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10 results for “transfer pricing”+ Section 234Dclear

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Key Topics

Section 4512Deduction7Section 143(3)6Section 37(1)6Addition to Income6Disallowance5Section 234D4Transfer Pricing4Comparables/TP4Section 144C(5)

HOWDEN SOLYVENT (INDIA) PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

Appeal stands partly allowed in terms of our above order

ITA 732/CHNY/2015[2010-11]Status: DisposedITAT Chennai31 Oct 2022AY 2010-11

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri Darpan Kripalani (Advocate) &For Respondent: Dr. S. Palani Kumar- CIT-DR
Section 143(3)Section 144C(5)Section 234BSection 43B

Section 234B and 234D of the Act is consequential in nature.” Ground No.1 is general in nature. Ground No.8 has not pressed before us. Ground No.9 assails levy of interest u/s 234B & 234C. The same is consequential in nature which do not require any specific adjudication. Ground Nos. 2 to 4 are related with Transfer Pricing

3
Reopening of Assessment3
TDS3

GIL SHARED SERVICES PRIVATE LTD.,,CHENNAI vs. ACIT (OSD), CHENNAI

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

ITA 3485/CHNY/2016[2012-13]Status: DisposedITAT Chennai26 Apr 2016AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri D.S.Sunder Singh

For Respondent: Mr.Pathlavath Peerya, CIT
Section 143(3)Section 92C

price without giving benefit of +/- 5 percent under the proviso to section 92C of the Act. Issue 2: Infusion of interest Ground of objection 12 — Erroneous levy of interest under Section234B, Section 234C and Section 234D The Ld. AO has erred by levying interest under Section 234B, 234C and 234D of the Income-tax Act, 1961 (Act) despite the fact

SHRIRAM TRANSPORT FINANCE CO. LTD.,CHENNAI vs. DCIT, CHENNAI

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

ITA 454/CHNY/2016[2012-2013]Status: DisposedITAT Chennai24 Aug 2016AY 2012-2013

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

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Dr. U. Anjaneyalu, CIT
Section 234DSection 36(1)(iii)Section 37Section 45

234D of the Act on the excess amount refunded to the assessee while processing a return under Section 143(1) of the Act. Even though it is an interest levied on the amount refunded to the assessee, in fact, it is an interest for delayed payment of tax. In other words, the amount refunded to the assessee while processing return

DCIT, CHENNAI vs. SHRIRAM TRANSPORT FINANCE CO. LTD., CHENNAI

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

ITA 728/CHNY/2016[2012-13]Status: DisposedITAT Chennai24 Aug 2016AY 2012-13

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

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Dr. U. Anjaneyalu, CIT
Section 234DSection 36(1)(iii)Section 37Section 45

234D of the Act on the excess amount refunded to the assessee while processing a return under Section 143(1) of the Act. Even though it is an interest levied on the amount refunded to the assessee, in fact, it is an interest for delayed payment of tax. In other words, the amount refunded to the assessee while processing return

DCIT, CHENNAI vs. EXTREME NETWORKS INDIA PVT. LTD., CHENNAI

Accordingly, we find no question of law much less any substantial question of law arises for consideration in these appeals. Accordingly, both the Tax Case (Appeals) stand dismissed

ITA 434/CHNY/2015[2010-11]Status: DisposedITAT Chennai07 Apr 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A .No.434/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

For Appellant: Shri. T.N. Seetharaman, AdvFor Respondent: Shri. Pathlavath Peerya, CIT
Section 144CSection 144C(2)(b)Section 144C(5)Section 154Section 2(24)(x)

Transfer Pricing Adjustment is uncalled for and deserves to be deleted. 8. The AO erred in adding Employees' contribution to PF of Rs.5,74,941/- invoking section 2(24)(x) r.w.s 36(1 )(va) of the Act. 9. The AO I DRP failed to see that the said amount had been paid before the due date for furnishing the return

EXTREME NETWORKS INDIA PVT LTD.,CHENNAI vs. DCIT, CHENNAI

Accordingly, we find no question of law much less any substantial question of law arises for consideration in these appeals. Accordingly, both the Tax Case (Appeals) stand dismissed

ITA 449/CHNY/2015[2010-11]Status: DisposedITAT Chennai04 Apr 2017AY 2010-11

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George] आयकर अपील सं./I.T.A .No.434/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

For Appellant: Shri. T.N. Seetharaman, AdvFor Respondent: Shri. Pathlavath Peerya, CIT
Section 144CSection 144C(2)(b)Section 144C(5)Section 154Section 2(24)(x)

Transfer Pricing Adjustment is uncalled for and deserves to be deleted. 8. The AO erred in adding Employees' contribution to PF of Rs.5,74,941/- invoking section 2(24)(x) r.w.s 36(1 )(va) of the Act. 9. The AO I DRP failed to see that the said amount had been paid before the due date for furnishing the return

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2580/CHNY/2017[2014-15]Status: DisposedITAT Chennai06 Dec 2018AY 2014-15

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

234D and levy correct amount of interest. 21. In the result, the appeal of the assessee is partly allowed. 22. Now, coming to Revenue’s appeal I.T.A.No.2077/Mds/2016, the only issue is addition made by the Assessing Officer towards advance fee of 64,39,989/-. 23. During assessment proceedings, the Assessing Officer found that the assessee is following the cash

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2579/CHNY/2017[2013-14]Status: DisposedITAT Chennai06 Dec 2018AY 2013-14

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

234D and levy correct amount of interest. 21. In the result, the appeal of the assessee is partly allowed. 22. Now, coming to Revenue’s appeal I.T.A.No.2077/Mds/2016, the only issue is addition made by the Assessing Officer towards advance fee of 64,39,989/-. 23. During assessment proceedings, the Assessing Officer found that the assessee is following the cash

ACIT NON CORP CIRCLE 1 (1) FORMERLY KNOWN AS BUSINESS CIRCLE 1, CHENNAI vs. M/S DEOLITE HASKINS & SELLS, CHENNAI

ITA 2578/CHNY/2017[2010-11]Status: DisposedITAT Chennai06 Dec 2018AY 2010-11

Bench: Shri Joginder Singh & Shri A.Mohan Alankamony

For Appellant: Mr.AR.V.Sreenivasan,JCIT,D.RFor Respondent: Mr.S.P.Chidambaram,Advocate
Section 143(3)Section 37(1)

234D and levy correct amount of interest. 21. In the result, the appeal of the assessee is partly allowed. 22. Now, coming to Revenue’s appeal I.T.A.No.2077/Mds/2016, the only issue is addition made by the Assessing Officer towards advance fee of 64,39,989/-. 23. During assessment proceedings, the Assessing Officer found that the assessee is following the cash

SMT. SUDHA EASHWAR,,CHENNAI vs. ITO, NCW - 14 (3),, CHENNAI

In the result, the appeal filed by the assessee in ITA

ITA 2342/CHNY/2019[2014-15]Status: DisposedITAT Chennai02 Jan 2020AY 2014-15

Bench: Shri George Mathan & Shri Ramit Kocharआयकर अपील सं./Ita No.2342/Chny/2019 "नधा"रण वष" /Assessment Year: 2014-15 V. Smt. Sudha Eashwar, The Income Tax Officer No.23A, P.T.Rajan Salai, Non-Corporate Ward-14(3) K.K.Nagar, Chennai Chennai-600 078. [Pan: Alxps 0601 D] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : None ""यथ" क" ओर से /Respondent By : Ms.Sumathi Venkatraman, Jcit सुनवाई क" तार"ख/Date Of Hearing : 09.10.2019 घोषणा क" तार"ख /Date Of Pronouncement : 02.01.2020 आदेश / O R D E R Per Ramit Kochar:

For Appellant: NoneFor Respondent: Ms.Sumathi Venkatraman
Section 143(3)

234D of the Act. 10.That the appellant craves the leave to add, modify, amend or delete any of the grounds of appeal at the time of hearing and all the above grounds are without prejudice to each other. The appellant prays that on the above grounds, the Hon. Income-tax Appellate tribunal may kindly delete the additions and pass such