GOKULAKRISHNA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the stay\napplication is dismissed

price. He argued that there is no element of transfer so as to attract\nthe provision of section 2(47) of the Act and hence there cannot be any\nlevy of tax on capital gain under section 45 of the Act on the event of\nintroduction of a new partner. He has further submitted that even if the\namount

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 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

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

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

M/S. DOOWON AUTOMOTIVE SYSTEMS INDIA PVT. LTD.,KANCHEEPURAM vs. JCIT (OSD),, CHENNAI

In the result, the appeal of Revenue is allowed

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

Transfer Pricing (“TP”) 11 - - ITA 2560/Mds/16 order is vide ab initio. The TPO order treating foreign exchange loss as operating expense without providing an opportunity to the assessee is opposed to the principle of natural justice and fair play. The TPO erred in not appreciating the fact that the assessee has imported the raw materials at the same price every

EVERSENDAI CONSTRUCTION PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1), CHENNAI

In the result, appeal filed by the assessee is partly allowed for

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.2084/Chny/2017 िनधा"रण वष" /Assessment Year: 2013-14 M/S.Eversendai Construction- V. The Dy. Commissioner- Pvt. Ltd., Of Income Tax, Plot No.1 & 2, The Lords, Corporate Circle-2(1), Block-1, 5Th Floor, Chennai. Thiru-Vi-Ka Industrial Estate, Jawaharlal Nehru Road, Ekkaduthangal, Guindy, Chennai.

Section 143(3) r.w.s. 144C (13) of the Income Tax Act, 1961 by the Deputy Commissioner of Income-tax, Corporate Circle 2(1), Chennai ('the Assessing Officer'/'AO') is erroneous and contrary to law, facts and circumstances of the case. 2. Transfer Pricing ground - upward adjustment to arm's length price. General Ground 2.1 The directions of the Dispute Resolution

KELLER GROUND ENGINEERING INDIA PRIVATE LTD,CHENNAI vs. ACIT, CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Transfer Pricing Officer and the TPO has passed order u/s.92CA of the Act dated 14.01.2015vide C.R. No.Y-603/TPO 3(2)/A.Y.2011-12, in which the TPO has recommended downward adjustment of Rs.7,40,95,333/- incurred to Management Support Services received from its Associated Enterprises YCH, Singapore. Thereafter the DCIT, Corporate Circle 3(2), Chennai passed draft assessment order u/s.143

DCIT, CHENNAI vs. REGEN POWERTECH (P) LTD., CHENNAI

In the result, the appeal of the Assessee and Department are allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing study report issued by ERNST & YOUNG referred at page 18 to 60 of the paper book and also highlightened Audit report form no. 3CEB at page 70 of paper book were the international transactions with Associated Enterprise and method used being TNMM method disclosed alongwith comparative statements, on Royalty. The ld. TPO is of the opinion that assessee

REGEN POWERTECH PRIVATE LMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Assessee and Department are allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

Transfer Pricing study report issued by ERNST & YOUNG referred at page 18 to 60 of the paper book and also highlightened Audit report form no. 3CEB at page 70 of paper book were the international transactions with Associated Enterprise and method used being TNMM method disclosed alongwith comparative statements, on Royalty. The ld. TPO is of the opinion that assessee

AADARSH SURANA, CHENNAI,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 1(1), CHENNAI, CHENNAI

156 TTJ 777 (Panaji - Trib) submitted that\nwhere, assee, a proprietary concern, had transferred all his assets and\nliabilities to a company and against consideration, he was allotted shares of the\ncompany, even though value of those shares was much more than value of\nassets disclosed in books of proprietary concern, provisions of section 47(xiv)\nwould apply to transfer

RECKITT BENCKISER SCHOLL INDIA PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri D.S. Sunder Singhआयकर अपील सं./Ita No.756/Mds/2016 िनधा"रण वष" / Assessment Year : 2011-12 M/S. Reckitt Benckiser Scholl The Deputy Commissioner Of India Private Limited V. Income Tax, (Formerly Known As M/S. Corporate Circle – V (1), Reckitt Benekiser Scholl India Chennai Limited). Plot F 73/74, Sipcot Industrial Park, Irungattukottai, Sriperumbudur, Kancheepuram – 602 117

Section 10B of the Act provides for a deduction of such ‘profits and gains’ as are derived by a hundred percent export-oriented undertaking and not deduction of such ‘income’ of the undertaking. 6. The Appellant craves leave to add, alter, amend, substitute, rescind, modify and/or withdraw in any manner whatsoever all or any of the foregoing grounds of appeal

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

price (i.e., INR 275 per share) was wrongly assessed as income under Section 56(2)(viia) of the Act. The learned AO failed to note that the valuation of INR 607 determined under the DCF method is not in accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

price (i.e., INR 275 per share) was wrongly assessed as income under Section 56(2)(viia) of the Act. The learned AO failed to note that the valuation of INR 607 determined under the DCF method is not in accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back

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

In the result, the Cross Objections filed by the assessees in C

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

KALI BMH SYSTEMS PVT. LTD.,,KUMBAKONAM vs. DCIT, CIRCLE - 2 (1),, TRICHY

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

Bench: Shri V. Durga Rao & Shri Manoj Kumar Aggarwalआयकर अपील सं./I.T.A. No.864/Chny/2020 िनधा"रण वष"/Assessment Year: 2013-14 Kali Bmh Systems P. Ltd., The Deputy Commissioner Of 42/6, B2, Chennai Road, Vs. Income Tax, Melacauvery, Kumbakonam 612 002. Circle 2(1), Trichy. [Pan:Aadck0974H]

section 3 of the Securities and Exchange Board of India Act, 1992 (15 of 1992);’ We may exhibit this by way of an example, assuming (for the sake of simplicity) land as the only capital asset of the firm: 5 I.T.A. No.864/Chny/20 Table – 1A Liabilities (₹.) Assets (₹.) Capital 2000 Fixed Assets – Land 1000 Net Current Assets (NCA) 1000 (current assets – current