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

Section 40A(2)(b) of the Act. A dispute arose regarding the limitation period for completing the assessment.", "held": "The Tribunal held that the reference to the Transfer Pricing

M/S. GRT JEWELLERS INDIA PRIVATE LIMITED,CHENNAI vs. DCIT,. CENTRAL CIRCLE-3(3), CHENNAI

In the result, appeal filed by the assessee is partly

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita No.: 113/Chny/2024 िनधा"रणवष" / Assessment Year: 2014-15

section 40A(2)(b) of the Act and even sales to related parties which form a part of related party transactions for Companies Act purposes but which are not in the nature of expenditure as required u/s 40A(2) of the Act. 10.4. For that the Learned DRP / AO erred in disallowing a sum of 13,73,09,683/-, which

ASSISTANT COMMISSIONER OF INCOME TAX, NUNGAMBAKKAM vs. R K M POWERGEN PRIVATE LIMITED, T NAGAR

In the result the appeal of the revenue for the both the

40A(2)(b) is only the disallowance of expenditure and does not extend to the application of the money received by the payee; the application of such funds thereafter has to be treated as a separate transaction and that would never be the income of the payee. The Appellant had not commenced its business or commercial operations and the payments

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. R K M POWERGEN PVT. LTD., CHENNAI

In the result the appeal of the revenue for the both the\n

40A(2)(b) is only the disallowance\nof expenditure and does not extend to the application of\nthe money received by the payee; the application of such\nfunds thereafter has to be treated as a separate\ntransaction and that would never be the income of the\npayee. The Appellant had not commenced its business or\ncommercial operations and the payments

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SPL SHELTERS PRIVATE LIMITED, CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case

SPL SHELTERS PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Bench: Shri George George K & Ms Padmavathy S, Am

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case

DEPUTY COMMISSIONER OF INCOME TAX, CHENNAI vs. SHRIPROP PROPERTIES PRIVATE LIMITED, BANGALORE

Bench: Shri George George K & Ms Padmavathy S, Am

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS. The assessee and the revenue are in appeal against the order of the CIT(A). 5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is retrospective in nature and therefore should be applied in assessee's case

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

transfer, by the purchaser. e. If, even one of the above four limbs is not satisfied or not substantiated, the claim of land being an agriculture land excluded within the meaning covered under section 2(14) of come Tax Act, is not admissible. 73. Heard both the parties and perused the material available on record. We note that the assessee

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

transfer, by the purchaser. e. If, even one of the above four limbs is not satisfied or not substantiated, the claim of land being an agriculture land excluded within the meaning covered under section 2(14) of come Tax Act, is not admissible. 73. Heard both the parties and perused the material available on record. We note that the assessee

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

transfer, by the purchaser. e. If, even one of the above four limbs is not satisfied or not substantiated, the claim of land being an agriculture land excluded within the meaning covered under section 2(14) of come Tax Act, is not admissible. 73. Heard both the parties and perused the material available on record. We note that the assessee

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

transfer, by the purchaser. e. If, even one of the above four limbs is not satisfied or not substantiated, the claim of land being an agriculture land excluded within the meaning covered under section 2(14) of come Tax Act, is not admissible. 73. Heard both the parties and perused the material available on record. We note that the assessee

SHRIPROP PROPERTIES PVT. LTD.,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(4), CHENNAI

Accordingly.\n15. In result, appeal of both the assessees in ITA No. 1172 & 1173/Chny/2025\nare allowed and the appeal of the revenue in ITA No

40A(2)(b) of the Act and confirmed the disallowance of interest on TDS.\nThe assessee and the revenue are in appeal against the order of the CIT(A).\n5. The ld. AR argued that the tolerance limit introduced in section 56(2)(x) it is\nretrospective in nature and therefore should be applied in assessee's case

DCIT, CENTRAL CIR-2, MADURAI vs. M SHAHJAHAN, PALAKKAD

In the result, the Cross Objections filed by the assessees in C

b) of this sub-section available to the Assessing Officer for\nmaking an order of assessment or reassessment, as the case may be,\nis less than sixty days, such remaining period shall be extended to\nsixty days and the aforesaid period of limitation shall be deemed to be\nextended accordingly: Provided further that where the period available\nto the Transfer

DCIT, CENTRAL CIRCLE-2, MADURAI vs. J S NIHAR BANU, PALAKKAD

In the result, the Cross Objections filed by the assessees in C

b) of this sub-section available to the Assessing Officer for\nmaking an order of assessment or reassessment, as the case may be,\nis less than sixty days, such remaining period shall be extended to\nsixty days and the aforesaid period of limitation shall be deemed to be\nextended accordingly: Provided further that where the period available\nto the Transfer

JOINT COMMISSIONER OF INCOME TAX (OSD), CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. M/S C R I PUMPS PRIVATE LIMITED , COIMBATORE

In the result, all the three appeals filed by the Revenue are dismissed…

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for nonexclusive user of logo based on turnover and not lump

JOINT COMMISSIONER OF INCOME TAX (OSD), CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. M/S C R I PUMPS PRIVATE LIMITED, COIMBATORE

In the result, all the three appeals filed by the Revenue are dismissed…

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for nonexclusive user of logo based on turnover and not lump

JOINT COMMISSIONER OF INCOME TAX (OSD), CORPORATE CIRCLE-1, COIMBATORE, COIMBATORE vs. M/S C R I PUMPS PRIVATE LIMITED, COIMBATORE

In the result, all the three appeals filed by the Revenue are dismissed…

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri Amitabh Shuklaआयकर अपील सं./Ita No.265/Chny/2025, Assessment Years: 2014-15 आयकर अपील सं./Ita No.266/Chny/2025, Assessment Years: 2015-16 आयकर अपील सं./Ita No.267/Chny/2025, Assessment Years: 2016-17

b) of sub-section (2) to section 40A of the Act. Accordingly, we reject the contention of the ld. DR. 4.9 In the case of ACIT v. Shriram Transport Finance Co. Ltd. [2011] 9 ITR (Trib) 543 (Chennai), the Coordinate Bench of the Tribunal has observed that the payment for nonexclusive user of logo based on turnover and not lump

DCIT, CENTRAL CIR-2, MADURAI vs. M SHAHJAHAN, PALAKKAD

In the result, the Cross Objections filed by the assessees in C

b) of this sub-section available to the Assessing Officer for\nmaking an order of assessment or reassessment, as the case may be,\nis less than sixty days, such remaining period shall be extended to\nsixty days and the aforesaid period of limitation shall be deemed to be\nextended accordingly: Provided further that where the period available\nto the Transfer