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

pricing of the international transaction. 18.2 The assessee also submitted a detailed note on the various services availed by them under the terms of the agreement. Further, it was also submitted before the TPO that the AE party had identified the nature of stewardship/shareholder activities in each of the above department/services and such costs was excluded and not charged back

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

pricing of the international transaction. 18.2 The assessee also submitted a detailed note on the various services availed by them under the terms of the agreement. Further, it was also submitted before the TPO that the AE party had identified the nature of stewardship/shareholder activities in each of the above department/services and such costs was excluded and not charged back

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

114 taxmann.com 568 (Karnataka) held that Clause (i) of section 92BA having been omitted by Finance Act, 2017 with effect from l-4-2017 from statute, resultant effect is that it had never been passed and, hence, decision taken by AO under effect of section 92BA and reference made to Transfer Pricing

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

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

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

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

NVH INDIA AUTO PARTS PRIVATE LIMITED,KANCHEEPURAM vs. DCIT CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 2773/Chny/2017 िनधा"रण वष" / Assessment Year: 2013-14 Nvh India Auto Parts Private Deputy Commissioner Of Limited, V. Income-Tax, B-68, Sipcot Industrial Park, Corporate Circle -4(2), Irungattukottai, Sriperumbadur Nungambakkam, Taluk, Kancheepuram – 602 105. Chennai – 600 034. [Pan: Aaccn-2857-P] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. S.P. Chidambaram, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 08.08.2023 घोषणा क" तारीख/Date Of Pronouncement : 31.10.2023

section 143(3) r.w.s. 92CA(3) of the Act by the Deputy Commissioner of Income-tax, Corporate Circle - 4(2), Chennai ('the Assessing Officer/1 'AO") for the aforesaid assessment year (AY") on the following among other grounds: TRANSFER PRICING GROUNDS 2. The AO / Transfer Pricing Officer (TPO') and the Dispute Resolution Panel (DRP) have erred in law and facts

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

price, which was much higher than the guideline value, which would normally have ended as a distress sale, under such circumstances, with much lesser consideration, the sale extracted much higher value which was incredible, considering overall circumstances under which such sale took place. The Assessee had paid these persons for such services, by way of commission, which totaled to about

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

price, which was much higher than the guideline value, which would normally have ended as a distress sale, under such circumstances, with much lesser consideration, the sale extracted much higher value which was incredible, considering overall circumstances under which such sale took place. The Assessee had paid these persons for such services, by way of commission, which totaled to about

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

114. At the threshold, it is necessary to advert to the charging contained in section 45 of the Act. The said section mandates that any profits or gains arising from the transfer of a capital asset shall be chargeable to income-tax under the head "Capital gains" and shall be deemed to be the income of the previous year

LOTUS FOOTWEAR ENTERPRISES LIMITED-INDIA BRANCH,TIRUVANNAMALAI vs. DCIT, INTERNATIONAL TAX 1(2), CHENNAI

In the result all the four appeals of the assessee are allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

114^ 3,40,34,392 20,54,26,506 16.57 % ^Annexure 5 to Additional Evidence petition dated 01.09.2025 58. Thus, without prejudice to the primary contention that F.Y.14-15, which is the year of formation, should be taken for computing the ratio of transferred machinery, the ld.AR submitted that even if F.Y.2013-14 is to be taken, the assessee would satisfy

MAHARAJA SIVAM INDUSTRIES (P) LIMITED,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, all the appeals stand restored back to the file of Ld

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Transfer pricing (TP) mechanism pursuant to the directions of Hon’ble Supreme Court in the case of CIT vs. Glaxo Smithkline Asia (P.) Ltd. (195 Taxman 35). 5. Since the plea of Ld. AR contest very validity of jurisdiction of Ld. TPO, we deal with the same. The Hon’ble Karnataka High Court in the case of PCIT vs. Texport

S.SARADHA,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, all the appeals stand restored back to the file of Ld

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Transfer pricing (TP) mechanism pursuant to the directions of Hon’ble Supreme Court in the case of CIT vs. Glaxo Smithkline Asia (P.) Ltd. (195 Taxman 35). 5. Since the plea of Ld. AR contest very validity of jurisdiction of Ld. TPO, we deal with the same. The Hon’ble Karnataka High Court in the case of PCIT vs. Texport

K.P.S.OIL MILLS,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, all the appeals stand restored back to the file of Ld

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Transfer pricing (TP) mechanism pursuant to the directions of Hon’ble Supreme Court in the case of CIT vs. Glaxo Smithkline Asia (P.) Ltd. (195 Taxman 35). 5. Since the plea of Ld. AR contest very validity of jurisdiction of Ld. TPO, we deal with the same. The Hon’ble Karnataka High Court in the case of PCIT vs. Texport

K.PARAMASIVAM,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, all the appeals stand restored back to the file of Ld

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Transfer pricing (TP) mechanism pursuant to the directions of Hon’ble Supreme Court in the case of CIT vs. Glaxo Smithkline Asia (P.) Ltd. (195 Taxman 35). 5. Since the plea of Ld. AR contest very validity of jurisdiction of Ld. TPO, we deal with the same. The Hon’ble Karnataka High Court in the case of PCIT vs. Texport

SIVAM AND COMPANY,ERODE vs. ACIT CIRCLE 1, ERODE

In the result, all the appeals stand restored back to the file of Ld

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

Transfer pricing (TP) mechanism pursuant to the directions of Hon’ble Supreme Court in the case of CIT vs. Glaxo Smithkline Asia (P.) Ltd. (195 Taxman 35). 5. Since the plea of Ld. AR contest very validity of jurisdiction of Ld. TPO, we deal with the same. The Hon’ble Karnataka High Court in the case of PCIT vs. Texport