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

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

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

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. BEACH MINERALS SANDS COMPANY, TIRUNELVELI

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1473 To 1475/Chny/2023 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & Cross-Objection Nos. 28 To 30/Chny/2024 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & आयकर अपील सं./Ita Nos.13 & 14/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15 & Cross-Objection Nos. 26 & 27/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

transfer of funds through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Moreover, in both the categories of discrepancies, it is necessary for the Appellant to produce the bills and vouchers in support of the relevant expenditure in respect of which the corresponding credit entries were

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. BEACH MINERALS SANDS COMPANY, TIRUNELVELI

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1473 To 1475/Chny/2023 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & Cross-Objection Nos. 28 To 30/Chny/2024 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & आयकर अपील सं./Ita Nos.13 & 14/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15 & Cross-Objection Nos. 26 & 27/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

transfer of funds through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Moreover, in both the categories of discrepancies, it is necessary for the Appellant to produce the bills and vouchers in support of the relevant expenditure in respect of which the corresponding credit entries were

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. BEACH MINERALS SANDS COMPANY, TIRUNELVELI

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1473 To 1475/Chny/2023 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & Cross-Objection Nos. 28 To 30/Chny/2024 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & आयकर अपील सं./Ita Nos.13 & 14/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15 & Cross-Objection Nos. 26 & 27/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

transfer of funds through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Moreover, in both the categories of discrepancies, it is necessary for the Appellant to produce the bills and vouchers in support of the relevant expenditure in respect of which the corresponding credit entries were

ASSISTANT COMMISSIONER OF INCOME-TAX, MADURAI vs. BEACH MINERALS SANDS COMPANY, TIRUNELVELI

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1473 To 1475/Chny/2023 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & Cross-Objection Nos. 28 To 30/Chny/2024 िनधा"रणवष"/Assessment Years: 2015-16 To 2017-18 & आयकर अपील सं./Ita Nos.13 & 14/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15 & Cross-Objection Nos. 26 & 27/Chny/2024 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

transfer of funds through bank from the group entity and incurring of expenditure by the Appellant from such funds by withdrawing the same from the bank. Moreover, in both the categories of discrepancies, it is necessary for the Appellant to produce the bills and vouchers in support of the relevant expenditure in respect of which the corresponding credit entries were

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 :

Transfer Pricing Officer” shall have the same meaning as assigned to it in the Explanation to section 92CA.] 55[(2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed.] (3) Notwithstanding anything contained in sub-section

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

price method for income tax purposes. The AO has not made any attempt to reconcile the stock position as per the Tally system of accounting and SAP accounting system. He has also not brought on record any evidence as to why he could not accept the appellant's explanation for the variation in stock position which

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

price method for income tax purposes. The AO has not made any attempt to reconcile the stock position as per the Tally system of accounting and SAP accounting system. He has also not brought on record any evidence as to why he could not accept the appellant's explanation for the variation in stock position which

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

price method for income tax purposes. The AO has not made any attempt to reconcile the stock position as per the Tally system of accounting and SAP accounting system. He has also not brought on record any evidence as to why he could not accept the appellant's explanation for the variation in stock position which

DCIT CENTRAL CIRCLE 2, TUTICORIN vs. VVD & SONS (P) LIMITED, TUTICORIN

In the result, both the Cross Objections filed by the assessee are allowed and all the appeals filed by the Revenue are dismissed

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. Nos.2153, 2154 2155 & 2156/Chny/2018 िनधा"रण वष"/Assessment Years: 2013-14, 2014-15, 2015-16 & 2016-17 & C.O. Nos. 132 & 133/Chny/2018 [In Ita Nos. 2153 & 2154/Chny/2018] The Deputy Commissioner Of Vs. M/S. Vvd & Sons (P) Limited, Income Tax, No. 182, Palayamkottai Road, Central Circle 2, Tuticorin 628 008. Madurai. [Pan:Aaacv8438J] (अपीलाथ" /Appellant) (""थ"/Respondent/Cross Objector) अपीलाथ" की ओर से / Appellant By Shri R. Clement Ramesh Kumar, Cit For : Shri M. Rajan, Cit ""थ" की ओर से/Respondent By Shri R. Vijayaraghavan, Advocate : सुनवाई की तारीख/ Date Of Hearing 24.08.2023 : घोषणा की तारीख /Date Of Pronouncement : 13.09.2023 आदेश /O R D E R Per V. Durga Rao: These Four Appeals Filed By The Revenue Are Directed Against The Common Order Of The Ld. Commissioner Of Income Tax (Appeals) 19, Chennai, Dated 23.04.2018 Relevant To The Assessment Years 2013-14, 2014-15, 2015-16 & 2016-17. 2. The Appeals Filed By The Revenue Are Delayed By Three Days For Which, The Revenue Has Filed Affidavits For Condonation Of Delay, To Which 2

price method for income tax purposes. The AO has not made any attempt to reconcile the stock position as per the Tally system of accounting and SAP accounting system. He has also not brought on record any evidence as to why he could not accept the appellant's explanation for the variation in stock position which

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

145(3) of the Act.\n5.23 In support of our above findings, we also gainfully refer to the\ndecision of this Tribunal at Ahmedabad in the case of Cadila Healthcare\nLtd v. Addl. CIT [2012] 21 taxmann.com 483/[2015] 67 SOT 110 (Ahd\nTrib.) (URO) wherein this Tribunal, on similar facts & circumstances, had\nnegated the Revenue's contention that

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

transfer of funds\nthrough bank from the group entity and incurring of expenditure by the\nAppellant from such funds by withdrawing the same from the bank.\nMoreover, in both the categories of discrepancies, it is necessary for the\nAppellant to produce the bills and vouchers in support of the relevant\nexpenditure in respect of which the corresponding credit entries were

COASTAL ENERGY PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2305/Chny/2012 िनधा"रण वष"/Assessment Year: 2008-09 Coastal Energy Private Limited, Vs. The Assistant Commissioner Of 5, Buhari Buildings, Moores Road, Income Tax, Thousand Lights, Chennai 600 006. Company Circle I(3), Chennai. [Pan: Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 06.02.2026 आदेश /O R D E R

Section 145 of the Act. He argued vehemently that the Assessing Officer has not brought on record any discrepancy in the physical stock, nor has there been any adverse finding from any third-party verification or audit to support the claim that such short-supplied coal was lying unaccounted in closing stock. In the absence of any tangible evidence