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

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

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

158 Germany and accessories DurrPaintshop 1,56,427 Systems,Shangai OLPI Durrs.p.a 12,26,511 Total 1,36,01,096 2 Durr Systems GmbH, Import of traded 15,29,542 Germany goods 3 Durr Systems GmbH, Purchase of fixed 1,33,484 Germany assets 4 Durr Systems GmbH, Payment of 9,83,41,500 Germany research and development and management

THE INDIA CEMENTS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 2(1) CHENNAI, CHENNAI

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

158/- 7.1 Aggrieved by the above action of the Ld. CIT(A) partly confirming the disallowance made by the AO, the assessee is now in appeal before us. ITA No.2174/Chny/2024 (AY 2017-18) M/s. The India Cements Ltd. :: 21 :: 7.2 Heard both the parties. Though the Ld. AR appearing for the assessee vehemently contended in support of this ground

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 154 of the Act, which specifically seeking the error in the original assessment by furnishing revised arm’s length price, the detailed computation is reproduced as under: Name of Rate Qty Price before Discount Price after Index Price Range Conclusion Vessel before discount discount discount Coastal

PANASONIC INDIA PVT LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is treated as 10

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A. No. 479/Mds/2016 "नधा"रण वष" /Assessment Year : 2007-2008. M/S. Panasonic India Pvt. Ltd, Vs. The Deputy Commissioner Of Spic Building Annexe, 6Th Floor, Income Tax, 88, Mount Road, Company Circle V(1) Guindy, Chennai. Chennai 600 032. [Pan Aadcp 9391B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Transfer Pricing Officer to pass a consequential order by verifying the fact after affording opportunity of hearing to the assessee’’. The Tribunal following the Special Bench decision in the case of L.G. Electronics India (P) Ltd vs. ACIT (2013) 22 ITR (Trib) 1 held that the component of business promotion expenditure had to be considered as expended for the purpose

R.SRINIVASAN,CHENNAI vs. DCIT CENTRAL CIRCLE 1, COIMBATORE

In the result, appeal filed by assessee is partly allowed

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकर अपीलसं./I.T.A.No.1466/Chny/2018 ("नधा"रणवष" / Assessment Year: 1996-97) Mr.R.Srinivasan Vs The Deputy Commissioner Of 103, Ashok Nagar Main Road Income Tax, Kodambakkam, Corporate Circle-I(2) Chennai-600 024. Chennai. Pan : Aaips 8386H (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer of amounts by Ponnambalam to Gopal should be found at the appellants premises. vi It was also found that SR Associates, a concern owned by the appellant and his family members had issued bills to TNEB for supply of energy generated and pumped to TNEB grid and the bills were signed on behalf of SR Associates by Shri Ponnambalam

KAG INDIA PRIVATE LIMITED,CHENNAI vs. PCIT CENTRAL CIRCLE -2, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1366/Chny/2024 िनधा"रणवष" / Assessment Year: 2020-21 The Pcit (Central), M/S. Kag India Pvt Ltd., V. Chennai -2. No. 264/15-1, Sathiyanathan Complex, Velachery Road, East Tambaram, Chennai – 600 059. [Pan: Aadck-5381-Q] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. Y. Sridhar, Fca ""यथ"क"ओरसे/Respondent By : Shri. Nilay Baran Som, Cit सुनवाई क" तार"ख/Date Of Hearing : 21.11.2024 घोषणा क" तार"ख/Date Of Pronouncement : 11.12.2024 आदेश /O R D E R

158 (Mad.) and he also cited the decision of the Hon’ble Rajasthan High Court in the case of CIT v.Keshrimal Parasmal reported in [1986] 157 ITR 484 (Raj.) to assail the impugned action of the Ld.PCIT invoking his revisional jurisdiction u/s.263 of the Act to interfere with the initiation of penalty by the AO in the assessment order

VODAFONE MOBILE SERVICES LIMITED,NEW DELHI vs. DCIT, COIMBATORE

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

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.587/Chny/2017 िनधा:रण वष: /Assessment Year: 2010-11

price at which these are transferred to pre-paid distributors and discount in nature. A.O has made disallowances of discount extended by the assessee company to various distributors of prepaid SIM Card/Recharge coupon u/s 40(a)(ia) of the Act on the ground that assessee was required to deduct TDS under section 194H :- 5 -: on such discount

ACIT CIRCLE 1, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

price whichever is less, is recognized for income-tax purpose. In this context, it is apt to reproduce circular No. 18/2015: 'Circular No. 18 of 2015, dated November 02, 2015. Subject : Interest from Non-SLR securities of Banks—reg. It has been brought to the notice of the Board that in the case of Banks, field officers are taking

CITY UNION BANK LIMITED,KUMBAKONAM vs. ACIT CIRCLE 1, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

price whichever is less, is recognized for income-tax purpose. In this context, it is apt to reproduce circular No. 18/2015: 'Circular No. 18 of 2015, dated November 02, 2015. Subject : Interest from Non-SLR securities of Banks—reg. It has been brought to the notice of the Board that in the case of Banks, field officers are taking

ACIT CIRCLE 1, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

price whichever is less, is recognized for income-tax purpose. In this context, it is apt to reproduce circular No. 18/2015: 'Circular No. 18 of 2015, dated November 02, 2015. Subject : Interest from Non-SLR securities of Banks—reg. It has been brought to the notice of the Board that in the case of Banks, field officers are taking

CITY UNION BANK LIMITED,KUMBAKONAM vs. ACIT CIRCLE 1, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

price whichever is less, is recognized for income-tax purpose. In this context, it is apt to reproduce circular No. 18/2015: 'Circular No. 18 of 2015, dated November 02, 2015. Subject : Interest from Non-SLR securities of Banks—reg. It has been brought to the notice of the Board that in the case of Banks, field officers are taking

PENTA MEDIA GRAPHICS LTD.,CHENNAI vs. DCIT, CHENNAI

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

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1402/Chny/2015 िनधा"रण वष"/Assessment Year: 2000-01 M/S. Penta Media Graphics Ltd., The Deputy Commissioner Of ‘Taurus’, No. 25, First Main Road, Vs. Income Tax, Media Circle I, Room No. 311, 3Rd Floor, New Block, United India Colony, Kodambakkam, Chennai 600 024. 121, Mahatma Gandhi Road, Nungambakkam, Chennai 600 034. [Pan: Aaacp1647B] (अपीलाथ" /Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By Shri G. Baskar, Advocate & : Smt. Sree Valli Lakshmi, Advocate ""थ" की ओर से/Respondent By None [Dept. Letter Submission] : सुनवाई की तारीख/ Date Of Hearing 12.04.2023 : घोषणा की तारीख /Date Of Pronouncement : 10.05.2023 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai Dated 30.03.2015 Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 [“Act” In Short].

price for the valuation of goodwill. Likewise, he further noted that the assessing authority has not examined the justification of the consideration for transfer of IPR and directed the Assessing Officer to re- examine the issue. 3.8 Subsequently, the Assessing Officer passed the assessment order under section 143(3) r.w.s. 263 of the Act dated 31.03.2006 by determining the assessee

ACIT CORPORATE CIRCLE 2, COIMBATORE vs. EMERALD JEWEL INDUSTRY INDIA LTD., COIMBATORE

In the result, the appeal of the Revenue is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A.No.1853/Chny/2018 ("नधा"रण वष" / Assessment Year: 2012-13) Vs M/S. Emerald Jewel Industry India The Acit, Corporate Circle-2, Ltd., 333, 2Nd Floor, Big Bazar Street, 63-A, Race Course Road, Coimbatore Coimbatore – 641 001. Pan: Aabce3430A (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Ar.V. Sreenivasan, Jcit ""यथ" क" ओर से/Respondent By : Shri S. Sridhar, Advocate

158/-, thus inflated its purchase to that extent. The AO was of the view that the transaction would not fall U/s.43(5)(e) of the Income Tax Act, 1961 (in short ‘the Act’). Specific provision, excluding the derivatives transaction, was introduced by the Finance Act, 2013 w.e.f. 01.04.2014 in Section 43(5)(e) of the Act. Therefore, he held that

ACIT COMPANY CIRCLE VI(1), CHENNAI vs. SAIPEM INDIA PROJECTS PRIVATE LIMITED, CHENNAI

In the result, the appeal filed by Revenue in ITA

Bench: Shri N.R.S. Ganesan & Shri Ramit Kochar"नधा'रण वष' /Assessment Year: 2014-15

price minus discount paid by VAR to the applicant is in the nature of royalty? It depends on the question whether any rights that the applicant granted to the licensee/end-user include the right of using the copyright Alternatively, going by the language of IT Act, the question is whether any right in respect of copyright has been transferred

SAME DEUTZ FAHR ITALIA SPA,ITALY vs. ASSISTANT COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

Bench: Shri Aby T Varkey, Hon’Ble & Shri S.R.Raghunatha, Hon’Ble

price. Further, on account of the above costs, the dealer claims reimbursements from the assessee and then the assessee claims reimbursement from SAME India for the cost incurred by the dealer. It is further to be noted that transporting the product from Italy to India for servicing will not be an economically viable option and hence SAME India has requested