DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 37 at INR 201,663 Transfer Pricing adjustment: INR 42,45,31,144 and thus a total additions of INR 65,52,97,718 was made

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 37 at INR 201,663 Transfer Pricing adjustment: INR 42,45,31,144 and thus a total additions of INR 65,52,97,718 was made

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 37 at INR 201,663 Transfer Pricing adjustment: INR 42,45,31,144 and thus a total additions of INR 65,52,97,718 was made

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

section 37 at INR 201,663 Transfer Pricing adjustment: INR 42,45,31,144 and thus a total additions of INR 65,52,97,718 was made

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

section) and for those in which the farm is supplied concrete from a factory. Construction Operations: Erecting wind turbines requires the efforts of many skilled construction workers. The work begins before the turbine components arrive on site: construction laborers and construction equipment operators are responsible for building local access roads and the foundations that support the turbines. Based

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

section) and for those in which the farm is supplied concrete from a factory. Construction Operations: Erecting wind turbines requires the efforts of many skilled construction workers. The work begins before the turbine components arrive on site: construction laborers and construction equipment operators are responsible for building local access roads and the foundations that support the turbines. Based

EATON POWER QUALITY PRIVATE LIMITED,PONDICHERRY vs. DCIT, PONDICHERRY

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

Bench: Shri Mahavir Singh, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 1010/Chny/2017 िनधा"रण वष" / Assessment Year: 2012-13 Eaton Power Quality Private The Deputy Commissioner Of Limited, V. Income Tax, No.2, Evr Street Sedarapet, Pondicherry Circle, Puducherry 605 111, Pondicherry. Puducherry (Ut). [Pan: Aacc-6943-R] आयकर अपील सं./It(Tp)A No.: 35/Chny/2021 िनधा"रण वष" / Assessment Year: 2016-17 Eaton Power Quality Private The Assessing Officer, Limited, V. National E-Assessment Centre, No.2, Evr Street Sedarapet, Delhi. Puducherry 605 111, Puducherry (Ut). [Pan: Aacc-6943-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Vishal Kalra, Advocate : Shri. S. Maruthu Pandian, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 01.05.2023 घोषणा क" तारीख/Date Of Pronouncement : 03.05.2023 आदेश /O R D E R

Section 153 expires’. Excluding 31.12.2019, the period of 60 days would expire on 01.11.2019 and the transfer pricing orders thus ought to have been passed on 31.10.2019 or any date prior thereto. Incidentally, the Board, in the Central Action Plan also indicates the date by which the Transfer Pricing orders are to be passed as 31.10.2019. The impugned orders

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 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 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

ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

Transfer Pricing Officer is extended\nto sixty days in accordance with the proviso to sub-section (3A) of section 92CA and the\n\nperiod of limitation available to the Assessing Officer for making an order of assessment,\nreassessment or recomputation, as the case may be, is less than sixty days, such remaining\nperiod shall be extended to sixty days

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

transfer pricing adjustment for fresh adjudication. Simultaneously, the assessee also challenged the order of Tribunal i.e., original order passed in ITA No.322/Mds/2016 dated 30.06.2016 and also challenged the Tribunal order passed in M.P. No.218/Mds/2016 dated 04.04.2017 before Hon’ble High Court of Madras and the Hon’ble High Court in Tax Case Appeal Nos.480 and 473 of 2017 vide order

INTERNATIONAL SEAPORT DREDGING LIMITED,CHENNAI vs. DCIT, CHENNAI

The appeal stand allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकर अपील सं./ Ita No.72/Chny/2018 (िनधा)रणवष) / Assessment Year: 2013-14) & आयकर अपील सं./ It (Tp)A No.35/Chny/2018 (िनधा)रणवष) / Assessment Year: 2014-15) & आयकर अपील सं./ It (Tp)A No.87/Chny/2019 (िनधा)रणवष) / Assessment Year: 2015-16) M/S. International Seaport Dredging Dcit / Jcit(Osd) Private Limited, Corporate Circle-2(2) बनाम 5Th Floor, Challam Towers, Chennai. Old No.62, New No.113, / Vs. Dr.Radhakrishnan Salai Chennai-600 004. "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aabci-2286-E (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Ashik Shah (C.A) – Ld.Ar ""थ"कीओरसे/Respondent By : Shri A.Sasi Kumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 05-02-2025 घोषणाकीतारीख /Date Of Pronouncement : 02-05-2025 आदेश / O R D E R Per Manu Kumar Giri, Jm: These Appeals By Assessee For Assessment Years (Ay) 2013-14 & 2014-15 Arise Out Of The Separate Orders Of Assessments Framed By Ld.

transfer pricing adjustment towards lease rental payments for AY 2013-14 and upheld the other adjustments and disallowances for AY 2013-14. 1. Further for the AY 2014-15, the DRP allowed the exclusion of certain comparable companies for computation of the upward adjustment made towards income received from deputation of personnel, while upholding the other adjustments made

DCIT, CHENNAI vs. ARMSTRONG INERNATIONAL PVT. LTD., CHENGALPUT

In the result, the appeal of the assessee for the A

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

transfer pricing documents page No.39 submitted by the assessee company, it was noticed by the TPO that while computing the margin, a part of expenditure amounting to Rs.7,26,74,144/- was segregated as expenditure towards the market development/Brand promotion expenses. 4.3 The assessee company claimed Rs.8.60 Cr. as operating cost and admitted the operating income of Rs.9.43 Cr. resulting

ARMSTRONG INTERNATIONAL PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee for the A

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

transfer pricing documents page No.39 submitted by the assessee company, it was noticed by the TPO that while computing the margin, a part of expenditure amounting to Rs.7,26,74,144/- was segregated as expenditure towards the market development/Brand promotion expenses. 4.3 The assessee company claimed Rs.8.60 Cr. as operating cost and admitted the operating income of Rs.9.43 Cr. resulting

ARMSTRONG INTERNATIONAL PRIVATE LIMITED,CHENGALPUT vs. DCIT, CHENNAI

In the result, the appeal of the assessee for the A

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

transfer pricing documents page No.39 submitted by the assessee company, it was noticed by the TPO that while computing the margin, a part of expenditure amounting to Rs.7,26,74,144/- was segregated as expenditure towards the market development/Brand promotion expenses. 4.3 The assessee company claimed Rs.8.60 Cr. as operating cost and admitted the operating income of Rs.9.43 Cr. resulting

AUGUSTAN KNITWEAR P LTD.,COIMBATORE vs. ACIT, COIMBATORE

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

section 92CA) or the Commissioner (Appeals) may direct that such person shall pay, by way of penalty, a sum equal to two per cent of the value of the international transaction (or specififed domestic transaction) for each such failure] The ld. Authorised Representative vehemently argued that the provisions of Sec.271AA of the Act does not apply and Assessing Officer