SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-1, ERODE

260 or section 262 or section 263,\nor section 264 is to be given by the Assessing Officer or\nthe Transfer Pricing

SRI MAHARAJA REFINERIES,ERODE vs. ACIT, CIRCLE-I,, ERODE

The appeal of the assessee is allowed for statistical\npurposes

260 or section 262 or section 263,\nor section 264 is to be given by the Assessing Officer or\nthe Transfer Pricing

ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

260 or section 262 or section 263 or section\n264 shall be made within the time specified in sub-section (3).]\n26[(5A) Where the Transfer Pricing

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

section 45 of Income-tax Act, 1961. The assessee, a body of individuals, purchased two pieces of land in the year 1966 measuring 14.55 acres at a price of Rs.27,260. By an instrument of lease-cum-licence dated 10th September, 1970 they granted a mining lease in favour of M/s. Sri Krishna Tiles and Potteries (Madras) Private Limited (hereinafter

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 Officer and the TPO has passed order u/s.92CA of the Act dated 14.01.2015vide C.R. No.Y-603/TPO 3(2)/A.Y.2011-12, in which the TPO has recommended downward adjustment of Rs.7,40,95,333/- incurred to Management Support Services received from its Associated Enterprises YCH, Singapore. Thereafter the DCIT, Corporate Circle 3(2), Chennai passed draft assessment order u/s.143

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

260-A of the Income Tax Act by raising the following purported substantial questions of law arising from the order passed by the Income Tax Appellate Tribunal dated 31.7.2008, by which the learned Tribunal upheld the order of the learned Commissioner of Income Tax (Appeals) and held that the expenditure incurred by the Assessee on Scientific Research was not entitled

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Jagadish

260-A of the Income Tax Act by raising the following purported substantial questions of law arising from the order passed by the Income Tax Appellate Tribunal dated 31.7.2008, by which the learned Tribunal upheld the order of the learned Commissioner of Income Tax (Appeals) and held that the expenditure incurred by the Assessee on Scientific Research was not entitled

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14\n& 2014-15 stands dismissed

Section 105 of the Transfer of Property Act defines a lease of\nimmovable property as a transfer of a right to enjoy such property, made for\ncertain times, expressed or implied by the lessee. In consideration of a price\npaid or premium, or of money, a share of crops, service or any other thing of\nvalue to be rendered periodically

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

transfer pricing adjustment in respect of guarantee given for AE to at 0.5% of the amount guaranteed. 2. The next issue is regarding disallowance under Section 14A. For this Assessment Year, the amended provisions of Rule 8D, with effect from 2nd June 2016 will be applicable and the disallowance should be restricted to 1% of the average investment which

MAHINDRA RESIDENTIAL DEVELOPERS LTD.,CHENGALPUT vs. ITO, CHENNAI

Section 105 of the Transfer of Property Act defines a lease of\nimmovable property as a transfer of a right to enjoy such property, made for\na certain time, expressed or implied, or in perpetuity, in consideration of a price\npaid or promised, or of money, a share of crops, service or any other thing of\nvalue to be rendered

KELLER GROUND ENGINEERING INDIA PRIVATE LTD,CHENNAI vs. ACIT, CORPORATE CIRCLE 4(2), CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

Transfer Pricing Officer and the TPO has passed order u/s.92CA of the Act dated 14.01.2015vide C.R. No.Y-603/TPO 3(2)/A.Y.2011-12, in which the TPO has recommended downward adjustment of Rs.7,40,95,333/- incurred to Management Support Services received from its Associated Enterprises YCH, Singapore. Thereafter the DCIT, Corporate Circle 3(2), Chennai passed draft assessment order u/s.143

JOHN CRANE SEALING SYSTEMS INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, both the assessee’s and Revenue’s appeals are partly allowed

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./Ita No.621/Mds/2016 "नधा"रण वष" / Assessment Year: 2011-12

Transfer Pricing 3 ITA Nos.621 & 785/Mds/2016 (AY 2011-12) John Crane Sealing Systems India Pvt. Ltd. Officer (TPO) did not find any fault with the Transactional Net Margin Method (TNMM), using Operating Profit (OP) to Operating Cost (OC) as the Profit Level Index (PLI), adopted by the company as the Most Appropriate Method (MAM) for bench marking the Manufacturing

DCIT, CHENNAI vs. JOHN CRANE SEALING SYSTEMS (INDIA) PRIVATE LIMITED, CHENNAI

In the result, both the assessee’s and Revenue’s appeals are partly allowed

Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./Ita No.621/Mds/2016 "नधा"रण वष" / Assessment Year: 2011-12

Transfer Pricing 3 ITA Nos.621 & 785/Mds/2016 (AY 2011-12) John Crane Sealing Systems India Pvt. Ltd. Officer (TPO) did not find any fault with the Transactional Net Margin Method (TNMM), using Operating Profit (OP) to Operating Cost (OC) as the Profit Level Index (PLI), adopted by the company as the Most Appropriate Method (MAM) for bench marking the Manufacturing

GANESAN KANNAN,THOOTHUKUDI vs. ITI, INTERNATIONAL TAXATION WARD, THOOTHUKUDI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपीलसं./Ita No.: 698/Chny/2024 िनधा"रण वष" / Assessment Year: 2018-19

260 Taxman 273 (Bom.) 4.3) The Department respectfully submits that it is a fact that the assessee preferred an appeal before the Ld.DRP against the additions made by the Assessing Officer. 4.4) The Department prays to draw attention of the Hon'ble Bench to the provisions contained in section 144C(13) of the Income Tax Act. The usage

M/S. V.V.VANNIAPERUMAL & SONS,VIRUDHUNAGAR vs. PCIT-2, CHENNAI, CHENNAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

260 341,124 8 Wealth 2,575,633 1,091,324 9 DOTS 802,718 360,778 Brand Value 1,587,438,398 669,284,163 Brand Value (in 158.74 66.93 Crores) Less:- Nil (Not required as 10% Variance in per Standards / 6.69 Estimation practices) Total Brand Value (in Crores) 158.74 60.24 6.1 The assessee claimed that conservatism adopted

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

260 341,124 8 Wealth 2,575,633 1,091,324 9 DOTS 802,718 360,778 Brand Value 1,587,438,398 669,284,163 Brand Value (in 158.74 66.93 Crores) Less:- Nil (Not required as 10% Variance in per Standards / 6.69 Estimation practices) Total Brand Value (in Crores) 158.74 60.24 6.1 The assessee claimed that conservatism adopted

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

260 341,124 8 Wealth 2,575,633 1,091,324 9 DOTS 802,718 360,778 Brand Value 1,587,438,398 669,284,163 Brand Value (in 158.74 66.93 Crores) Less:- Nil (Not required as 10% Variance in per Standards / 6.69 Estimation practices) Total Brand Value (in Crores) 158.74 60.24 6.1 The assessee claimed that conservatism adopted

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

260 341,124 8 Wealth 2,575,633 1,091,324 9 DOTS 802,718 360,778 Brand Value 1,587,438,398 669,284,163 Brand Value (in 158.74 66.93 Crores) Less:- Nil (Not required as 10% Variance in per Standards / 6.69 Estimation practices) Total Brand Value (in Crores) 158.74 60.24 6.1 The assessee claimed that conservatism adopted

M/S. V.V.V. & SONS EDIBLE OILS LTD.,,VIRUDHUNAGAR vs. DCIT, CENTRAL-1,, MADURAI

In the result, the appeals of the assessee in ITA Nos

Bench: Shri Mahavir Singhand Shri G. Manjunatha

260 341,124 8 Wealth 2,575,633 1,091,324 9 DOTS 802,718 360,778 Brand Value 1,587,438,398 669,284,163 Brand Value (in 158.74 66.93 Crores) Less:- Nil (Not required as 10% Variance in per Standards / 6.69 Estimation practices) Total Brand Value (in Crores) 158.74 60.24 6.1 The assessee claimed that conservatism adopted