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

4 :: [2024] 460 ITR 162 (SC) wherein it was held that the market value of the power supplied for captive consumption should be considered at the rate at which the State Electricity Board supplied power to its end consumers and not at the rate at which an assessee sells to the State Electricity Board. 5. Aggrieved by the aforesaid action

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

Transfer Pricing order u/s.92CA(3) of the Act for the AY 2013-14 was completed after the conclusion of the search, wherein the TPO proposed TP downward adjustment of Rs.407.25 crores on the imports from MIPP. The TPO did not propose any adjustment on the receipt of share capital reported in the Form 3CEB. The assessee had filed appeal against

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

price whichever is lower. The appellant contended that the stand of the AO is not correct also the statement recorded during the survey has no evidentiary value. The appellant also submitted that this component of stock difference does not represent the value of any excess quantity of stock found during the course of survey in relation to the stock register

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

price whichever is lower. The appellant\ncontended that the stand of the AO is not correct also the statement recorded\nduring the survey has no evidentiary value. The appellant also submitted that\nthis component of stock difference does not represent the value of any\nexcess quantity of stock found during the course of survey in relation to the\nstock register

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

price whichever is lower. The appellant\ncontended that the stand of the AO is not correct also the statement recorded\nduring the survey has no evidentiary value. The appellant also submitted that\nthis component of stock difference does not represent the value of any\nexcess quantity of stock found during the course of survey in relation to the\nstock register

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI vs. AATHMIKA HOLDINGS PVT LTD, CHENNAI

In the result, the appeal of the Revenue stand dismissed and the

Bench: Shri Aby T. Varkey & Shri Jagadish

134 shares of M/s IG3 Infra Limited (in short ‘IG3’) on 08.08.2020 at the rate of Rs.12.43/- per share, viz., total consideration of Rs.73,63,67,296/-. The assessee had also purchased 18,43,73,618 shares of M/s ETL Power Services Limited (in short ‘ETL Power’) at the rate of Rs.14.30/- per share, which worked out to a total

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, TIRUNELVELI, TIRUNELVELI vs. M/S.LOYAL TEXTILE MILLS LIMITED, KOVILPATTI

In the result, both appeals filed by the Revenue are dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.192/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.193/Chny/2025, A.Y.: 2018-19 V. Deputy Commissioner Of Income M/S.Loyal Textile Mills Tax, Limited, Circle-1, New No.21, Old No.4, Tirunelveli. Mill Street, Kovilpatti, Tamil Nadu-628 501. [Pan: Aaacl2632C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.Bhupendran, Advocate. : प्रत्यर्थी की ओर से /Respondent By Mr.Krishna Murthy At, Jcit सुनवाईकीतारीख/Date Of Hearing : 22.10.2025 घोषणाकीतारीख /Date Of Pronouncement : 30.10.2025

Transfer Pricing Officer (TPO) who, vide order dated 28.01.2021, proposed a downward adjustment of ITA Nos.192 & 193 /Chny/2025 (AY-2017-18 & 2018-19) M/s.Loyal Textile Mills Limited. Rs.22,18,09,187/– in relation to the claim of deduction under section 80IA. The Assessing Officer (AO), in the order passed u/s 143(3) r.w.s. 144C(3) dated 29.10.2021, assessed the income

DEPUTY COMMISSIONER OF INCOME TAX, TIRUNELVELI vs. M/S.LOYAL TEXTILE MILLS LIMITED, KOVILPATTI

In the result, both appeals filed by the Revenue are dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.192/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.193/Chny/2025, A.Y.: 2018-19 V. Deputy Commissioner Of Income M/S.Loyal Textile Mills Tax, Limited, Circle-1, New No.21, Old No.4, Tirunelveli. Mill Street, Kovilpatti, Tamil Nadu-628 501. [Pan: Aaacl2632C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.Bhupendran, Advocate. : प्रत्यर्थी की ओर से /Respondent By Mr.Krishna Murthy At, Jcit सुनवाईकीतारीख/Date Of Hearing : 22.10.2025 घोषणाकीतारीख /Date Of Pronouncement : 30.10.2025

Transfer Pricing Officer (TPO) who, vide order dated 28.01.2021, proposed a downward adjustment of ITA Nos.192 & 193 /Chny/2025 (AY-2017-18 & 2018-19) M/s.Loyal Textile Mills Limited. Rs.22,18,09,187/– in relation to the claim of deduction under section 80IA. The Assessing Officer (AO), in the order passed u/s 143(3) r.w.s. 144C(3) dated 29.10.2021, assessed the income

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

Accordingly, the assessee’s appeals in ITA Nos. 1881, 1882, and 1883/Chny/2025 for A.Ys. 2016-17, 2019-20, and 2022-23 are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 3(3), CHENNAI., CHENNAI vs. M/S. CATERPILLAR INDIA PVT. LTD , CHENNAI

Appeal is dismissed

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपीलसं./It(Tp)A No.: 42/Chny/2023 िनधा"रण वष" / Assessment Year: 2014-15 M/S.Caterpillar India Private Limited, The Deputy Commissioner Of 7Th Floor, International Tech Park, Income Tax, Taramani Road, Vs. Central Circle- 3(3), Chennai – 600 113. Chennai – 600 034. [Pan:Aabcc-4615-K] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपीलसं./Ita No.: 717/Chny/2023 िनधा"रण वष" / Assessment Year: 2014-15 The Deputy Commissioner Of Income M/S.Caterpillar India Private Tax, Limited, 7Th Floor, International Tech Park, Central Circle- 3(3), V. Chennai – 600 034. Taramani Road, Chennai – 600 113. [Pan:Aabcc-4615-K] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/Assessee By : Shri Harish Ramanathan, C.A. By Virtual ""थ" की ओर से/Department By : Shri A. Sasikumar, C.I.T. सुनवाई की तारीख/Date Of Hearing : 12.03.2025 घोषणा की तारीख/Date Of Pronouncement : 06.06.2025 आदेश /O R D E R Per S. R. Raghunatha, Am: These Cross Appeals Filed By The Assessee & The Revenue Are Arising Out Of Order Of Commissioner Of Income Tax (Appeals)-18, Chennai U/S. 143(3) R.W.S. 92Ca (3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) For The Assessment Year 2014-15 Dated 07.03.2023. Since, Facts Are Identical & Issues Are Common, For :-2-: It(Tp) A. No:42 /Chny/2023 & The Sake Of Convenience, The Appeal Filed By The Revenue & Assessee Are Being Heard Together & Disposed Off, By This Consolidated Order.

transfer pricing study has applied Transaction Net Margin Method (TNMM) as the most appropriate method and basis that the assessee concluded that the international transactions at arm's length price (ALP) in arriving at the operating profit margins of the assessee. While computing the ALP the assessee made certain adjustments to its operating cost base. One of the adjustments thus

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

4 of the said instruction clarified\nthat in a limited scrutiny, the scrutiny assessment proceedings would initially\nbe confined only to issues and questionnaire, enquiry, investigation etc.\nwould be restricted to such issues in the limited scrutiny. Only upon\nconversion of such case to complete scrutiny after following the procedure\nlaid down as stated, the AO may examine the issues

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. MOHANLAL JEWELLERS PRIVATE LIMITED, CHENNAI

transfer entries are as below: -\n\nITA Nos.1178 to 1182/Chny/2025 &\nITA Nos.1393 to 1397/Chny/2025 \n(AYs: 2017-18 to 2021-22)\nM/s. Mohanlal Jewellers Pvt. Ltd\n\n::73 :: \n\nAO, both Shri Kothari and Shri Khatri had admitted that, the entries in\nthis ledger was also unaccounted for and therefore the AO quantified the\n‘Vatav’ income from this

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)

price goes up in order to earn profits. In the result, the appeals filed by the Revenue challenging the judgment of the Punjab and Haryana High Court in State Bank of Patiala also fail, though law in this respect has been clarified hereinabove. 41. Having regard to the language of section 14A(2) of the Act, read with rule

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)

price goes up in order to earn profits. In the result, the appeals filed by the Revenue challenging the judgment of the Punjab and Haryana High Court in State Bank of Patiala also fail, though law in this respect has been clarified hereinabove. 41. Having regard to the language of section 14A(2) of the Act, read with rule

P PALANISMAY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

4) from N Sundaramoorthy, partner of PP Enterprises\nOddanchatram dated 11.08.2017 in Q No. 18, the partner has\nconfirmed the two-digit suppression system with example. The same\nwas confirmed by Shri Palanisamy in the statement recorded u/s.\n132(4) as well. The same was corroborated by the debtors who were\npresent at the premises of the two firms

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), CHENNAI, CHENNAI vs. RAMANATHAN VISWANATHAN, CHENNAI

In the result, all appeals filed by the assessee are allowed and the appeals of the Revenue are dismissed

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

transfer monies to the bank account(s) of his thirty eight (38) firms, which Shri CPA would withdraw in cash and hand over to the assessee. Shri CPA however expressed his unknowingness to the manner and mode in which the coal companies would allegedly pay monies to Shri PLA but submitted that somehow he would receive the monies

DCIT CENTRAL CIRCLE 2(1), CHENAI vs. C.VIJAYA BASKAR, PUDUKOTTAI

In the result, ITA Nos.695 to 702/Chny/2023 stands dismissed

134 -3,32,21,561\n2013-14 2014-15 5,76,37,413 10,55,25,105 -4,78,87,692\n2014-15 2015-16 1,23,91,96,963 20,79,31,748 1,03,12,65,215\n2015-16 2016-17 6,93,82,738 28,28,60,683 -21,34,77,945\n2016

M/S CHOLAMANDALAM INVESTMENT & FINANCE COMPANY LIMITED,CHENNAI vs. DCIT-1(2), CHENNAI

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

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

transferred substantially all the risk and rewards of the ownership of the said receivables and hence the assessee should have offered the entire profit on the assignment of receivables including Rs 2699.02 lakhs to tax during A.Y. 2012-13 only. 10.2 In the grounds of appeal, the appellant contested that the change in the accounting policy is bonafide