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

253(2A) of the Income-tax Act, 1961. 2. The learned TPO has erred in not providing any basis for arriving at 3.5 percentage as arm’s length price commission for issuing corporate guarantee for the subject AY 2009-10. 3. The learned TPO erred in not appreciating the fact that the learned TPO himself applied the rate

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

253(2A) of the Income-tax Act, 1961. 2. The learned TPO has erred in not providing any basis for arriving at 3.5 percentage as arm’s length price commission for issuing corporate guarantee for the subject AY 2009-10. 3. The learned TPO erred in not appreciating the fact that the learned TPO himself applied the rate

YCH LOGISTICS (INDIA) PRIVATE LIMITED,KANCHEEPURAM vs. DCIT, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

transfer pricing adjustment for fresh adjudication. Simultaneously, the assessee also challenged the order of Tribunal i.e., original order passed in ITA No.322/Mds/2016 dated 30.06.2016 and also challenged the Tribunal order passed in M.P. No.218/Mds/2016 dated 04.04.2017 before Hon’ble High Court of Madras and the Hon’ble High Court in Tax Case Appeal Nos.480 and 473 of 2017 vide order

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...

section (3). 3. The cross objection is thus dismissed as not maintainable. 4. We will first take up the appeal of the assessee for the assessment year 2009-10. 5. Ground no. 1 is general and it does not call for any specific adjudication by us. Transfer Pricing Issue: 6. In ground no. 2, the assessee has raised a grievance

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...

section (3). 3. The cross objection is thus dismissed as not maintainable. 4. We will first take up the appeal of the assessee for the assessment year 2009-10. 5. Ground no. 1 is general and it does not call for any specific adjudication by us. Transfer Pricing Issue: 6. In ground no. 2, the assessee has raised a grievance

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...

section (3). 3. The cross objection is thus dismissed as not maintainable. 4. We will first take up the appeal of the assessee for the assessment year 2009-10. 5. Ground no. 1 is general and it does not call for any specific adjudication by us. Transfer Pricing Issue: 6. In ground no. 2, the assessee has raised a grievance

DCIT, CHENNAI vs. HYUNDAI MOTOR INDIA LIMITED, 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...

section (3). 3. The cross objection is thus dismissed as not maintainable. 4. We will first take up the appeal of the assessee for the assessment year 2009-10. 5. Ground no. 1 is general and it does not call for any specific adjudication by us. Transfer Pricing Issue: 6. In ground no. 2, the assessee has raised a grievance

DCIT, CHENNAI vs. HYUNDAI MOTORS 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...

section (3). 3. The cross objection is thus dismissed as not maintainable. 4. We will first take up the appeal of the assessee for the assessment year 2009-10. 5. Ground no. 1 is general and it does not call for any specific adjudication by us. Transfer Pricing Issue: 6. In ground no. 2, the assessee has raised a grievance

RENAULT NISSAN TECHNOLOGY & BUSINESS CENRE INDIA PVT. LTD.,KANCHEEPURAM vs. DCIT CORPORATE CIRCLE 5(1), CHENNAI

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

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

transfer pricing documentation and thereafter decide the issue afresh in accordance with law, after giving a reasonable opportunity to the assessee. The Assessing Officer shall follow the statutory provisions and pass the necessary orders as provided under Section 144C of the Income-tax Act, 1961 (in short 'the Act'). 5. The next issue arises for consideration is exclusion of expenditure

AALAYA JEWEL INDUSTRY PRIVATE LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, the appeals of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Abraham P George

Transfer Pricing (TP) adjustment of `2,57,04,337/-. A Draft assessment order based on TPO recommendations was proposed by the ld. Assessing Officer on 29.12.2016. Assessee thereupon filed an application before the Dispute ITA Nos.970 & 971/Mds./17 :- 3 -: Resolution Panel, (DRP) on 31.01.2017. Though in such application, assessee recorded the date of receipt of draft assessment order

AALAYA JEWEL INDUSTRY PRIVATE LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, the appeals of the assessee in ITA

Bench: Shri N.R.S. Ganesan & Shri Abraham P George

Transfer Pricing (TP) adjustment of `2,57,04,337/-. A Draft assessment order based on TPO recommendations was proposed by the ld. Assessing Officer on 29.12.2016. Assessee thereupon filed an application before the Dispute ITA Nos.970 & 971/Mds./17 :- 3 -: Resolution Panel, (DRP) on 31.01.2017. Though in such application, assessee recorded the date of receipt of draft assessment order

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

253 Keller India, in response to the notice under section 133(6) dated March 10, 2023 9.1. Notice under section 133(6) dated March 10, 2023, issued on 258 Keller Ground Engineering India Private Limited ("Keller India") 9.2. Extract of the ledger of the Appellant maintained by Keller 260 India in its books

ASSISTANT COMMISSIONER OF INCOME TAX, TIRUNELVELI vs. LOYAL TEXTILE MILLS LTD, KOVILPATTI

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

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

3. The ld.CIT(A), after considering the submissions of the assessee, deleted disallowance on both commission payments and partly deleted the disallowance on professional fees. In so far as deduction u/s.80IA of the Act, the ld.CIT(A), by relying on the decisions by Supreme Court reported in 157 taxmann.com 207 and by Tribunal, Hyderabad upheld the determination

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

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

253) held that purpose or object of subsidy was relevant to decide the character of the incentive not the mechanism of payment and observed that, “If the object of the subsidy scheme was to ITA No.2174/Chny/2024 (AY 2017-18) M/s. The India Cements Ltd. :: 15 :: enable the assessee to run the business more profitably then the receipt is on revenue

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

Transfer Pricing Officer, for the purpose of determining the Arm's Length Price with reference to the 'international transaction carried out by the assessee with its associated enterprises during the F.Y. 2006-07 as per the provisions of sec 92C of the Act. In response to the same, the TPO passed order vide C.R.No.A-103/TPO-I/A.Y.2007-08 dated 16.09.2010 stating

DCIT, CHENNAI vs. ASHOK LEYLAND LTD., CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

Transfer Pricing Officer, for the purpose of determining the Arm's Length Price with reference to the 'international transaction carried out by the assessee with its associated enterprises during the F.Y. 2006-07 as per the provisions of sec 92C of the Act. In response to the same, the TPO passed order vide C.R.No.A-103/TPO-I/A.Y.2007-08 dated 16.09.2010 stating

ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. Nos.2825, 2826 & 2827/Mds/2014 "नधा"रण वष" /Assessment Years : 2005-06, 2006-07 & 2007-2008. The Deputy Commissioner Of M/S. Ashok Leyland Ltd, Income Tax, Vs. No.1, Sardar Patel Road, Large Taxpayer Unit -Ii, Guindy, Chennai 600 101. Chennai 600 032. [Pan Aaaca 4651L] (Department) (Assessee )

Transfer Pricing Officer, for the purpose of determining the Arm's Length Price with reference to the 'international transaction carried out by the assessee with its associated enterprises during the F.Y. 2006-07 as per the provisions of sec 92C of the Act. In response to the same, the TPO passed order vide C.R.No.A-103/TPO-I/A.Y.2007-08 dated 16.09.2010 stating

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