ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

4) requires that he determines the total income of the assessee in conformity with the arm's length price determined by the TPΟ.\n7.5.13 The appellant submitted that the AO has surmised that the profits on the supply of equipment that were made by MIPP were distributed to Mudajaya and Enerkwho have in turn contributed to the share capital

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

120/- paid in accordance with the payment terms... 2. Schedule-B: All that place & parcel of land bearing Plot no. ….. measuring … sq.ft. of land area, along with premiere villa/deluxe villa/luxury villa/deluxe admeasuring a built up area of 2402 sq. Comprised in survey numbers... 3: ASSIGNMENT/ TRANSFER: The Lessee shell be entitled to assign/mortgage/transfer his/her/its rights under this Lease Deed

SEVUGAN PETHAPERUMAL,MADURAI vs. PCIT, MADURAI-1,, MADURAI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1196/Chny/2025 Assessment Years: 2020-21 Sevugan Pethaperumal, Principal Commissioner Of Income No.41, First Main Street, Tax, Narayanapuram West, Madurai-1, Madurai, Madurai. Tamil Nadu-625 014. [Pan: Afjpp5984J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Shri G.Tarun, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 06.08.2025 घोषणा की तारीख /Date Of Pronouncement : 25.08.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

4 - of 13 order under the said section]. 36[ 37[Explanation 1.]-For the removal of doubts 38, it is hereby declared that, for the purposes of this sub-section,- (a) an order passed 39[on or before or after the 1st day of June, 1988] by the Assessing Officer 40[or the Transfer Pricing Officer, as the case

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

4) requires that he determines the\ntotal income of the assessee in conformity with the arm's\nlength price determined by the TPΟ.\n7.5.13 The appellant submitted that the AO has surmised\nthat the profits on the supply of equipment that were made\nby MIPP were distributed to Mudajaya and Enerkwho have\nin turn contributed to the share capital

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

4. The brief facts of the case insofar the cross appeals for the block period under consideration in IT(SS)A No.153 & 162/Mds/2003 are as follows: The assessee is a Managing Director of M/s.Pentafour Products Limited, receiving income under the head “Salary”, dividend income as well as the sitting fees during the block period. The Income Tax Department had conducted

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

4. The brief facts of the case insofar the cross appeals for the block period under consideration in IT(SS)A No.153 & 162/Mds/2003 are as follows: The assessee is a Managing Director of M/s.Pentafour Products Limited, receiving income under the head “Salary”, dividend income as well as the sitting fees during the block period. The Income Tax Department had conducted

SAME DEUTZ FAHR ITALIA SPA,ITALY vs. ASSISTANT COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

transferred to India. Thus, as per the business model, the on-site services are entirely performed by the assessee from outside India and delivered for ultimate consumption or utilization by foreign clients in their business outside India. Para 17 It is found that the assessee made an alternative argument on without prejudice bas HCL India provides both onsite and offshore

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

120/- paid in accordance with the payment\nterms...\n2. Schedule-B: All that place & parcel of land bearing Plot no.\nmeasuring .... sq.ft. of land area, along with premiere villa/deluxe\nvilla/luxury villa/deluxe admeasuring a built up area of 2402 sq.\nComprised in survey numbers...\n3: ASSIGNMENT/ TRANSFER:\nThe Lessee shell be entitled to assign/mortgage/transfer his/her/its\nrights under this Lease Deed

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

120 days. b) Applicability of Article 14 of DTAA between India and Germany c) Taxability of receipts in Germany. The ld.Senior DR also pointed out that the CIT(A) in his appellate order has also observed that the assessee failed to adduce evidence in ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 support of its claim and hence, this issue

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

120 days. b) Applicability of Article 14 of DTAA between India and Germany c) Taxability of receipts in Germany. The ld.Senior DR also pointed out that the CIT(A) in his appellate order has also observed that the assessee failed to adduce evidence in ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 support of its claim and hence, this issue

RANE ENGINE VALVE LTD,CHENNAI vs. DCIT CORPORATE CIRCLE-5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

120 days. b) Applicability of Article 14 of DTAA between India and Germany c) Taxability of receipts in Germany. The ld.Senior DR also pointed out that the CIT(A) in his appellate order has also observed that the assessee failed to adduce evidence in ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 support of its claim and hence, this issue

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5 (1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

120 days. b) Applicability of Article 14 of DTAA between India and Germany c) Taxability of receipts in Germany. The ld.Senior DR also pointed out that the CIT(A) in his appellate order has also observed that the assessee failed to adduce evidence in ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 support of its claim and hence, this issue

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

120 days. b) Applicability of Article 14 of DTAA between India and Germany c) Taxability of receipts in Germany. The ld.Senior DR also pointed out that the CIT(A) in his appellate order has also observed that the assessee failed to adduce evidence in ITA Nos.1497, 1498/Chny/2017, 1477 & 2815/CHNY/2018 & 885/CHNY/2020 support of its claim and hence, this issue

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

120 taxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the judgment reads as follows: "9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd. [TCA Nos.732 & 733 of 2018 decided on 7-7-2020], has relied upon the decisions of the Delhi High Court in the case of Joint Investments

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

120 taxmann.com 84/275 Taxman 502 (Mad.). The operative portion of the judgment reads as follows: "9. A Co-ordinate Bench of this Court, in the case of CIT v. Tidel Park Ltd. [TCA Nos.732 & 733 of 2018 decided on 7-7-2020], has relied upon the decisions of the Delhi High Court in the case of Joint Investments

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. RAMASUBBU MINNALKODI, TIRUNELVELI

In the result, the appeal of the Revenue is dismissed

B' BENCH, CHENNAI\nश्री एस एस विश्वनेत्र रवि, न्यायिक सदस्य एवं श्री एस. आर. रघुनाथा, लेखा सदस्य के समक्ष\nBEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER AND\nSHRI S. R. RAGHUNATHA, ACCOUNTANT MEMBER\nआयकर अपीलसं/.ITA No.: 1632/Chny/2025\nनिर्धारणवर्ष / Assessment Year: 2020-21\nAssistant Commissioner of\nIncome tax,\nCentral Circle -2,\nMadurai - 625 002.\nV.\nRamasubbu Minnalkodi,\n7/10, Ambasamudram Road

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

120 taxmann.com 84 (Madras) − CIT vs. Celebrity Fashion Ltd [2020] 119 taxmann.com 426 ITA Nos.1402 & 1663/Chny/2024 (AY 2019-20) M/s. Ashok Leyland Ltd. :: 10 :: 6.3 The ld. AR for the assessee further submitted that in the case of M/s Ramco Cements Limited Vs DCIT in ITA NO.1897/Chny/2017, this coordinate Bench has decided this identical issue in favour of the assessee

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nआयकर अपील सं./ITA No.1402/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nM/s. Ashok Leyland Ltd.,\nNo.1, Sardar Patel Road,\nGuindy, Chennai-600 032.\n[PAN: AAAСА 4651 L]\n(अपीलार्थी/Appellant)\nv.\nThe DCIT,\nNCC-8(1),\nLTU-II,\nChennai.\n(प्रत्यर्थी/Respondent)\nआयकर अपील सं./ITA No.1663/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nThe DCIT,\nNCC-8,\nChennai.\n(अपीलार्थी/Appellant)\nv.\nM/s. Ashok Leyl

120 taxmann.com 84 (Madras)\nCIT vs. Celebrity Fashion Ltd [2020] 119 taxmann.com 426\nITA Nos.1402 & 1663/Chny/2024 (AY 2019-20)\nM/s. Ashok Leyland Ltd.\n:: 10 ::\n6.3 The Id. AR for the assessee further submitted that in the case of\nM/s Ramco Cements Limited Vs DCIT in ITA NO.1897/Chny/2017,\nthis coordinate Bench has decided this identical issue in favour