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 provisions do not override the computation mechanism of section 80IA(8) in the absence of any international transaction. Case relied upon by the revenue is not binding on Chennai Bench. The CIT(A) has rightly followed the binding precedent of the Hon’ble Supreme Court and the jurisdictional Tribunal. The mere insertion of Explanation to section 80IA

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI vs. AATHMIKA HOLDINGS PVT LTD, CHENNAI

In the result, the appeal of the Revenue stand dismissed and the

Bench: Shri Aby T. Varkey & Shri Jagadish

transfer pricing proceedings. The TPO vide show cause notice (SCN) dated 19.12.2022 proposed to ascertain the Arm’s Length Price (ALP) value of the IG3 shares, purchased from G3, by benchmarking it to the price of Rs.29.48/share, paid by M/s Chidaatma Contractors Pvt. Ltd. for acquiring the same IG3 shares from ILFS Realty Fund C/o Vistra ITCL India Ltd, during

ASSISTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. HITACHI SOLUTIONS INDIA PRIVATE LIMITED , KANCHIPURAM

In the result, the appeal filed by the assessee is allowed and the appeal filed\nby the revenue is dismissed

Bench: SHRI GEORGE GEORGE K, VICE PRESIDENT AND\nSHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER\nआयकर अपीलसं./IT(TP)A No.: 17/CHNY/2024\nनिर्धारण वर्ष / Assessment Year: 2018-19\nHitachi Solutions India Private\nLimited,\nBlock 5, 10th Floor, 1/124,\nDLF IT Park, Shivaji Gardens,\nMount Poonamallee Road,\nChennai - 600 089.\nThe Deputy Commissioner of\nIncome Tax,\nVs. Corporate Circle- 1(1),\nNo.121, M.G.Road,\nChennai - 600 034.\n[PAN:AAACZ-1544-R]\n(अपीलार्थी/Appellant)\n(प्रत्यर्थी/Respondent)\nआयकर

section 115JB of the Act.\n5.\nA reference was made u/s.92CA(1) of the Act to the Deputy Commissioner of\nIncome-tax, Transfer Pricing Officer, Corporate Circle - 2(1), Chennai (“Ld. Transfer\nPricing Officer” or “TPO”) for determination of the arm's length price (\"ALP\") of the\ninternational transactions entered into by the assessee with its Associated Enterprise

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

price whichever is lower. The appellant\ncontended that the stand of the AO is not correct also the statement recorded\nduring the survey has no evidentiary value. The appellant also submitted that\nthis component of stock difference does not represent the value of any\nexcess quantity of stock found during the course of survey in relation to the\nstock register

DEPUTY COMMISSIONER OF INCOME TAX , CHENNAI vs. ASHOK LEYLAND LIMITED, CHENNAI

In the result, appeal filed by the Revenue is partly allowed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

Section 92B does not enlarge the scope of the term international transaction to include the Corporate Guarantee in the nature provided by the assessee therein. The Tribunal held that in case of default, Guarantor has to fulfill the liability and therefore, there is always an inherent risk in providing guarantees and that may be a reason that Finance provider insist

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

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

Bench: Shri Duvvuru Rl Reddy & Shri S. R. Raghunathaआयकर अपीलसं/.Ita Nos.:3315, 3316 & 3321/Chny/2024 िनधा"रण वष" / Assessment Years: 2019-20, 2020-21 & 2018-19

price whichever is lower. The appellant contended that the stand of the AO is not correct also the statement recorded during the survey has no evidentiary value. The appellant also submitted that this component of stock difference does not represent the value of any excess quantity of stock found during the course of survey in relation to the stock register

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1, TRICHY, TRICHY vs. KUMARASAMY RAMAKRISHNAN, KARUR

In the result, all the three appeals filed by the Revenue are\nOrder pronounced in the court on 05th June, 2025 at Chennai

price whichever is lower. The appellant\ncontended that the stand of the AO is not correct also the statement recorded\nduring the survey has no evidentiary value. The appellant also submitted that\nthis component of stock difference does not represent the value of any\nexcess quantity of stock found during the course of survey in relation to the\nstock register

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, TIRUNELVELI, TIRUNELVELI vs. MS.PHILLIPS FOODS INDIA PRIVATE LIMITED, TUTICORIN

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

Bench: Shri George George Kand Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 739/Chny/2024 िनधा"रण वष"/Assessment Year:2015-16 & C.O No.17/Chny/2024 [In I.T.A. No.739/Chny/2024] The Assistant Phillips Foods India Pvt. Commissioner Of Income Vs. Ltd., Tax, C-75/76, Sipcot Industrial Circle 1, Complex, Tirunelveli Tuticorin Central Stand S.O. Tuticorin – 628 002. Pan: Aabcp 7916Q (अपीलाथ"/Appellant) (""यथ"/Respondent/Cross Objector) राज"व क" ओर से /Revenue By : Shri Ar.V. Sreenivasan, Cit िनधा"रती क" ओर से/Assessee By : Ms. K. Amulya, Ca & Shri Vinay Jain, Ca सुनवाई क" तारीख/Date Of Hearing : 07.07.2025 घोषणा क" तारीख/Date Of Pronouncement : 08.07.2025

Transfer Pricing Officer (TPO) to determine the arm’s length price of the international transaction undertaken by the assessee with its AE. The TPO vide order dated 01.11.2019 passed u/s.92CA(3) of the Act proposed upward adjustment of Rs.13.98 crores to the assessee’s margin from export of its manufactured product to its AE. In this context, it is relevant

DCIT, CHENNAI vs. AB MAURI INDIA PRIVATE LIMITED, CHENNAI

In the result, the appeal filed by the Revenue is partly-allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita No.3318/Chny/2018 (िनधा"रणवष" / Assessment Year: 2013-2014) The Deputy Commissioner Of Vs. M/S. A B Mauri India Private Ltd, Income Tax, Plot No.218 & 219 Bommasandra Corporate Circle 1(1) Jigani Link Road, Rajapura Hobli, Chennai 600 034. Jigani, Anekal Taluk. Bengaluru 560 105. [Pan:Aaeca 9923H ] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. Kavitha, Irs, Addl. Cit. ""यथ" क" ओर से /Respondent By : Shri S P Chidambaram, Advocate सुनवाई क" तार"ख/Date Of Hearing : 20.11.2024 घोषणा क" तार"ख /Date Of Pronouncement : 25 .11.2024 आदेश / O R D E R Per Manu Kumar Giri ()

46A of the Income Tax Rules. Accordingly, the Ground related to Deprecation on Effluent Treat Plant is set-aside to the file of Assessing Officer. The AO is free to conduct necessary enquiries and assessee is given liberty to file all the documents before the AO. The AO shall pass order after giving opportunity of being heard to the assessee

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

transfer of bonds before maturity, the difference would be subjected to capital gains tax or assessable as business income, as the case may be. On final redemption, no capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

transfer of bonds before maturity, the difference would be subjected to capital gains tax or assessable as business income, as the case may be. On final redemption, no capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular

ACIT CIRCLE 1 , SALEM vs. M/S AVR SWARNAMAHAL JEWELLERY PRIVATE LIMITED, SALEM

The appeals stand partly allowed for statistical purposes in terms of our above order

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

transfer of bonds before maturity, the difference would be subjected to capital gains tax or assessable as business income, as the case may be. On final redemption, no capital gains will arise. The tax would be deducted at source on difference between the bid price and the redemption price at the time of maturity. The Para-8 of the Circular

THE INDIA CEMENTS LTD.,CHENNAI vs. DCIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri George George K & Shri S.R. Raghunatha

transferred, shall be increased or decreased, as the case :-5-: ITA. No:1708/Chny/2025 may be, by the amount or the aggregate of the amounts referred to in the said sub-clause relatable to such foreign operations. Explanation.—For the purposes of this sub-section, the expression— (i) "year of convergence" means the previous year within which the convergence date falls

DCIT CENTRAL CIRCLE-3 [1], CHENNAI vs. M/S OM SHAKTHY AGENCIES [MADRAS]PVT LTD, CHENNAI

In the result, the appeal stand dismissed

Bench: Hon’Ble Shri V. Durga Rao, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.321/Chny/2022 (िनधा"रण वष" / Assessment Year: 2012-13) Dcit M/S. Om Shakthy Agencies (Madras) Pvt.Ltd. बनाम/ Central Circle-3(1) T-64, Sidco Industrial Estate, Vs. Chennai. Guindy, Chennai-600 032. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaaco-3722-E (अपीलाथ"/Appellant) : (!"थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Clement Ramesh Kumar (Cit)-Ld. Dr !"थ"कीओरसे/Respondent By : Shri K.R. Vasudevan (Advocate)-Ld.Ar सुनवाईकीतारीख/Date Of Hearing : 10-08-2023 घोषणाकीतारीख /Date Of Pronouncement : 23-08-2023 आदेश / O R D E R

46A. The Ld. CIT-DR also submitted that the assessee is in the habit of 3 inflating purchase cost. The Ld.AR, on the other hand, submitted that substantial issues, as stated in impugned order, are covered in assessee’s favour by the decision of this Tribunal in earlier years. The Ld. AR supported the findings rendered in the impugned order

ACIT, CHENNAI vs. SRI BALAJI EDUCATIONAL AMD TRUST CHARITABLE PUBLIC TRUST , CHENNA

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

transfer or receive any Specified Bank Notes. From the above what is clear is that up to the appointed date Le 31.12.2016, there is no prohibition for dealing with Specified Bank Notes. Therefore, in my considered view, the objection of the AO on this regard in light of said Act is devoid of merits. Further, a similar issue had been

M/S. SRI BALAJI EDUCATIONAL AND CHARITABLE PUBLIC TRUST,CHENNAI vs. ACIT, CENTRAL CIRCLE-3(4), CHENNAI

In the result, the appeal of the Assessee and that of the Department are dismissed

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1249/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 M/S. Sri Balaji Educational & Acit, Charitable Public Trust, Vs. Central Circle 3(4), No. 60, First Avenue, Chennai. Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (&'थ"/Respondent) [Pan: Aacts-1386-D] (अपीलाथ"/Appellant) आयकर अपील सं./Ita Nos.:1471/Chny/2025 िनधा$रण वष$ / Assessment Year: 2017-18 Acit, M/S. Sri Balaji Educational & Central Circle 3(4), Vs. Charitable Public Trust, Chennai. No. 60, First Avenue, Jai Durga Complex, Ashok Nagar, Chennai – 600 083. Tamil Nadu. (अपीलाथ"/Appellant) [Pan: Aacts-1386-D] (&'थ"/Respondent) िनधा$)रती की ओर से/Assessee By : Shri. Y.Sridhar, Fca राज4 की ओर से /Revenue By : Ms. E. Pavuna Sundari, Cit सुनवाई की तारीख/Date Of Hearing : 08.09.2025 घोषणा की तारीख/Date Of Pronouncement : 01.12.2025

transfer or receive any Specified Bank Notes. From the above what is clear is that up to the appointed date Le 31.12.2016, there is no prohibition for dealing with Specified Bank Notes. Therefore, in my considered view, the objection of the AO on this regard in light of said Act is devoid of merits. Further, a similar issue had been

DCIT, CORPORATE CIRCLE - 1(1),, CHENNAI vs. M/S. ALLIANCE GRANIMARMO PVT. LTD.,, CHENNAI

In the result, the appeal of the Revenue is partly allowed

price variation.\nWe also note that the Ld. First appellate authority in his order supra, extracted\nherein above has analyzed the issue in great detail, inter-alia, by considering\nthe remand report of the AO 26.02.2019. The Ld. Counsel for the assesse has,\nthrough his copies of invoices and shipping bills placed in the paper book,\nvividly explained that there