RENAULT INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No. 1078/Mds/2017 "नधा"रण वष" /Assessment Year : 2012-2013. M/S. Renault India Private Vs. The Deputy Commissioner Of Limited, Income Tax, No.37 & 38, Asv Ramana Corporate Circle 5(1) Towers, Chennai. 4Th Floor, Venkatnarayana Road, T.N Agar, Chennai 600 017. [Pan Aadcr 2042M ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Transfer Pricing provisions, transaction s other than the international transactions as reported in form 3CEB, jurisdiction is invalid, without any and void ab initio as the transaction that the authorities intended 10 treat (IS international transaction was neither identified nor communicated to the assessee in any of the notices issued prior 10 the passing of the order under section 92CA

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex- ITA No.672/Chny/201 /Chny/2017 (AY 2012-13) M/s.TVS Motor Co. Ltd. M/s.TVS Motor Co. Ltd. :: 16 :: factory sale at Rs.2,15,56,000/ factory

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

M/S. STERLITE INDUSTRIES (INDIA) LTD.,MADURAI vs. ADDITIONAL CIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

price by changing the method of accounting. However, when the assessee was consistently following the same, there will be revenue neutral, hence there cannot be loss to the Revenue. Therefore, this Tribunal is of the considered opinion that the CIT(Appeals) has rightly allowed the claim of the assessee under the provisions of Section 145A of the Act. This Tribunal

DCIT, CHENNAI vs. PARRYWARE ROCA PVT. LTD., CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

Transfer Pricing Officer or Dispute Resolution Panel, this Tribunal is of the considered opinion that the matter needs to be re-examined. Accordingly, the orders of the Assessing Officer are set aside and the Assessing Officer shall refer the matter again to the Dispute Resolution Panel. The Dispute Resolution Panel shall examine the agreement between the parties and other transactions

ROCA BATHROOM PRODUCTS PRIVATE LIMITED,CHENNAI vs. JCIT, CHENNAI

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.586/Mds/2014 & आयकर अपील सं./Ita No.610/Mds/2015 "नधा"रण वष" / Assessment Years : 2009-10 & 2010-11

Transfer Pricing Officer or Dispute Resolution Panel, this Tribunal is of the considered opinion that the matter needs to be re-examined. Accordingly, the orders of the Assessing Officer are set aside and the Assessing Officer shall refer the matter again to the Dispute Resolution Panel. The Dispute Resolution Panel shall examine the agreement between the parties and other transactions

COOK INDIA MEDICAL DEVICES PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

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

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita No.3137/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14

section 234C of the Act. 10. The Ld. AO has erred, in law and in facts, in initiating penalty proceedings u/s.271(1)(c) of the Act; The Appellant submits that each of the above grounds is independent and without prejudice of each other. The Appellant craves leave to add, alter, amend, vary, omit or substitute any of the aforesaid grounds

PANASONIC CORPORATION,HARYANA vs. DCIT, CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

Transfer Pricing Officer as required under Section 92CA(4) of the Act, preferred to pass a draft assessment order as provided in Section 144C(1) of the Act, whether the assessee is challenging the jurisdiction of the Assessing Officer to pass a draft assessment order under Section 144C(1) of the Act instead of passing order under Section 92CA

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

pricing of the international transaction. 18.2 The assessee also submitted a detailed note on the various services availed by them under the terms of the agreement. Further, it was also submitted before the TPO that the AE party had identified the nature of stewardship/shareholder activities in each of the above department/services and such costs was excluded and not charged back

GAMESA RENEWABLE PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, both the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri Duvvuru Rl Reddy

pricing of the international transaction. 18.2 The assessee also submitted a detailed note on the various services availed by them under the terms of the agreement. Further, it was also submitted before the TPO that the AE party had identified the nature of stewardship/shareholder activities in each of the above department/services and such costs was excluded and not charged back

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

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

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita Nos.:433 & 435/Chny/2025 धनिाजरण वर्ज / Assessment Year: 2018-19 & 2017-18 Acit, Circle -1 Prabhu Spining Mills Private 121, Adarns Plaza, Vs. Limited, 60, Feet Road, No. 207 – 86, Mangalam Road, Tiruppur – 641 602. Karuvampalayam, Tiruppur – 641 604. Tamil Nadu. (अपीलाथी/Appellant) [Pan:Aabcp-0750-E] (प्रत्यथी/Respondent) अपीलाथी की ओर से/Appellant By : Shri. Arv Sreenivasan, Cit प्रत्यथी की ओर से/Respondent By : Shri. T. Banusekar, Advocate. सुनवाई की तारीख/Date Of Hearing : 16.07.2025 घोर्णा की तारीख/Date Of Pronouncement : 13.08.2025

price as defined in clause (ii) of section 92F, where the transfer of such goods or services is a specified domestic transaction referred to in section 92BA. It may be noticed that section 80-IA(8) in its explanation defines market value to be either as per clause (i) or (ii). 19

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

19,700 as commission income on the guarantee extended by the appellant to its associated enterprises (“AEs”), under section 143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

19,700 as commission income on the guarantee extended by the appellant to its associated enterprises (“AEs”), under section 143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

19,700 as commission income on the guarantee extended by the appellant to its associated enterprises (“AEs”), under section 143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

19,700 as commission income on the guarantee extended by the appellant to its associated enterprises (“AEs”), under section 143(3) of the Act read with section with 92CA(3) of the Act. 22. The Honorable DRP, TPC and the AC have erred in law and on facts in holding that the provisions of section 92 of the Act would