assessee is dismissed, all the three appeals filed by the assessee are partly allowed in the terms indicated above, all the three appeals filed by the revenue are dis...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

YCH LOGISTICS (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

transfer pricing adjustment for fresh adjudication. Simultaneously, the assessee also challenged the order of Tribunal i.e., original order passed in ITA No.322/Mds/2016 dated 30.06.2016 and also challenged the Tribunal order passed in M.P. No.218/Mds/2016 dated 04.04.2017 before Hon’ble High Court of Madras and the Hon’ble High Court in Tax Case Appeal Nos.480 and 473 of 2017 vide order

TRIUMPH INTERNATIONAL (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. ACIT, CHENNAI

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

section 143(3) r.w.s. 92CA(4) and r.w.s 144C of the Income-tax Act, 1961 ('the Act') by the Assistant Commissioner of Income-tax, Corporate Circle - 3 (1), Chennai ('the Assessing Officer'/ 'AO') for the aforesaid assessment year on the following among other grounds: TRANSFER PRICING GROUNDS 2. Adjustment of Rs.34,483,111

TRIUMPH INTERNATIONAL (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. ACIT, CHENNAI

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

section 143(3) r.w.s. 92CA(4) and r.w.s 144C of the Income-tax Act, 1961 ('the Act') by the Assistant Commissioner of Income-tax, Corporate Circle - 3 (1), Chennai ('the Assessing Officer'/ 'AO') for the aforesaid assessment year on the following among other grounds: TRANSFER PRICING GROUNDS 2. Adjustment of Rs.34,483,111

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

In the result, the appeal of the assessee is allowed

Section 143 of the Act. Further, as noted above, the CIT(A) has examined the merits of the matter and after taking note of the facts granted relief to the assessee to the extent indicated therein. Thus, for the above reasons, we find that the revenue has not made out any case for interference of the order passed

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

111 taxmann.com 338 (Mumbai - Trib.) - CIT v. M/s. Wheels India Ltd. [2011] 336 ITR 513 (Madras) (AY 2012- 13) - Brakes India Limited vs. DCIT [2017] 56 ITR(T) 341 (Chennai -Trib.)” 6.4 In light of the above therefore, we hold that the lower authorities were not justified in curtailing the deduction u/s 35(2AB) in the pre- amended pre period

M/S. EID PARRY INDIA LTD.,CHENNAI vs. DCIT, LTU-1,, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing proceedings, the assessee has submitted that Letter of Comfort is a facility to avail credit by Parry America Inc. which is a subsidiary of the assessee company. Therefore, the assessee contented before the TPO that, the above facility is not a guarantee and the adjustment towards guarantee commission would not arise with reference to Section

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. E I D PARRY INDIA LIMITED, CHENNAI

In the result, all the appeals filed by the assessee are partly allowed for statistical purposes and the appeal filed by the Revenue is dismissed

Bench: Shri George George Kand Shri S.R. Raghunathait(Tp)A. Nos.:105, 106, 107/Chny/2024 & Ita No.3113/Chny/2024 िनधा"रण वष"/Assessment Years: 2011-12, 2012-13, 2013-14 & 2014-15 M/S. E.I.D. Parry India Ltd., The Deputy Commissioner Of No. 234, Dare House, Nsc Vs. Income Tax, Bose Road, Parrys Corner, Large Taxpayer Unit -1, Chennai 600 001. Chennai. [Pan: Aaace-0702-C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing proceedings, the assessee has submitted that Letter of Comfort is a facility to avail credit by Parry America Inc. which is a subsidiary of the assessee company. Therefore, the assessee contented before the TPO that, the above facility is not a guarantee and the adjustment towards guarantee commission would not arise with reference to Section

EATON POWER QUALITY PRIVATE LIMITED,PUDUCHERRY vs. THE DEPUTY COMMISSIONER OF INCOME TAX, PUDUCHERRY

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

111. Puducherry. [PAN: AAACC 6943 R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant by : Mr.Vishal Kalra, Advocate (Virtual) ""यथ" क" ओर से /Respondent by : Mr. ARV Sreenivasan, CIT : सुनवाईक"तारीख/Date of Hearing 25.09.2025 : घोषणाक"तारीख /Date of Pronouncement 18.12.2025 आदेश / O R D E R PER ABY T. VARKEY, JM: This is an appeal preferred

GANESAN KANNAN,THOOTHUKUDI vs. ITI, INTERNATIONAL TAXATION WARD, THOOTHUKUDI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 698/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19

111 taxmann.com 387 (Delhi-Trib) Hon 'ble Delhi Bench of the Tribunal in the case of Honda Trading Corporation, Japan vs. DCIT in ITA No. 1132/Kol/2015, order dated 15/09/2015 Hon'ble coordinate bench of Bangalore Tribunal in case of Volvo India private limited Vs. ACIT IT(TP)A No.1537/Bang/2012 dated 8/5/2019 and Acer India Pvt. Ltd. Vs. DCIT 502/Bang/2017 dated

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

111 of the case laws paper book): • We have gone through the provisions of section 56(2)(viia) of the Act and from plain reading of section, it is clear that the same can be invoked only where the assessee receives a property for an inadequate consideration and in the present case before us, the assessee company only brought back

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

111 of the case laws paper book): • We have gone through the provisions of section 56(2)(viia) of the Act and from plain reading of section, it is clear that the same can be invoked only where the assessee receives a property for an inadequate consideration and in the present case before us, the assessee company only brought back

SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

transfer of asset and the value adopted for stamp duty valuation was apparently not less than 10% tolerance margin which has been brought into effect from 1-4-2021 in the first proviso to section 43CA and therefore, the Tribunal in its wisdom had restored the matter to the file of the A.O for fresh adjudication (supra). Before us, admittedly