SAINT-GOBAIN INDIA PRIVATE LIMITED,CHENNAI vs. DCIT NCC 8(1), CHENNAI

In the result, the assessee succeeds

Bench: Shri Aby T. Varkey & Shri Jagadish

153(4) of the Act in case of the Appellant since transfer pricing reference was made additional 12 months Time limit for issuance of Transfer Pricing Order as per 31/10/2019 Section

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

transfer pricing, is only directory or a rough and ready guideline. This argument is rejected. 30. Now, coming to the question of how the 60 day period is to be computed, the critical question would be whether the period of 60 days would be computed including the 31st of December or excluding it. Section 153

DEPUTY COMMISSIONER OF INCOME TAX, TRICHY vs. DALMIA CEMENT (BHARAT) LIMITED, TRICHY

In the result, the appeal filed by the Revenue is dismissed

Bench: SHRI MAHAVIR SINGH (Vice President), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)

section 153(4) of the Act in the cases where the matter is referred to transfer pricing adjustment. It was contended

PFIZER HEALTHCARE INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CIRCLE-1-LTU, CHENNAI

In the result, the corporate additions made in the assessment order would not survive

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.641/Chny/2023 (िनधा9रण वष9 / Assessment Year: 2016-17) M/S.Pfizer Healthcare India Pvt. Limited Dcit (Formerly Known As Hospira Healthcare India Corporate Circle-5(2)-Ltu, बनाम/ Private Limited) Chennai. Vs. 237, Emerald Building, Anna Salai, Chennai-600 006. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aabco-2190-F (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri Ashik Shah (Ca)-Ld. Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 09-05-2024 घोषणा की तारीख /Date Of Pronouncement : 03-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

153(4) of the Act in case of the Appellant since transfer pricing reference was made additional 12 months Time limit for issuance of Transfer Pricing Order as per Section

GANESAN KANNAN,THOOTHUKUDI vs. ITI, INTERNATIONAL TAXATION WARD, THOOTHUKUDI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 698/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19

transfer pricing adjustments have been made under sub-section (3) of section 92CA of the Act, the Assessing Officer {AO) is required to forward a draft assessment order to the eligible assessee, if he proposed to make any variation in the :-12-: ITA. No:698/Chny/2024 income or loss returned which is prejudicial to the interest of such assessee. Such eligible

SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-I,, ERODE

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.1955 & 1956/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15) Sri Maharaja Refineries, # 128, Bhavani Road, Erode-638 004. Vs The Assistant Commissioner Of Income-Tax, Circle-1, Erode. Pan: Aaffs-8491-N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे / Appellant By प्रत्यर्थीकीओरसे/Respondent By : Mr. S.Sridhar, Advocate (Erode) : Mr. R.Clement Ramesh Kumar, Cit & Ms.Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख / Date Of Pronouncement : 07.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)] Both Dated 07.06.2024 For

153(5) of the Act, which is reproduced hereunder for ready reference: "(5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263, or section 264 is to be given by the Assessing Officer or the Transfer Pricing

SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-1, ERODE

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकरअपीलसं./I.T.A.Nos.1955 & 1956/Chny/2024 (निर्धारणवर्ष / Assessment Years: 2013-14 & 2014-15) Sri Maharaja Refineries, # 128, Bhavani Road, Erode-638 004. Vs The Assistant Commissioner Of Income-Tax, Circle-1, Erode. (प्रत्यर्थी/Respondent) Pan: Aaffs-8491-N (अपीलार्थी/Appellant) अपीलार्थीकीओरसे / Appellant By : Mr. S.Sridhar, Advocate (Erode) प्रत्यर्थीकीओरसे/Respondent By : Mr. R.Clement Ramesh Kumar, Cit & Ms.Anitha, Addl.Cit सुनवाईकीतारीख/Date Of Hearing : 19.02.2025 घोषणाकीतारीख / Date Of Pronouncement : 07.05.2025 आदेश / Order Per Manu Kumar Giri, Jm: The Captioned Appeals Filed By The Assessee Are Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals)(Nfac), Delhi [Cit(A)] Both Dated 07.06.2024 For

153(5) of the Act, which is reproduced hereunder for ready reference: "(5) Where effect to an order under section 250 or section 254 or section 260 or section 262 or section 263, or section 264 is to be given by the Assessing Officer or the Transfer Pricing

HARLAND CLARKE HOLDING SOFTWARE INDIA PRIVATE LIMITED,CHENNAI vs. DCIT COMPANY CIRCLE 2(2), CHENN

In the result, the appeal of the assessee is partly allowed

Bench: Shri George Mathan & Shri S.Jayaraman

sections 234B & 234C of the Act and Ground No.15 was against the initiation of penalty u/s.271(1)(c) of the Act. The grounds Nos.14 & 15 were not argued by ld.A.R. Consequently, the same is dismissed as not pressed. 5. In regard to the transfer pricing issues, it was submitted by ld.A.R that the assessee has three lines of business

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 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 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

RAMAKRISHNAN PRABHU JYOTHI,,COIMBATORE vs. ACOT, NCC-5, , COIMBATORE

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita Nos.690/Chny/2020 निर्धारण वर्ष /Assessment Years: 2016-17 Ramakrishnan Prabhu Jyothi, Race Course, Coimbatore, Tamil Nadu-641018, [Pan: Adjpp4946N] Asst. Commissioner Of Income Tax, Non-Corporate Circle-5, Coimbatore. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By : Shri N.P.Vijay Kumar, Advocate प्रत्यर्थी की ओर से /Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/Date Of Hearing : 27.05.2024 घोषणा की तारीख /Date Of Pronouncement : 23.08.2024 आदेश / Order Per Amitabh Shukla, A.M : This Appeal Is Filed Against The Order Bearing Din & Order No.Itba/Apl/S/250/2029-20/1026334108(1) Dated 09.03.2020 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), For The

153 in case it is assumed that Valuation Officer is entitled to submit report for period of 6 months Period from 28.12.2019 to 30.06.2019 is excluded :- 5 -: ITA No.690/Chny/2020 7 Valuation Report submitted (No valuation report submitted. Only comment submitted by Valuation officer) 09.08.2019 8 Assessment Order. No opportunity of being heard 14.08.2019 Interpretation and application of Section

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. HITACHI SOLUTIONS INDIA PRIVATE LIMITED , KANCHIPURAM

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

Bench: SHRI GEORGE GEORGE K, VICE PRESIDENT AND\nSHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER\nआयकर अपीलसं./IT(TP)A No.: 17/CHNY/2024\nनिर्धारण वर्ष / Assessment Year: 2018-19\nHitachi Solutions India Private\nLimited,\nBlock 5, 10th Floor, 1/124,\nDLF IT Park, Shivaji Gardens,\nMount Poonamallee Road,\nChennai - 600 089.\nThe Deputy Commissioner of\nIncome Tax,\nVs. Corporate Circle- 1(1),\nNo.121, M.G.Road,\nChennai - 600 034.\n[PAN:AAACZ-1544-R]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent)\nआयकर

Transfer Pricing Officer ("Ld. TPO") after the original limitation period of 18 months. As per the first proviso to Section 153

DCIT, CENTRAL CIR-2, MADURAI vs. M SHAHJAHAN, PALAKKAD

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.355, 356, 357 & 358 /Chny/2019 निर्धारण वर्ष / Assessment Year: 2012-13, 2013-14, 2014-15 & 2015-16 & Co 32, 33, 34 & 35 /Chny/2019

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

DCIT, CENTRAL CIRCLE-2, MADURAI vs. J S NIHAR BANU, PALAKKAD

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.355, 356, 357 & 358 /Chny/2019 निर्धारण वर्ष / Assessment Year: 2012-13, 2013-14, 2014-15 & 2015-16 & Co 32, 33, 34 & 35 /Chny/2019

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

DCIT, CENTRAL CIRCLE-2, MADURAI vs. ACHU TRADERS, PALAKKAD

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.355, 356, 357 & 358 /Chny/2019 निर्धारण वर्ष / Assessment Year: 2012-13, 2013-14, 2014-15 & 2015-16 & Co 32, 33, 34 & 35 /Chny/2019

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

DCIT, CENTRAL CIRCLE-2, MADURAI vs. ACHU TRADERS, PALAKKAD

Bench: Shri Manu Kumar Giri & Shri Amitabh Shuklaआयकर अपील सं./Ita No.355, 356, 357 & 358 /Chny/2019 निर्धारण वर्ष / Assessment Year: 2012-13, 2013-14, 2014-15 & 2015-16 & Co 32, 33, 34 & 35 /Chny/2019

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