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...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

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...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

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...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

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...

transfer pricing controversy. Ground no. 2 is thus allowed. 46. We may also add that ground no.1 in the assessee’s appeal for the assessment year 2009-10 is general in nature and it does not call for any specific adjudication. Tax withholding obligation from interest payments to Mauritian entities 47. In ground no. 3.1, the assessee is aggrieved

BANCA SELLA S.P.A. CHENNAI BRANCH (IT DIVISION),CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

Section 5OB of IT ACT 1961 2.4 The learned DRP held that there was no 'element of non-competition in the transaction' which was not acceptable as per the agreement it is seen that the assessee is transferring the right, title and interest in the business forever to the its Associated Enterprise. From the above it is very clear that

SELLA SYNERGY INDIA PVT. LTD.,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

Section 5OB of IT ACT 1961 2.4 The learned DRP held that there was no 'element of non-competition in the transaction' which was not acceptable as per the agreement it is seen that the assessee is transferring the right, title and interest in the business forever to the its Associated Enterprise. From the above it is very clear that

DCIT, CHENNAI vs. SELLA SYNERGY INDIA PVT LTD., CHENNAI

In the result, the appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri G. Pavan Kumarआयकर अपील सं./I.T.A. No.398/Mds/2015 "नधा"रण वष" /Assessment Year : 2010-2011

Section 5OB of IT ACT 1961 2.4 The learned DRP held that there was no 'element of non-competition in the transaction' which was not acceptable as per the agreement it is seen that the assessee is transferring the right, title and interest in the business forever to the its Associated Enterprise. From the above it is very clear that

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

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

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer agreement dated 19.10.2011 from M/s.Southern Petrochemical Industries Corporation Ltd. For this purpose, the assessee obtained ECB loan in foreign currency amounting to USD 15 million (INR 74.53 crores) vide agreement dated 14.10.2011 from AM International Holding Pte Ltd, Singapore. The assessee has restated its liability towards ECB loan as on 31.03.2012 and loss on restatement of liability has been

DCIT CORPORATE CIRCLE-2(1), CHENNAI vs. GREENSTAR FERTILIZERS LTD., CHENNAI

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

Bench: Shri V.Durga Rao & Shri G. Manjunathaआयकरअपीलसं./I.T.A.Nos.34 & 35 /Chny/2020 ("नधा"रणवष" / Assessment Years: 2012-13 & 2013-14) The Deputy Commissioner Of Vs M/S. Green Star Fertilizers Ltd, Income Tax, No.8, Spic House, Corporate Circle-2(1), Mount Road, Guindy, Room No.511, Wanaparthy Block Chennai-600 032. Chennai-600 034. Pan: Aadcg 9451D (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer agreement dated 19.10.2011 from M/s.Southern Petrochemical Industries Corporation Ltd. For this purpose, the assessee obtained ECB loan in foreign currency amounting to USD 15 million (INR 74.53 crores) vide agreement dated 14.10.2011 from AM International Holding Pte Ltd, Singapore. The assessee has restated its liability towards ECB loan as on 31.03.2012 and loss on restatement of liability has been