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

4 :: [2024] 460 ITR 162 (SC) wherein it was held that the market value of the power supplied for captive consumption should be considered at the rate at which the State Electricity Board supplied power to its end consumers and not at the rate at which an assessee sells to the State Electricity Board. 5. Aggrieved by the aforesaid action

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

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

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

4. The Revenue has challenged both the issues: a. The deletion of 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

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

4. The Revenue has challenged both the issues: a. The deletion of 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

ACIT, CHENNAI vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

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

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

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Jagadishआयकर अपील सं./ Ita Nos.1881, 1882 & 1883/Chny/2025 िनधा;रण वष; /Assessment Years: 2016-17, 2019-20 & 2022-23

prices are highly volatile. Timely lifting, transportation, storage, and export were critical, as delays could result in substantial demurrage and dead freight costs. Since transport operators lacked adequate incentive to ensure timely delivery, the assessee assumed responsibility for resolving logistical impediments through direct intervention involving facilitation payments at various stages. 11. Similar challenges were faced in the sourcing and supply

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

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

INTEGRATED SERVICE POINT LTD.,CHENNAI vs. ACIT, CC-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

ACIT, NUNGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

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

ACIT, NUNAGAMBAKKAM vs. INTEGRATED SERVICE POINT LIMITED, ANNA NAGAR

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

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

In the result the appeal of the assessee is allowed

172 (Mumbai\n- Trib.)\n“Moreover, in case of many closely held companies and even in new\ncompanies promoters used to issue share at premium with the main\npurpose of keeping share capital low, yet capital base stronger so that\nbreakup value and market value is high. This leads to advantage of low cost\nof servicing share capital and also

P PALANISMAY,BENGALURU vs. ACIT, CENTRAL CIRCLE-3,, COIMBATORE

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

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

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

price whichever is lower, which is different from valuation of securities for the purpose of books which is as per RBI guidelines. Since, the issue is covered by the decision of Hon’ble High Court of Madras in appellant’s own case, we are of the considered view that, the Assessing Officer is erred in making additions towards disallowance

M/S. CITY UNION BANK,,KUMBAKONAM vs. DCIT, CIRCLE - 2 (1),, TRICHY

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

price whichever is lower, which is different from valuation of securities for the purpose of books which is as per RBI guidelines. Since, the issue is covered by the decision of Hon’ble High Court of Madras in appellant’s own case, we are of the considered view that, the Assessing Officer is erred in making additions towards disallowance

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

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

price whichever is lower, which is different from valuation of securities for the purpose of books which is as per RBI guidelines. Since, the issue is covered by the decision of Hon’ble High Court of Madras in appellant’s own case, we are of the considered view that, the Assessing Officer is erred in making additions towards disallowance