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 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

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

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

112 of the paper-book, had exempted the assessee from the following duties and levies, subject to rules and regulations in this regard. “This is to certify that Ms. Mahindra Residential Developers Ltd., approved as a Co-Developer in the sector specific SEZ for IT/Hardware/Bio-informatics at Chennai, Tamil Nadu, developed by Ms. Mahindra World city Developers Ltd., and holder

ACIT, CHENNAI vs. C.H.ROBINSON WORLDWIDE FREIGHT INDIA P. LTD., CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri G. Manjunatha

112 order dated 1.9.2016 wherein it was held as under: 7 The assessee objected to the adjustment made by the Transfer Pricing Officer. With regard to working capital adjustment, the asseessee claims that the difference in working capital between the assessee and the comparable companies - would materially affect the profit determined. Therefore, ‘certain CO No.28/Chny/2017 adjustment needs to be made

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14\n& 2014-15 stands dismissed

112 of the paper-book, had\nexempted the assessee from the following duties and levies, subject to\nrules and regulations in this regard.\n\"This is to certify that Ms. Mahindra Residential Developers Ltd.,\napproved as a Co-Developer in the sector specific SEZ for\nIT/Hardware/Bio-informatics at Chennai, Tamil Nadu, developed by Ms.\nMahindra World city Developers Ltd., and holder

DCIT, CHENNAI vs. M/S. AVT MC CORMICK INGREDIENTS LTD., CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Provisions. As per notification dated 24.06.2003, applicable to the assessee, the royalty was paid at 0.75% on FOB value of exports which is below 8% prescribed rate under the automatic route and supported the case with the decision of ACIT vs. Dufon Laboratoies (2010) 39 SOT 59 (Mum) and EKL Appliances (24 Taxmann 199). The Commissioner of Income

AVT MC CORMICK INGREDIENTS PVT LTD.,CHENNAI vs. ADDL. CIT, CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Provisions. As per notification dated 24.06.2003, applicable to the assessee, the royalty was paid at 0.75% on FOB value of exports which is below 8% prescribed rate under the automatic route and supported the case with the decision of ACIT vs. Dufon Laboratoies (2010) 39 SOT 59 (Mum) and EKL Appliances (24 Taxmann 199). The Commissioner of Income

DCIT, CHENNAI vs. M/S. AVT MC CORMICK INGREDIENTS LTD., CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Provisions. As per notification dated 24.06.2003, applicable to the assessee, the royalty was paid at 0.75% on FOB value of exports which is below 8% prescribed rate under the automatic route and supported the case with the decision of ACIT vs. Dufon Laboratoies (2010) 39 SOT 59 (Mum) and EKL Appliances (24 Taxmann 199). The Commissioner of Income

DCIT, CHENNAI vs. M/S. AVT MC CORMICK INGREDIENTS LTD., CHENNAI

In the result, the appeals of the Revenue in ITA No

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Provisions. As per notification dated 24.06.2003, applicable to the assessee, the royalty was paid at 0.75% on FOB value of exports which is below 8% prescribed rate under the automatic route and supported the case with the decision of ACIT vs. Dufon Laboratoies (2010) 39 SOT 59 (Mum) and EKL Appliances (24 Taxmann 199). The Commissioner of Income

REGEN POWERTECH PRIVATE LMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Assessee and Department are allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Report. Under the erstwhile regulatory laws payment of royalty was permitted to the extent of 5% on domestic sales and 8% in respect of export sale. But in the present case, the rate of royalty has worked to 1.14% which is well within the regulated rates. The ld. TPO relied on the FEMA provisions and could not decide

DCIT, CHENNAI vs. REGEN POWERTECH (P) LTD., CHENNAI

In the result, the appeal of the Assessee and Department are allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing Report. Under the erstwhile regulatory laws payment of royalty was permitted to the extent of 5% on domestic sales and 8% in respect of export sale. But in the present case, the rate of royalty has worked to 1.14% which is well within the regulated rates. The ld. TPO relied on the FEMA provisions and could not decide

MAHINDRA RESIDENTIAL DEVELOPERS LTD.,CHENGALPUT vs. ITO, CHENNAI

112 of the paper-book, had\nexempted the assessee from the following duties and levies, subject to\nrules and regulations in this regard.\n\"This is to certify that Ms. Mahindra Residential Developers Ltd.,\napproved as a Co-Developer in the sector specific SEZ for\nIT/Hardware/Bio-informatics at Chennai, Tamil Nadu, developed by Ms.\nMahindra World City Developers Ltd., and holder

DAESUNG ELECTRIC INDIA PVT. LTD.,,THIRUVALLUR vs. ACIT (OSD), CHENNAI

In the result, appeals filed by the assessee’s in ITA No

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita No.: 585/Chny/2017 िनधा"रणवष" / Assessment Year: 2012-13 Ls Automotive India Private Limited Assistant Commissioner Of (Formerly Known As Daesung V. Income Tax (Osd), Electric India Pvt Ltd) Corporate Range 1, Room No. 603, 6Th Floor, No. 118, Padur Village, Thiruvelangadu Post, Wanaparthy Block, Kunnavalam V.O. No. 121, Aayakarbhavan, Thiruvallur – 631 210. Mahatma Gandhi Road, [Pan: Aakcs-1901-R] Nungamabakkam, Chennai – 600 034. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita No.: 2159/Chny/2017 िनधा"रणवष" / Assessment Year: 2013-14 Komos Automotive India Pvt Deputy Commissioner Of Limited, V. Income Tax, B-10/1, Sipcot Industrial Corporate Circle 4(2), 4Th Floor, Main Building, Development Centre, Oragadam, Vaippur-A Vilalge, No. 121, Mahatma Gandhi Sriperumbudurtaluk, Road, Nungamabakkam, Kanchipuramdist – 602 105. Chennai – 600 034. [Pan: Aacck-8859-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./It(Tp)A No.: 40/Chny/2019 &

112, Singadivakkam Chennai – 600 034. Village, Kanchipuram, Tamilnadu – 631 560. [PAN: AAFCM-2148-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) :-3-: ITA. No: 585/Chny/2017, 360/Chny/2018, 40 & 1365/Chny/2019 & IT(TP)A Nos: 2159/Chny/2017, 44 & 45/Chny/2019 Assessee by : Shri. Raghunathan Sampath, Advocate and Shri. S. Sankara Narayanan, Advocate Department by : Shri. A. Sasikumar, CIT सुनवाई क" तारीख/Date of Hearing : 07.12.2023 घोषणा क" तारीख

DONG-A INDIA AUTOMOTIVE PVT LIMITED,KANCHEEPURAM vs. ITO, CORPORATE WARD 1(4), CHENNAI

In the result, appeals filed by the assessee’s in ITA No

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita No.: 585/Chny/2017 िनधा"रणवष" / Assessment Year: 2012-13 Ls Automotive India Private Limited Assistant Commissioner Of (Formerly Known As Daesung V. Income Tax (Osd), Electric India Pvt Ltd) Corporate Range 1, Room No. 603, 6Th Floor, No. 118, Padur Village, Thiruvelangadu Post, Wanaparthy Block, Kunnavalam V.O. No. 121, Aayakarbhavan, Thiruvallur – 631 210. Mahatma Gandhi Road, [Pan: Aakcs-1901-R] Nungamabakkam, Chennai – 600 034. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita No.: 2159/Chny/2017 िनधा"रणवष" / Assessment Year: 2013-14 Komos Automotive India Pvt Deputy Commissioner Of Limited, V. Income Tax, B-10/1, Sipcot Industrial Corporate Circle 4(2), 4Th Floor, Main Building, Development Centre, Oragadam, Vaippur-A Vilalge, No. 121, Mahatma Gandhi Sriperumbudurtaluk, Road, Nungamabakkam, Kanchipuramdist – 602 105. Chennai – 600 034. [Pan: Aacck-8859-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./It(Tp)A No.: 40/Chny/2019 &

112, Singadivakkam Chennai – 600 034. Village, Kanchipuram, Tamilnadu – 631 560. [PAN: AAFCM-2148-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) :-3-: ITA. No: 585/Chny/2017, 360/Chny/2018, 40 & 1365/Chny/2019 & IT(TP)A Nos: 2159/Chny/2017, 44 & 45/Chny/2019 Assessee by : Shri. Raghunathan Sampath, Advocate and Shri. S. Sankara Narayanan, Advocate Department by : Shri. A. Sasikumar, CIT सुनवाई क" तारीख/Date of Hearing : 07.12.2023 घोषणा क" तारीख

KOMOS AUTOMOTIVE INDIA PVT LTD,KANCHIPURAM vs. DCIT, CORPORATE CIRCLE4(2), CHENNAI

In the result, appeals filed by the assessee’s in ITA No

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita No.: 585/Chny/2017 िनधा"रणवष" / Assessment Year: 2012-13 Ls Automotive India Private Limited Assistant Commissioner Of (Formerly Known As Daesung V. Income Tax (Osd), Electric India Pvt Ltd) Corporate Range 1, Room No. 603, 6Th Floor, No. 118, Padur Village, Thiruvelangadu Post, Wanaparthy Block, Kunnavalam V.O. No. 121, Aayakarbhavan, Thiruvallur – 631 210. Mahatma Gandhi Road, [Pan: Aakcs-1901-R] Nungamabakkam, Chennai – 600 034. (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita No.: 2159/Chny/2017 िनधा"रणवष" / Assessment Year: 2013-14 Komos Automotive India Pvt Deputy Commissioner Of Limited, V. Income Tax, B-10/1, Sipcot Industrial Corporate Circle 4(2), 4Th Floor, Main Building, Development Centre, Oragadam, Vaippur-A Vilalge, No. 121, Mahatma Gandhi Sriperumbudurtaluk, Road, Nungamabakkam, Kanchipuramdist – 602 105. Chennai – 600 034. [Pan: Aacck-8859-N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./It(Tp)A No.: 40/Chny/2019 &

112, Singadivakkam Chennai – 600 034. Village, Kanchipuram, Tamilnadu – 631 560. [PAN: AAFCM-2148-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) :-3-: ITA. No: 585/Chny/2017, 360/Chny/2018, 40 & 1365/Chny/2019 & IT(TP)A Nos: 2159/Chny/2017, 44 & 45/Chny/2019 Assessee by : Shri. Raghunathan Sampath, Advocate and Shri. S. Sankara Narayanan, Advocate Department by : Shri. A. Sasikumar, CIT सुनवाई क" तारीख/Date of Hearing : 07.12.2023 घोषणा क" तारीख