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

transfer pricing adjustment in respect of captive power valuation for the purpose of deduction u/s.80IA of the Act. b. The deletion of disallowance u/s.40(a)(ia) of the Act on domestic commission. The learned Departmental Representative (ld.DR) reiterated the grounds taken by the Revenue, contending that the ld.CIT(A) erred in relying upon the decision of the Hon’ble Supreme

TITAN INDUSTRIES LIMITED,HOSUR vs. JCIT, CHENNAI

The appeal stands partly allowed in terms of our above order

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

Transfer Pricing adjustments- Rs. 50,529,810/- Ground 1: Error in sustaining the arm's length price The learned AO/TPO/DRP erred in making adjustments to the Arm's Length price as originally determined by the Appellant. Ground 2: Error in imputing notional interest The learned AO/TPO/DRP erred in imputing interest on advances granted by the appellant to the Associated Enterprises

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

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

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

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

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

M/S. VESTAS TECHNOLOGY R&D CHENNAI PVT. LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri C.M. Garg, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No.3081/Chny/2016 (िनधा"रण वष" / Assessment Year : 2012-2013) M/S Vestas Technology R&D Vs Acit, Corporate Circle-3(2), Chennai Private Limited, Chennai Block A, 8Th Floor, Tecci Park No.173, Rajiv Gandhi Road, Old Mahabalipuram Road, Shollinganallur, Chennai Pan No. : Aaccv 4768 P (अपीलाथ" /Appellant) (""थ" / Respondent) .. िनधा"रती की ओर से /Assessee By : Darpan Kirpalani, Advocate राज" की ओर से /Revenue By : Dr. S.Palanikumar, Cit सुनवाई की तारीख / Date Of Hearing : 15/02/2022 घोषणा की तारीख/Date Of Pronouncement : 31/03/2022 आदेश / O R D E R Per Arun Khodpia, Am : This Is An Appeal Filed By The Assessee Against The Order Of The Acit, Corporate Circle-3(2), Chennai, Dated 28.09.2016 For The Assessment Year 2012-2013, On The Following Grounds Of Appeal: - 1. Ground No.1 1.1. On The Facts & In The Circumstances Of The Case & In Law, The Learned Assistant Commissioner Of Income Tax, Chennai ("Ld. Ao"), The Ld. Deputy Commissioner Of Income Tax, Chennai ("Ld. Tpo") & The Ld. Dispute Resolution Panel ("Ld. Drp"), Erred In Enhancing The Income Of The Appellant By Inr 79,265,132 On Account Of Interest At The Rate Of 21% On Receivables Purportedly Due To The Appellant From Its Associated Enterprise ("Ae") , Without Granting Working Capital Adjustment. 1.2. In This Regard, The Order Of The Ld. Ao To The Extent Prejudicial To The Appellant Is Bad In Law & Is Liable To Be Quashed.

297/- of interest on income tax and TDS u/s.37 of the Act. 5. Now, the assessee again dissatisfied with the above order of AO, has filed appeal before the Tribunal. 6. Ld. AR of the assessee submitted that the authorities below erred in enhancing the income of the appellant by INR 7,92,65,132/- on account of interest

INCOME TAX OFFICER, CORPORATE WARD -3(1), CHENNAI, CHENNAI vs. TTK HEALTHCARE LIMITED , CHENNAI

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

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2254/Chny/2024 िनधा"रण वष"/Assessment Year: 2015-16 The Income Tax Officer, Vs. Ttk Healthcare Limited, Corporate Ward 3(1), No. 6, Cathedral Road, Chennai. Gopalapuram, Chennai 600 086. [Pan:Aabct3312J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri C. Murugesan, Addl. Cit ""थ" की ओर से/Respondent By : Shri Vikram Vijayaraghavan, Advocate (Virtual) सुनवाई की तारीख/ Date Of Hearing : 26.11.2024 घोषणा की तारीख /Date Of Pronouncement : 27.11.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Revenue Is Directed Against The Order Dated 27.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi For The Assessment Year 2015-16. 2. We Note That The Return Of Income Filed By The Assessee Was Selected For Scrutiny & Assessment Order Was Passed Assessing Income Of ₹.35,75,45,407/-. The Assessing Officer Reopened The 2

transfer or assign any of their rights under this agreement. 3. TTK-LIG accepts that the said monogram shall be used by TTKLIG under this agreement in a manner indicative of the fact that the copyright in the said monogram is owned by TTK. Illustrative of the words to appear in close proximity to the said monogram, for the purpose

INCOME TAX OFFICER, CORPORATE WARD -3(1), CHENNAI, CHENNAI vs. TSL TECHNO SERVICES LIMITED(TTK HEALTHCARE PRIVATE LIMITED ), CHENNAI

In the result, appeal filed by the revenue is dismissed

Bench: Shri S.S. Viswanethra Ravi, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1772/Chny/2024 िनधा"रणवष" / Assessment Year: 2020-21 Income Tax Officer, Tsl Techno Services Limited, Corporate Ward -3(1), V. (Ttk Healthcare Private Ltd), Chennai – 600 034. No.6, Cathedral Road, Gopalapuram, Chennai – 600 086. [Pan: Aabct-3312-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Mr. Vikram Vijayaraghavan, Advocate ""यथ"क"ओरसे/Respondent By : Ms. Gouthami Manivasagam, Jcit सुनवाईकीतारीख/Date Of Hearing : 15.10.2024 घोषणाकीतारीख/Date Of Pronouncement : 25.10.2024 आदेश /O R D E R

transfer or assign any of their rights under this agreement. 3. TTK-LIG accepts that the said monogram shall be used by TTKLIG under this agreement in a manner indicative of the fact that the copyright in the said monogram is owned by TTK. Illustrative of the words to appear in close proximity to the said monogram, for the purpose

DCIT, CHENNAI vs. TTK HEALTH CARE LIMITED, CHENNAI

In the result, the appeal of the Revenue in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

transfer or assign any of their rights under this agreement. 3. TTK-LIG accepts that the said monogram shall be used by TTKLIG under this agreement in a manner indicative of the fact that the copyright in the said monogram is owned by TTK. Illustrative of the words to appear in close proximity to the said monogram, for the purpose

INCOME TAX OFFICER, CORPORATE WARD-3(1), CHENNAI, CHENNAI vs. TSL TECHNO SERVICES LIMITED(TTK HEALTHCARE PRIVATE LIMITED ), CHENNAI

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

transfer or assign any of their rights under this agreement. 3. TTK-LIG accepts that the said monogram shall be used by TTKLIG under this agreement in a manner indicative of the fact that the copyright in the said monogram is owned by TTK. Illustrative of the words to appear in close proximity to the said monogram, for the purpose

INCOME TAX OFFICER, CORPORATE WARD -3(1), CHENNAI, NUNGAMBAKKAM, CHENNAI vs. TSL TECHNO SERVICES LIMITED(TTK HEALTHCARE PRIVATE LIMITED ), CHENNAI

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

transfer or assign any of their rights under this agreement. 3. TTK-LIG accepts that the said monogram shall be used by TTKLIG under this agreement in a manner indicative of the fact that the copyright in the said monogram is owned by TTK. Illustrative of the words to appear in close proximity to the said monogram, for the purpose

INCOME TAX OFFICER, CORPORATE WARD-3(1), CHENNAI, NUNGAMBAKKAM vs. TSL TECHNO SERVICES LIMITED(TTK HEALTHCARE PRIVATE LIMITED ), CHENNAI

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

transfer or assign any of their rights under this agreement. 3. TTK-LIG accepts that the said monogram shall be used by TTKLIG under this agreement in a manner indicative of the fact that the copyright in the said monogram is owned by TTK. Illustrative of the words to appear in close proximity to the said monogram, for the purpose

DCIT, CHENNAI vs. A.V.THOMAS LEATHER & ALLIED PRODUCTS LTD., CHENNAI

The appeal of the Revenue is dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.2067/Mds/2015 "नधा"रण वष" / Assessment Year : 2012-13

transfer of agricultural land is not exigible to capital gains tax being in the nature of agricultural income. In fact, according to the Ld. representative, the computation of book profit under Section 115JB 7 I.T.A. No.2067/Mds/15 I.T.A. No.2101/Mds/15 of the Act was raised by the assessee in the assessee’s appeal. Therefore, the Ld. representative submitted that the CIT(Appeals

A.V.THOMAS LEATHER & ALLIED PRODUCTS PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

The appeal of the Revenue is dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.2067/Mds/2015 "नधा"रण वष" / Assessment Year : 2012-13

transfer of agricultural land is not exigible to capital gains tax being in the nature of agricultural income. In fact, according to the Ld. representative, the computation of book profit under Section 115JB 7 I.T.A. No.2067/Mds/15 I.T.A. No.2101/Mds/15 of the Act was raised by the assessee in the assessee’s appeal. Therefore, the Ld. representative submitted that the CIT(Appeals

M/S. DORLING KINDERSLEY INDIA PVT. LTD.,NEW DELHI vs. ITO, NEW DELHI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

transfer pricing provisions. No doubt, to the clause under which the assessee comes. For this, he relied on the decision of Hon’ble Supreme Court in the case of CCE v. Ratan Melting and Wire Industries [2008] 231 ELT 22. 10. We have heard rival contentions and gone through facts and circumstances of the case. We have gone through

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LTD.,CHENNAI vs. ACIT, LARGE TAXPAYER UNIT-1, CHENNAI

Bench: Shri Mahavir Singh, Hon’Ble & Shrimanjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.269/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. M/S.Cognizant Technology- The Asst. Commissioner- Solutions India Pvt. Ltd., Of Income Tax, 5/535, Okkiam, Thoriapakkam, Large Taxpayer Unit-1, Old Mahabalipuram Road, Chennai. Chennai-600 096. [Pan:Aaacd 3312 M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Ajay Vohra, Sr.Counsel For Shri N.V. Balaji, Adv. ""यथ" क" ओर से /Respondent By : Shri R.Shankaranarayanan, Additional Solicitor – General Of India For Shri A.P.Srinivas, Sr. Standing Counsel : सुनवाईक"तारीख/Date Of Hearing 03.07.2023 घोषणाक"तारीख /Date Of Pronouncement : 13.09.2023

297/- per share aggregating to Rs.19,080.26 Crs. from its shareholders in terms of :: 4 :: Scheme of Arrangement and Compromise (the Scheme) u/s.391 to 393 of the Companies Act, 1956, approved by the Hon’ble High Court of judicature at Madras vide in Company Petition No.102 of 2016 dated 18.04.2016. The purpose and manner in which purchase of shares from

M/S GIMPEX PVT. LTD.,CHENNAI vs. ACIT, CENTRAL CIRCLE-1(2), CHENNAI

Appeals stands dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manomohan Das

price on a future date. A forward contract can be used for hedging or speculation, although its non-standardized nature makes it particularly apt for hedging. The assessee had entered into forward contract with the aim to safeguard against the foreign exchange fluctuation on its revenue receipts from foreign parties. Further, the transaction being hedging transactions, it would fall under