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 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

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

142(1) were issued, which were complied with by the assessee. At the onset, the AO noted that the assessee didn’t file the Form 10CCB within the due date of filing of return of income and ITA No.870/Chny/2017 for AY 2012-13 & ITA Nos.338 & 339/Chny/2020 for AYs 2013-14 & 2014-15 M/s. Mahindra Residential Developers Ltd. :: 3 :: therefore

INTERNATIONAL FLAVOURS & FRAGRANCES INDIA PRIVATE LIMITED,CHENNAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX, CHENNAI

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

142(1) of the Act calling for various details and conducted a complete inquiry. After going through various submissions filed by the assessee from time to time, the AO passed an order u/s.143(3) of the Act dated 05.05.2022 with the following additions: Particulars Amount in INR Income as per section 143(1) 1,22,06,84,110 Add: Transfer

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

142(1) of the Act were issued by DCIT, Company Cirlce-12(5), Chennai. A draft assessment order was passed by DCIT, Corporate Circle 3(2), Chennai u/s.143(3) r.w.s 92CA(3) of the Act vide order dated 13.03.2015 after passing of transfer pricing adjustment order by the DCIT, Transfer Pricing Officer-3(2) (i/c), Chennai u/s.92CA

YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing adjustment. Further, it was held that where the PLI of the assessee under TNMM is at arm’s length and it is not possible on the part of the department to identify a comparable, which is rendering similar services, the question of considering CUP method would not arise at all. Since the assessee has stated that

NETHERLANDS OPERATING COMPANY B.V.,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, INT. TAXATION 2(1), CHENNAI, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1198/Chny/2023 िनधा"रणवष"/Assessment Year: 2010-11 V. Netherlands Operating Company B.V. The Acit, Rmz Millenia (Phase-1), International Taxation -2(1), Business Park, 4Th Floor, Campus 1C, Chennai. 11, Dr. M.G.R. Road, Kandanchavadi, Perungudi, Chennai-600 096. [Pan: Aabcl 0573 D] (अपीलाथ"/Appellant) (""यथ"/Respondent)

142 or (sub-section (2) of section 115WE or] sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier, 4.11 The appellant is aware that there is no notice u/s 143(2). However, it has participated in the assessment proceedings willingly and compliantly and Netherlands Operating Company B.V. :: 7 :: haven't raised any question

THE INDIA CEMENTS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1) CHENNAI, CHENNAI

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

142(1) dated 19.08.2019 as to why the above items should not be treated as revenue receipts and the claim of deduction in the computation statement be not disallowed. The assessee submitted that the receipts relating to Parli Unit, Maharashtra, were in the nature of capital subsidy granted to the unit / incentive for investing in the backward area and hence

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

142(1) of the Act in 'Limited Scrutiny' cases shall remain confined only to the specific reasons/issues for which case has been picked up for scrutiny. Further, the scope of enquiry shall be restricted to the 'Limited Scrutiny' issues. c. These cases shall be completed expeditiously in a limited number of hearings. d. During the course of assessment proceedings

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

price is equal or higher, the said provision has no implication. It is noted from Rule 11UA(1) that, the valuation methodology set out therein is to be applied for the purposes of Section 56 of the Act, and more specifically Rule 11UA(1)(c) is relevant to the present case. The valuation method set out in Rule 11UA

YCH LOGISTICS LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No. 944/Chny/2015 िनधा"रण वष"/Assessment Year:2010-11 M/S. Ych Logistics (India) Private The Deputy Commissioner Of Limited, Plot No. Dv1, Sipcot Hi-Tech Vs. Income Tax, Sez, Phase Ii, Sirumangadu Village, Corporate Circle 3(2), Sriperumbudur Taluk, Kancheepuram Chennai. District, Tamil Nadu 602 105. [Pan:Aaacy2873L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ajit Kumar Jain, Ca ""थ" की ओर से/Respondent By : Shri S. Palanikumar, Cit सुनवाई की तारीख/ Date Of Hearing : 07.07.2022 घोषणा की तारीख /Date Of Pronouncement : 30.08.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Assessment Order Passed Under Section 143(3) R.W.S. 144C(5) Of The Income Tax Act, 1961 [“Act” In Short] Dated 14.01.2015 Relevant To The Assessment Year 2010-11. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Providing Logistics Services & Filed Its Return Of Income On 20.07.2011 For The Assessment Year 2010-11 Admitting Loss Of 2

142(1) along with questionnaire was issued. In response, the assessee filed various details as called for. During the course of assessment proceedings, on perusal of the details furnished by the assessee, the Assessing Officer has noted that the value of international transactions of the assessee has exceeded the prescribed limit, the reference was made to ld. TPO for proper

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

142(1) of the Act dated October 07, 221 2022, issued by the Ld. AO 7.2. Statement of computation of income of the Appellant for AY 225 2018-19 7.3. Financial statements of the Appellant for FY 2017-18 230 8 Submission dated March 21, 2023, filed with the AO in response 233 to the show cause notice ("SCN") dated

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

142(1) were issued, which were complied with\nby the assessee.\nAt the onset, the AO noted that the assessee didn't file\nthe Form 10CCB within the due date of filing of return of income and\ntherefore he opined that the deduction claimed u/s 80-IAB ought to be\ndisallowed on this count alone. On merits, the AO noted

KELLER GROUND ENGINEERING INDIA PRIVATE LTD,CHENNAI vs. ACIT, CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

142(1) of the Act dated 03.08.2012 & 09.04.2013 were issued by DCIT, Company Circle 12(5), Bangalore and later the jurisdiction was transferred to Corporate Circle 3(2), Chennai. In this case, the AO noticed that the assessee has entered into international transaction with its Associated Enterprises exceeding Rs.15 crores. Therefore, as per the Board’s circular / notification, the matter

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

142(1) of the Act were issued. In compliance the ld. Authorised Representative of assessee appeared from time to time and filed information. The ld. Assessing Officer in the assessment found that assessee has international transactions exceeding "15 Crores and reference was made to Transfer Pricing Officer (hereinafter ‘’TPO’’) by letter dated 13.03.2014 for determining Arms’s Length Price

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

142(1) of the Act were issued. In compliance the ld. Authorised Representative of assessee appeared from time to time and filed information. The ld. Assessing Officer in the assessment found that assessee has international transactions exceeding "15 Crores and reference was made to Transfer Pricing Officer (hereinafter ‘’TPO’’) by letter dated 13.03.2014 for determining Arms’s Length Price