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 the goods and services falling u/s.80IA(8) has to be compulsorily be determined under arm‟s length principle. Had it Sri Shanmugavel Mills Pvt. Ltd :: 11 :: been so, then post introduction of SDT in Section 92BA w.e.f. 01/04/2013, then statute would have provided that for the purpose of Sub-section (8) to Section 80IA, “market value” in relation

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 the goods and services\nfalling u/s.801A(8) has to be compulsorily be determined under arm's length principle.\nHad it been so, then post introduction of SDT in Section 92BA w.e.f. 01/04/2013,\nthen statute would have provided that for the purpose of Sub-section (8) to Section\n80IA, \"market value” in relation to goods or services means

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1, TIRUNELVELI, TIRUNELVELI vs. M/S.LOYAL TEXTILE MILLS LIMITED, KOVILPATTI

In the result, both appeals filed by the Revenue are dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.192/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.193/Chny/2025, A.Y.: 2018-19 V. Deputy Commissioner Of Income M/S.Loyal Textile Mills Tax, Limited, Circle-1, New No.21, Old No.4, Tirunelveli. Mill Street, Kovilpatti, Tamil Nadu-628 501. [Pan: Aaacl2632C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.Bhupendran, Advocate. : प्रत्यर्थी की ओर से /Respondent By Mr.Krishna Murthy At, Jcit सुनवाईकीतारीख/Date Of Hearing : 22.10.2025 घोषणाकीतारीख /Date Of Pronouncement : 30.10.2025

transfer pricing adjustment in respect of captive power valuation for the purpose of deduction u/s 80IA. Page 2 of 6 ITA Nos.192 & 193 /Chny/2025 (AY-2017-18 & 2018-19) M/s.Loyal Textile Mills Limited. b. The deletion of disallowance u/s 40(a)(ia) on commission paid to non-resident agents. The ld. Departmental Representative (DR) reiterated the grounds taken

DEPUTY COMMISSIONER OF INCOME TAX, TIRUNELVELI vs. M/S.LOYAL TEXTILE MILLS LIMITED, KOVILPATTI

In the result, both appeals filed by the Revenue are dismissed

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.192/Chny/2025, A.Y.: 2017-18 आयकर अपील सं./Ita No.193/Chny/2025, A.Y.: 2018-19 V. Deputy Commissioner Of Income M/S.Loyal Textile Mills Tax, Limited, Circle-1, New No.21, Old No.4, Tirunelveli. Mill Street, Kovilpatti, Tamil Nadu-628 501. [Pan: Aaacl2632C] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) : अपीलार्थी की ओर से/ Appellant By Mr.Bhupendran, Advocate. : प्रत्यर्थी की ओर से /Respondent By Mr.Krishna Murthy At, Jcit सुनवाईकीतारीख/Date Of Hearing : 22.10.2025 घोषणाकीतारीख /Date Of Pronouncement : 30.10.2025

transfer pricing adjustment in respect of captive power valuation for the purpose of deduction u/s 80IA. Page 2 of 6 ITA Nos.192 & 193 /Chny/2025 (AY-2017-18 & 2018-19) M/s.Loyal Textile Mills Limited. b. The deletion of disallowance u/s 40(a)(ia) on commission paid to non-resident agents. The ld. Departmental Representative (DR) reiterated the grounds taken

ACIT, LTU-2,, CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the assessee is partly allowed and the appeal of the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

172, 173 & 182 of the Paper Book-I and the summary of his stay at Page 9 of Paperbook-II to show that, his stay in India for rendering such consultancy services to the assessee was actually less than 183 days during the year. Having taken note of these facts / details, according to us, the taxability of the impugned payment

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

transfer to a new business of machinery or plant previously used for\nany purpose\".\n5.4 The Id.CIT(A) erred in not observing that the assessee purchased the first\nunit K-40 in the FY 2011-12 and this unit was previously owned and used by\nM//s.AmitronicsPvt Ltd, Bangalore and this machine was originally installed

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

transfer to a new business of machinery or plant previously used for any purpose”. 5.4 The ld.CIT(A) erred in not observing that the assessee purchased the first unit K-40 in the FY 2011-12 and this unit was previously owned and used by M//s.AmitronicsPvt Ltd, Bangalore and this machine was originally installed

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

transfer to a new business of machinery or plant previously used for\nany purpose\".\n5.4 The Id.CIT(A) erred in not observing that the assessee purchased the first\nunit K-40 in the FY 2011-12 and this unit was previously owned and used by\nM//s.AmitronicsPvt Ltd, Bangalore and this machine was originally installed

M/S. AMBATTUR DEVELOPERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(1), CHENNAI

In the result the appeal of the assessee is allowed

transferred through\nbanking channels. Further neither of the lower authorities have doubted the\nsource of the investment and as such they cannot hinder the genuine and bona\nfide business transactions. Therefore, in the absence of this primary criteria (i.e.\ninvestment is out of unaccounted money), we feel invocation of section\n56(2)(viib) of the Act is against main objective

SUNTEC BUSINESS SOLUTIONS PRIVATE LIMITED,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE 3(1), CHENNAI, CHENNAI

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

Bench: Shri George George Kand Shri S.R. Raghunatha

Transfer Pricing Officer (TPO) to determine the arm’s length price of international transaction undertaken by the assessee with its AE. The TPO passed an order u/s.92CA of the Act on 23.10.2023 wherein, he proposed downward adjustment of Rs.1,42,01,590/- being the arm’s length price of the salary paid to global sales personnel. The reasoning

M/S INNOVTIVE MICROFINANCE FOR POVERTY ALLEVIATION,CHENNAI vs. DCIT(EXEMPTIONS),CHENNAI CIRCLE, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Jagadish

transfers, counselling, etc. 2.2. For the purposes of this report, the Sub-Committee has confined itself to only one aspect of Microfinance, namely, the provision of credit to low income groups. 2.3 The provision of credit to the Microfinance sector is based on the following postulates: a) It addresses the concerns of poverty alleviation by encouraging the poor to work

ASHOK LEYLAND LIMITED,,CHENNAI vs. ACIT,, CHENNAI

172, 173 & 182 of the Paper Book-I and the\nsummary of his stay at Page 9 of Paperbook-II to show that, his stay in\nIndia for rendering such consultancy services to the assessee was actually\nless than 183 days during the year. Having taken note of these facts /\ndetails, according to us, the taxability of the impugned payment

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

172 (SC) As already observed, M/s PPL was liable to pay interest on the loans taken from various financial institutions. The Appellant in the capacity of Managing Director was under no legal obligation to discharge the liabilities of interest belonging to M/s PPL even though he was its promoter. It is in this context the principles enunciated by the Apex

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

172 (SC) As already observed, M/s PPL was liable to pay interest on the loans taken from various financial institutions. The Appellant in the capacity of Managing Director was under no legal obligation to discharge the liabilities of interest belonging to M/s PPL even though he was its promoter. It is in this context the principles enunciated by the Apex

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-2(4), CHENNAI

Accordingly, the assessee's appeals in ITA Nos.1881, 1882,\nand 1883/Chny/2025 for A.Ys.2016-17, 2019-20, and 2022-23 are\nallowed

prices are highly volatile. Timely\nlifting, transportation, storage, and export were critical, as delays could\nresult in substantial demurrage and dead freight costs. Since transport\noperators lacked adequate incentive to ensure timely delivery, the\nassessee assumed responsibility for resolving logistical impediments\nthrough direct intervention involving facilitation payments at various\nstages.\n11. Similar challenges were faced in the sourcing and supply

DCIT CENTRAL CIRCLE 2(20, CHENNAI vs. RAMA NARAYANAN (LATE), L/H SHRINARAYANAN RAMASWAMY, CHENNAI

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.3080/Chny/2018 िनधा"रण वष" /Assessment Year: 2012-13 The Dy. Commissioner – V. Mr.Rama Narayanan (Late) Of Income Tax, L/H Mr.Narayanan- Central Circle-2(2), Ramasamy, Chennai. No.14/19, Saraswathi Street, Mahalingapuram, Chennai-600 034. [Pan: Achpr 5912 K] (अपीलाथ"/Appellant) (""यथ"/Respondent)

section 2(14) of the IT Act, 1961. :: 5 :: 12. As per the letter submitted during scrutiny also accepted that agricultural operations had not been undertaken. The existence of trees is incidental. and does not by any stretch of imagination grant an automatic stamp that the land is agricultural in nature. Mere mention in the records of the Revenue Authorities

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRLCE -3, COIMBATORE, COIMBATORE vs. P.P. CONSTRUCTIONS, KARUR

172\n-\n2014-15\n5,33,000\n3,87,64,907\n-\n2015-16\n1,63,10,665\n4,03,71,296\n-\n2016-17\n1,78,44,300\n4,61,36,950\n-\n2017-18\n-\n4,27,25,426\n-\n2018-19\n-\n4,68,07,051\n79,56,500\nTotal

L KARUPPUSAMY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

172 - 2014-15 5,33,000 3,87,64,907 - 2015-16 1,63,10,665 4,03,71,296 - 2016-17 1,78,44,300 4,61,36,950 - 2017-18 - 4,27,25,426 - 2018-19 - 4,68,07,051 79,56,500 Total 17,88,81,965 29,02,36,910 79,56,500 66. Before

M/S. P.P. FINANCIERS,KARUR vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.1119, 1120 & 1121/Chny/2025 "नधा"रण वष"/Assessment Years: 2015-16, 2017-18 & 2018-19 & आयकर अपील सं./Ita Nos.209 To 213 & 214/Chny/2025 "नधा"रण वष"/Assessment Years: 2010-11 To 2014-15 & 2016-17

172 - 2014-15 5,33,000 3,87,64,907 - 2015-16 1,63,10,665 4,03,71,296 - 2016-17 1,78,44,300 4,61,36,950 - 2017-18 - 4,27,25,426 - 2018-19 - 4,68,07,051 79,56,500 Total 17,88,81,965 29,02,36,910 79,56,500 66. Before