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

Section 56(1) for Assessment Years 2010-11 to 2014-15but confirmed and enhanced the downward adjustment made by the TPO for Assessment Year 2014-15, holding as under:\n“7.5 Addition u/s. 56(1):\n7.5.1 The Assessing Officer has added the following share premia paid by the two foreign investors, as income of the assessee u/s. 56

M/S. UPDATER SERVICES LTD.,CHENNAI vs. DCIT, CENTRAL CIRCLE-2(3), CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

price (i.e., INR 275 per share) was wrongly assessed as income under Section 56(2)(viia) of the Act. The learned AO failed to note that the valuation of INR 607 determined under the DCF method is not in accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back

ACIT, CHENNAI vs. UPDATER SERVICES LIMITED, CHENNAI

In the result, the grounds of appeal raised by both the assessee and the Revenue, as well as the grounds raised in the cross-objections filed by the assessee, are treated as allowed for statistical...

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1339 /Chny/2025 िनधा#रण वष# / Assessment Year: 2017-18 M/S. Updater Services Limited (Formerly Dcit, Known As Updater Services Private Vs. Central Circle -2(3), Limited), No.2/302-A, Uds Salai, Chennai. Off Old Mahabalipuram Road, Thoraipakkam, Chennai – 600 097. [Pan:Aaacu-6845-J] (अपीलाथ%/Appellant) (&'थ%/Respondent)

price (i.e., INR 275 per share) was wrongly assessed as income under Section 56(2)(viia) of the Act. The learned AO failed to note that the valuation of INR 607 determined under the DCF method is not in accordance with the valuation methodology prescribed under the Act. • If one were to compute the FMV of the shares bought back

M/S. AMBATTUR DEVELOPERS PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-1(1), CHENNAI

In the result the appeal of the assessee is allowed

price.\n9. Applicability of section 56(2)(viib)\nAt the outset, it is important to determine the applicability of Section\n56(2)(viib) of the Act to the facts of the present case. The Ld.AR submitted that\n:-7-:\nITA. No: 2601/Chny/2024\nthe purpose of introduction of this section will be determinative factor and\nsubmitted as under:\n9.1 Purpose

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)

56,11,939 TNMM Renault SAS Sale of trial cars 71,93,334 Renault SAS Purchase of sample 15,96,100 miniature car models Renault Nissan Reimbursement of salaries 3,46,14,038 CUP Global Management and wages paid Renault SAS Reimbursement of F1 race 68,83,300 CUP related cost received Renault BV Interest paid

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

transfer pricing orders, which formed the basis of the revenue's appeal, had been deleted in prior proceedings. Therefore, the additions made by the Assessing Officer were deleted.", "result": "Dismissed", "sections": ["Section 56

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)

Section 92B of the Act. He vehemently stressed on the incorrect methodology followed by the TPO to vehemently stressed on the incorrect methodology followed by the TPO to vehemently stressed on the incorrect methodology followed by the TPO to make the transfer pricing adjustment i.e. the bright line test, which had make the transfer pricing adjustment i.e. the bright line

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

56 SOT 349). 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

VAANI ESTATES PVT LTD.,CHENNAI vs. ITO CORPORATE WARD 3(4), CHENNAI

In the result appeal of the assessee is allowed

Bench: Shri A.Mohan Alankamony & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.1352/Chny/2018 (िनधा"रण वष" / Assessment Year: 2014-15) M/S. Vaani Estates Pvt. Ltd., Vs The Ito, No.60, Old No.100, Iv Street, Corporate Ward – 3(4), Abhiramapuram, Chennai Chennai – 600 018. Pan: Aaecv0933A (अपीलाथ"/Appellant) (""यथ"/Respondent)

price / share premium for the shares allotted to Mrs.Sasikala Raghupathy over and above the face value of shares which works out to Rs.23,31,68,600/- (i.e., 23,086 * 10,100). Accordingly the Ld.AO invoking the provisions of Section 56(2)(viib) of the Act, added the amount of Rs.23,31,68,600/- to the income of the assessee

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

M/S. STERLITE INDUSTRIES (INDIA) LTD.,MADURAI vs. ADDITIONAL CIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

M/S STERLITE INDUSTRIES (INDIA) LTD.,TUTICORIN vs. DCIT, CHENNAI

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

ACIT, CHENNAI vs. M/S. STERLITE INDUSTRIES (INDIA) LTD., TUTICORIN

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.318 & 319/Mds/2008 "नधा"रण वष" / Assessment Year : 2004-05 आयकर अपील सं./Ita No. 1020/Mds/2010 "नधा"रण वष" / Assessment Year : 2005-06 आयकर अपील सं./Ita No. 1665/Mds/2010 "नधा"रण वष" / Assessment Year : 2006-07

Transfer Pricing Officer, more particularly page 27 of his order, found that the assessee has failed to furnish information and documents regarding the expenses said to be incurred by providing management consultancy services to CMT and TCM. To ITA No.1020,1665 & 1386/Mds/10 ascertain the nature of service rendered by the assessee to CMT and TCM, the matter was remitted back

KARADI PATH EDUCATION COMPANY PRIVATE LIMITED,CHENNAI vs. COMMISSIONER, CHENNAI

In the result the appeal of the assessee is allowed

price or in the alternative provided a valuation under DCF method to\ncounter the contentions of your appellant. The DCF method postulates that the\nvalue of an asset is the sum of the cash flows expected to be generated by the\nasset during the life of the asset discounted to present value by the cost of\ncapital. This is done

DCIT CORPORATE CIRCLE 3(2), CHENNAI vs. VENTURE LIGHTING INDIA LIMITED, CHENNAI

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

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwal

transferring unlisted shares at prices much below their fair market value, it is proposed to amend section 56 to also

ASIRVAD MICRO FINANCE LIMITED,ANNA SALAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -1(1), CHENNAI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1140/Chny/2025 Assessment Years: 2016-17 Asirvad Micro Finance Limited, Assistant Commissioner Of No.9, 9Th Floor, Club House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [Pan: Aagca5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.P.R.Prasanna Varma, Fca & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 25.09.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

price ought to have been Rs.56.36/share. The Ld.AO consequently made an addition of Rs.42,29,48,758/- invoking provisions of section 56(2)(viib) r.w. Rule 11UA. Aggrieved by the order, the assessee preferred appeal before the Ld.CIT(A) who confirmed the findings of the Ld.AO. The assessee is assailing the impugned order of Ld.CIT(A) dated

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

56,155/- as against the returned income of Rs.3,51,95,750/- computed by the Appellant in its return of income for AY 2013-14. 3. The Ld. AO has erred in law and in fact, in determining a sum of Rs.1,98,87,910/- as the balance tax (including interest) demand payable by the Appellant. Transfer pricing grounds