ACIT, EXEMPTIONS, COIMBATORE vs. MAHENDRA EDUCATIONAL TRUST, MANAKKAL

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

4. The brief facts of the case extracted from assessment year 2011-12 are that, the assessee is a charitable trust registered u/s.12A of the Income Tax Act, 1961 (hereinafter the ‘Act’) and is imparting education by running various educational institutions, which includes 5 Engineering Colleges and 1 Arts & Science College, a Matriculation School, a Higher Secondary School

ACIT, EXEMPTIONS, COIMBATORE vs. MAHENDRA EDUCATIONAL TRUST, MANAKKAL

In the result, appeal filed by the Revenue is dismissed and cross objection filed by the assessee is allowed

Bench: Shri Duvvuru Rl Reddy & Shri G. Manjunathaआयकर अपील सं./Ita Nos.: 125 & 126/Chny/2019 िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) & Co Nos.: 18 & 19/Chny/2019 (In Ita Nos.125 & 126/Chny/2019) िनधा"रण वष" / Assessment Years: 2011-12 & 2012-13 The Acit (Exemptions), M/S. Mahendra Educational May Flower Mid City Building, V. Trust, 1510, Trichy Road, Kalipatti Post, Attayampatti Via, Coimbatore – 641 018. Tiruchengode, Namakkal – 637 501. Pan: Aaaam2491C (अपीलाथ"/Appellant) (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri N.V. Balaji, Advocate राज" की ओर से /Revenue By : Shri G. Chandrababu, Addl.Cit सुनवाई क" तार"ख/Date Of Hearing : 28.01.2021 घोषणा क" तार"ख/Date Of Pronouncement : 11.02.2021

4. The brief facts of the case extracted from assessment year 2011-12 are that, the assessee is a charitable trust registered u/s.12A of the Income Tax Act, 1961 (hereinafter the ‘Act’) and is imparting education by running various educational institutions, which includes 5 Engineering Colleges and 1 Arts & Science College, a Matriculation School, a Higher Secondary School

RENAULT INDIA PRIVATE LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No. 1078/Mds/2017 "नधा"रण वष" /Assessment Year : 2012-2013. M/S. Renault India Private Vs. The Deputy Commissioner Of Limited, Income Tax, No.37 & 38, Asv Ramana Corporate Circle 5(1) Towers, Chennai. 4Th Floor, Venkatnarayana Road, T.N Agar, Chennai 600 017. [Pan Aadcr 2042M ] (अपीलाथ"/Appellant) (""यथ"/Respondent)

c) Interim adjustment. Should RNAIPL wish to adjust the reference price of the Renault Licensed Vehicle at any other time than regular adjustments and in accordance with the rules provided by paragraph (a) above, RNAIPL shall provide RIPL with 4 (four) weeks notice before the effective date of any such price change and include the justification for the required

DCIT, CHENNAI vs. FLAKT (INDIA) LTD., CHENNAI

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

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamonyआयकर अपील सं./Ita No.1032/Mds/2014 "नधा"रण वष" / Assessment Year : 2009-10

4. On the contrary, Shri Kapil Hirani, the Ld. representative for the assessee, submitted that the services rendered by the Associate Enterprise to the assessee-company is not in dispute. In fact, this was accepted by the Transfer Pricing Officer and the Dispute Resolution Panel. The only dispute is with regard to adoption of most appropriate method. The assessee

PHILIPS FOODS INDIA PRIVATE LIMITED,TUTICORIN vs. PCIT-1, MADURAI

In the result, the appeal of the assesse is allowed

4) of the Act vide order dated 01.11.2019.\nIt was submitted that PCIT, Madurai-1 has no authority to invoke\nrevisionary proceedings w.r.t orders passed by TPO and hence he was\ndevoid of any valid jurisdiction. It was submitted that the Ld. PCIT,\nMadurai-1 had initiated revisionary proceedings u/s 263 of the Act for the\nimpugned assessment years

T vs. MOTOR COMPANY LTD.,CHENNAIVS.ACIT, CHENNAI

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकरअपीलसं./Ita No.672/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 M/S.Tvs Motor Co. Ltd., V. The Acit, No.29, Haddows Road, Corporate Circle – 3(1), Chennai-600 006. Chennai. [Pan: Aaacs 7032 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

transfer pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex pricing adjustment towards royalty receivable at the rate of 2% at ex- ITA No.672/Chny/201 /Chny/2017 (AY 2012-13) M/s.TVS Motor Co. Ltd. M/s.TVS Motor Co. Ltd. :: 16 :: factory sale at Rs.2,15,56,000/ factory

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2, COIMBATORE vs. M/S. RP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

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

transferred to the Central Government, State Government local authority or any other statutory authority" (also ref. CBDT Circular no. 14/2001 dated 9/11/2001) developed and begins to operate. Further, as can be made out from the section the deduction will be in respect of income generated from operation of the infrastructure facility in the following specified years as mentioned

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are dismissed

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

transferred to the Central Government, State Government local authority or any other statutory authority" (also ref. CBDT Circular no. 14/2001 dated 9/11/2001) developed and begins to operate. Further, as can be made out from the section the deduction will be in respect of income generated from operation of the infrastructure facility in the following specified years as mentioned

K.G. DENIM LIMITED,COIMBATORE vs. DCIT, TP-2(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 1718/Chny/2024 िनधा"रण वष" / Assessment Year: 2020-21 K G Denim Limited, Dcit, 1, Thenthirumalai, V. Tp-2(1), Jadayampalayam B.O., Chennai. Dhoddabavi, Coimbatore – 641 302. [Pan: Aaack-7940-C] (अपीलाथ"/Assessee) (""यथ"/Respondent) अपीलाथ" क" ओर से/Assessee By : Shri. Arjun Raj, Advocate : Shri. A. Sasikumar, Cit ""यथ" क" ओर से/Respondent By सुनवाई क" तारीख/Date Of Hearing : 11.09.2024 घोषणा क" तारीख/Date Of Pronouncement : 05.12.2024

4. The PCIT failed to appreciate that the twin conditions prescribed for assuming jurisdiction under Section 263 of the Act were not satisfied concurrently on the facts and in the circumstances of the case and hence ought to have appreciated that the order of revision under consideration was passed out of time, invalid, passed without jurisdiction and not sustainable

M/S. SIVANANDHA MILLS LTD.,COIMBATORE vs. DCIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

transfer of land paid to the Bank of Baroda and payment of workmen compensation for settlement at Rs 807,43,083/-. ii) Disallowance of claim of set off of business expenditure against long term capital gains at ` 3,68,30,254/- iii) Disallowance of bad debts of rs 14,21,618/- 3. The ld. AR submitted that the assessee

SIVANANDHA MILLS LIMITED,COIMBATORE vs. ACIT, COIMBATORE

In the result, ITA No.2106/Mds/13 is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

transfer of land paid to the Bank of Baroda and payment of workmen compensation for settlement at Rs 807,43,083/-. ii) Disallowance of claim of set off of business expenditure against long term capital gains at ` 3,68,30,254/- iii) Disallowance of bad debts of rs 14,21,618/- 3. The ld. AR submitted that the assessee

DCIT , COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED , ERODE

In the result, all these four appeals filed by the Revenue are\ndismissed

transferred to the Central Government, State Government local\nauthority or any other statutory authority\"\n(also ref. CBDT Circular no. 14/2001 dated 9/11/2001)\nThus, as contained in the above clarification an assessee is entitled to\ndeduction under section 80IA only after the infrastructure facility is\ndeveloped and begins to operate. Further, as can be made out from\nthe section

DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2, COIMBATORE vs. M/S RPP INFRA PROJECTS LIMITED, ERODE

In the result, all these four appeals filed by the Revenue are\ndismissed

transferred to the Central Government, State Government local\nauthority or any other statutory authority\"\n(also ref. CBDT Circular no. 14/2001 dated 9/11/2001)\nThus, as contained in the above clarification an assessee is entitled to\ndeduction under section 80IA only after the infrastructure facility is\ndeveloped and begins to operate. Further, as can be made out from\nthe section

GOKULAKRISHNA,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX, NON CORPORATE CIRCLE 8(1), CHENNAI

In the result, the appeal filed by the assessee is allowed and the stay\napplication is dismissed

C' BENCH, CHENNAI\nश्री जॉर्ज जॉर्ज के, उपाध्यक्ष एवं श्री जगदीश, लेखा सदस्य के समक्ष\nBEFORE SHRI GEORGE GEORGE K, VICE PRESIDENT AND\nSHRI JAGADISH, ACCOUNTANT MEMBER\n\nआयकर अपीलसं/.ITA No.:1088/CHNY/2025\nनिर्धारण वर्ष/Assessment Year: 2017-18\n&\nS.A. No. 48/Chny/2025 [In ITA No. 1088/Chny/2025\nGokulakrishna,\nD 401, Purva Jade, Arcot Road,\nValasaravakkam, Chennai

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

section 13(1) (c) of the Act" When the AD has concluded that he has to treat the cash refunds as withdrawals for the purpose of college expenses, merely because proof adduced for such expenses is 'treated as not genuine' by the AO, cannot automatically lead to the conclusion of violation of sec.13(1)(c), unless

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

section 13(1) (c) of the Act" When the AD has concluded that he has to treat the cash refunds as withdrawals for the purpose of college expenses, merely because proof adduced for such expenses is 'treated as not genuine' by the AO, cannot automatically lead to the conclusion of violation of sec.13(1)(c), unless

DCIT, CENTRAL CIRCLE 1(1), CHENNAI vs. VELLORE INSTITUTE OF TECHNOLOGY, VELLORE

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

section 13(1) (c) of the Act" When the AD has concluded that he has to treat the cash refunds as withdrawals for the purpose of college expenses, merely because proof adduced for such expenses is 'treated as not genuine' by the AO, cannot automatically lead to the conclusion of violation of sec.13(1)(c), unless

VELLORE INSTITUTE OF TECHNOLOGY,VELLORE vs. DCIT, CC IV(1), CHENNAI

Appeals of the Revenue are dismissed whereas that of assessee are partly allowed

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

section 13(1) (c) of the Act" When the AD has concluded that he has to treat the cash refunds as withdrawals for the purpose of college expenses, merely because proof adduced for such expenses is 'treated as not genuine' by the AO, cannot automatically lead to the conclusion of violation of sec.13(1)(c), unless

COOK INDIA MEDICAL DEVICES PRIVATE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 1(2), CHENNAI

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

Bench: Shri George Mathan & Shri S. Jayaramanआयकर अपील सं./Ita No.3137/Chny/2017 "नधा"रण वष" /Assessment Year: 2013-14

transfer pricing adjustment amounting to Rs.1,05,28,594/-. 4.1. The Ld. AO/TPO/ DRP have erred, in law and in facts, by rejecting the foreign AEs as the tested party and selecting the Appellant as the tested party. 4.2. The Ld. AO/TPO/DRP has erred, in laws and facts, by rejecting transaction net margin method as the most appropriate method