ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPUR vs. SRI SHANMUGAVEL MILLS PRIVATE LIMITED, TIRUPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

transfer of such goods or services is a specified domestic transaction referred to in section 92BA? Sri Shanmugavel Mills Pvt. Ltd :: 12 :: (b) WHETHER in facts of the case and in law, the Hon'ble ITAT is justified in not appreciating the finding of the TPO that the assessee's generating unit cannot as such claim any benefit under section80IA

TITAN COMPANY LIMITED,HOSUR vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.393/Chny/2018 & आयकर अपील सं./ It(Tp)A No.89/Chny/2018 िनधा>रण वष> /Assessment Years: 2013-14 & 2014-15 Titan Company Ltd., The Dy. Commissioner Of Income No.3, Spicot Industrial Complex, Vs. Tax, Hosur, Krishnagiri – 635 126. Ltu-2, [Pan: Aaact 5131A] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing (TP) adjustment related to the claim u/s. 80IC ITA No.393/Chny/2015 & IT(TP)A No.89/Chny/2018 Titan Company Ltd. :- 3 -: of the Act. For the first two issues, the assessee placed reliance on the order of the Co-ordinate Bench of the Tribunal in the Assessee’s own case for earlier assessment years, vide ITA Nos. 518, 505– 507/2018 dated

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.

154 of the Act dated August 08, 2023 issued 349 by the Ld. AO, received vide mail dated August 24, 2023 V. Documents relied upon in connection with proceedings under section 263 of the Act 12 Submission dated August 31, 2023, filed with the Ld. 361 Commissioner of Income Tax ("Ld. CIT"), in response to the SCN dated August

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

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

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

pricing adjustments,\ndisallowance u/s.14A of the Act and disallowance of depreciation on goodwill\narising on amalgamation. The Id. CIT(A) has partially allowed the appeals of\nthe assessee. Now the Revenue has filed appeals in ITA No.:\n1731/CHNY/2024, ITA No.: 1682/CHNY/2024 and ITA No.: 1763/CHNY/2024\nfor AY 2014-15, AY 2015-16 and AY 2017-18 respectively. Further, the\nassessee

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,TIRUPPUR, TIRUPPUR vs. PRABHU SPINNING MILLS PRIVATE LIMITED, TIRUPPUR

In the result all the grounds raised by the revenue for the A

transfer of such goods or services is a specified\ndomestic transaction referred to in section 92BA?\n(b) WHETHER in facts of the case and in law, the Hon'ble ITAT is justified in not\nappreciating the finding of the TPO that the assessee's generating unit cannot as\nsuch claim any benefit under section801A of the Income

DURR INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, all the grounds of the appeal are treated as allowed for statistical purposes

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

154 TNMM OP/OC 69.79% 9.53% Engineering design services Reimbursement of 1,79,8 1,455 NA NA NA NA actual expenses by to the AE Reimbursement of 8,85,789 NA NA NA NA actual expenses by the AE Total Rs.19,20,75,835 5. The assessee using Transactional Net Margin Method (TNMM) as Most Appropriate Method (MAM) determined

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

pricing adjustments,\ndisallowance u/s.14A of the Act and disallowance of depreciation on goodwill\narising on amalgamation. The Id. CIT(A) has partially allowed the appeals of\nthe assessee. Now the Revenue has filed appeals in ITA No.:\n1731/CHNY/2024, ITA No.: 1682/CHNY/2024 and ITA No.: 1763/CHNY/2024\nfor AY 2014-15, AY 2015-16 and AY 2017-18 respectively. Further, the\nassessee

DCIT, CHENNAI vs. JAGATHRAKSKAN SRINISHA, CHENNAI

transferred to the Jewellers for purchase. There are\nno receipts available for the said cash purchases and no submission as to from which\nJeweller such huge amount of Jewellery has been purchased. In the absence of the\nabove documents evidencing purchase of jewellery, it is evident that the cash withdrawals\nhave been used for some other purpose

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

pricing adjustments,\ndisallowance u/s.14A of the Act and disallowance of depreciation on goodwill\narising on amalgamation. The Id. CIT(A) has partially allowed the appeals of\nthe assessee. Now the Revenue has filed appeals in ITA No.:\n1731/CHNY/2024, ITA No.: 1682/CHNY/2024 and ITA No.: 1763/CHNY/2024\nfor AY 2014-15, AY 2015-16 and AY 2017-18 respectively. Further, the\nassessee

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

transfer pricing adjustment or addition is warranted on this account. 32. The ld. AR drew our attention to pages 49-50 of the Paper Book, a rectification petition under section 154

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

TITAN INDUSTRIES LIMITED,HOSUR vs. JCIT, CHENNAI

The appeal stands partly allowed in terms of our above order

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

section 234C as consequential in nature and not on the returned income. 2. This appeal was heard along with assessee’s appeal for AYs 2006-07 & 2007-08 on the same day. The appeals for AYs 2006-07 & 2007-08 have separately been disposed-off by us. It was admitted position that the facts as well as issues in this

DAESEUNG AUTOPARTS INDIA PRIVATE LIMITED,KANCHEEPURAM vs. ACIT (OSD), CHENNAI

The appeal stand partly allowed in terms of our above order

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.752/Chny/2017 (िनधा;रणवष; / Assessment Year: 2012-13) M/S. Daeseung Autoparts India Pvt. Ltd. Acit (Osd) Plot No,474, Mannur Village, Corporate Range-1, बनाम/ Vs. Valarpuram Post, Sriperumpudhur Taluk Chennai. Kanchipuram- 602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccd-5629-D (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Vikram Vijayaraghavan (Advocate)- Ld. Ar " थ"कीओरसे/Respondent By : Shri G. Suresh (Jcit)- Ld. Sr. Dr सुनवाई की तारीख/Date Of Hearing : 28-05-2024 घोषणा की तारीख /Date Of Pronouncement : 04-06-2024 आदेश / O R D E R Manoj Kumar Aggarwal ()

154 which were disposed-off vide order dated 07.03.2016. Incorporating the same, a draft assessment order was passed on 15.03.2016 which was subjected to assessee’s objections before Ld. DRP. Pursuant to the directions of Ld. DRP, final assessment order was passed against which the assessee is in further appeal before us. The grounds of appeal read as under

SOCOMEC INNOVATIVE POWER SOLUTIONS PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 848/Chny/2017 िनधा"रण वष" / Assessment Year: 2012-13 M/S. Socomec Innovative Deputy Commissioner Of Power Solutions Pvt Ltd., V. Income Tax, (Formerly Known As Socomec Corporate Circle 6(2), Ups India Pvt Ltd) Chennai – 600 034. Thiru-Vi-Ka Industrial Estate, Guindy, Chennai – 600 032. [Pan: Aakcs-3579-H] (अपीलाथ"/Appellant) (""यथ"/Respondent) : Shri. Darpan Kirpalani, Advocate अपीलाथ" क" ओर से/Appellant By ""यथ" क" ओर से/Respondent By : Shri. Marutha Pandiarajan, Cit सुनवाई क" तारीख/Date Of Hearing : 05.07.2023 घोषणा क" तारीख/Date Of Pronouncement : 12.07.2023

Section 234B of the Act. The above grounds of appeal are mutually exclusive and without prejudice to each other. The Appellant craves leave to add, alter, amend or vary any of the above grounds either before or at the time of hearing as may be advised. The grounds taken hereinabove are without prejudice to each other.” 3. The brief facts