ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

3)(g) of Income-tax Rules, 1962. Therefore, according to the Ld. Sr. Standing Counsel, the CIT(Appeals) is not justified in deleting the penalty under Section 271G of the Act. 49. On the contrary, Shri G. Baskar, the Ld.counsel for the assessee, submitted that the Assessing Officer levied penalty of ` 1,43,58,919/- under Section 271G

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

3)(g) of Income-tax Rules, 1962. Therefore, according to the Ld. Sr. Standing Counsel, the CIT(Appeals) is not justified in deleting the penalty under Section 271G of the Act. 49. On the contrary, Shri G. Baskar, the Ld.counsel for the assessee, submitted that the Assessing Officer levied penalty of ` 1,43,58,919/- under Section 271G

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

3)(g) of Income-tax Rules, 1962. Therefore, according to the Ld. Sr. Standing Counsel, the CIT(Appeals) is not justified in deleting the penalty under Section 271G of the Act. 49. On the contrary, Shri G. Baskar, the Ld.counsel for the assessee, submitted that the Assessing Officer levied penalty of ` 1,43,58,919/- under Section 271G

M/S. STERLITE INDUSTRIES (INDIA) LTD.,MADURAI vs. ADDITIONAL CIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

3)(g) of Income-tax Rules, 1962. Therefore, according to the Ld. Sr. Standing Counsel, the CIT(Appeals) is not justified in deleting the penalty under Section 271G of the Act. 49. On the contrary, Shri G. Baskar, the Ld.counsel for the assessee, submitted that the Assessing Officer levied penalty of ` 1,43,58,919/- under Section 271G

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

3)(g) of Income-tax Rules, 1962. Therefore, according to the Ld. Sr. Standing Counsel, the CIT(Appeals) is not justified in deleting the penalty under Section 271G of the Act. 49. On the contrary, Shri G. Baskar, the Ld.counsel for the assessee, submitted that the Assessing Officer levied penalty of ` 1,43,58,919/- under Section 271G

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

Transfer Pricing assessment. In the said valuation, the option to convert was valued using Cox Ross Rubinstein Model. The annualized return on the investment determined on the basis of such valuation, it can be established that the effective annualized yield on the investment is higher than the arm's length earning on a lending in foreign exchange. Further, details

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

Transfer Pricing assessment. In the said valuation, the option to convert was valued using Cox Ross Rubinstein Model. The annualized return on the investment determined on the basis of such valuation, it can be established that the effective annualized yield on the investment is higher than the arm's length earning on a lending in foreign exchange. Further, details

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

Transfer Pricing assessment. In the said valuation, the option to convert was valued using Cox Ross Rubinstein Model. The annualized return on the investment determined on the basis of such valuation, it can be established that the effective annualized yield on the investment is higher than the arm's length earning on a lending in foreign exchange. Further, details

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

Transfer Pricing assessment. In the said valuation, the option to convert was valued using Cox Ross Rubinstein Model. The annualized return on the investment determined on the basis of such valuation, it can be established that the effective annualized yield on the investment is higher than the arm's length earning on a lending in foreign exchange. Further, details

NATESAN KRISHNAMURTHY ,CHENNAI vs. ITO NON CORPORATE WARD 9(2) , CHENNAI

In the result, the appeal of the assessee stands dismissed

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No. 1672/Chny/2017 "नधा"रण वष" /Assessment Year : 2013-2014. Natesan Krishnamurthy, Vs. The Income Tax Officer, 24/60, Mookathal Street, Non Corporate Ward 9(2) Purasawalkam, Chennai 600 034. Chennai 600 007. [Pan Ancpk 2634B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

prices and accept cash from :- 4 -: outside bidders like me or by Ch/RTGS if it was bid successfully by Manappuram Group. The usual procedure will be to form a syndicate bidders ranging from 10 to 25 persons to a void increase In the, cost of auction gold and' after successive bidding by me, I will collect cash from each

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. ALBA INDUSTRIES LIMITED, CHENNAI

Bench: Shri Aby T. Varkey & Shri Jagadish

transfer of funds through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Appellant from such funds by withdrawing the same from

FORD INDIA (P) LTD,CHENNAI vs. DY CIT LTU, CHENNAI

In the result, the assessee’s appeal is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.2344 & 2345/Mds/2012 "नधा*रण वष* /Assessment Year: 2005-06 & 2008-09

3 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward3a a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation

FORD INDIA (P) LTD,CHENNAI vs. DY CIT LTU, CHENNAI

In the result, the assessee’s appeal is allowed

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singhआयकर अपील सं./Ita Nos.2344 & 2345/Mds/2012 "नधा*रण वष* /Assessment Year: 2005-06 & 2008-09

3 144C. (1) The Assessing Officer shall, notwithstanding anything to the contrary contained in this Act, in the first instance, forward3a a draft of the proposed order of assessment (hereafter in this section referred to as the draft order) to the eligible assessee if he proposes to make, on or after the 1st day of October, 2009, any variation

M/S. BRITISH AGRO PRODUCTS (INDIA) PVT. LTD.,CHENNAI vs. PCIT-1, CHENNAI

In the result, the appeal of the assessee is allowed

Transfer Pricing Officer” shall\nhave the same meaning as assigned to it in the Explanation to section 92CA.]\n55[(2) No order shall be made under sub-section (1) after the expiry of two years\nfrom the end of the financial year in which the order sought to be revised was\npassed.]\n(3) Notwithstanding anything contained in sub-section

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 145(3) of the Act and that by not doing so, the action of the AO in estimating the profits of the eligible unit was unjustified. 5.7 The Ld. AR further showed the comparative figures of the gross profit and net profit of the eligible unit and other non-eligible units and showed that the profits of Pantnagar were