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

transfer pricing orders, approx. 27% of value of imports was considered for downward adjustment. Even if the TPO orders were to be accepted, such profits would amount to Rs.1120.55 crores out of total imports of Rs.4150.20 crores only, whereas the total additions proposed in the case of assessee and RK exceed this conjectured profit. Without prejudice, the entire share capital

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, approx. 27% of value\nof imports was considered for downward adjustment. Even\nif the TPO orders were to be accepted, such profits would\namount to Rs.1120.55 crores out of total imports of\nRs.4150.20 crores only, whereas the total additions\nproposed in the case of assessee and RK exceed this\nconjectured profit. Without prejudice, the entire share\ncapital

YCH LOGISTICS INDIA PRIVATE LIMITED,KANCHIPURAM, TAMILNADU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CORPORATE CIRCLE -3(2), CHENNAI, CHENNAI

In the result the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Transfer Pricing Adjustment 1 Disallowance of deduction under 5,72,73,875 AO Order – Page 38 of the section 10AA

COASTAL ENERGY PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. No.2305/Chny/2012 िनधा"रण वष"/Assessment Year: 2008-09 Coastal Energy Private Limited, Vs. The Assistant Commissioner Of 5, Buhari Buildings, Moores Road, Income Tax, Thousand Lights, Chennai 600 006. Company Circle I(3), Chennai. [Pan: Aaacc4160A] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri B. Ramakrishnan, Fca ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing : 10.11.2025 घोषणा की तारीख /Date Of Pronouncement : 06.02.2026 आदेश /O R D E R

section 154 of the Act, which specifically seeking the error in the original assessment by furnishing revised arm’s length price, the detailed computation is reproduced as under: Name of Rate Qty Price before Discount Price after Index Price Range Conclusion Vessel before discount discount discount Coastal

ASSISTANT COMMISSIONER OF INCOME TAX LTU CIRCLE 1 CHENNAI, CHENNAI vs. CARBORUNDUM UNIVERSAL LIMITED, CHENNAI

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble Amitabh Shuklaआयकर अपील सं./ It(Tp)A Nos.2, 3 & 4/Chny/2025 िनधा@रण वष@ /Assessment Years: 2012-13, 2013-14 & 2017-18

transfer pricing adjustment in respect of guarantee given for AE to at 0.5% of the amount guaranteed. 2. The next issue is regarding disallowance under Section 14A. For this Assessment Year, the amended provisions of Rule 8D, with effect from 2nd June 2016 will be applicable and the disallowance should be restricted to 1% of the average investment which

ASHOK LEYLAND LIMITED,CHENNAI vs. DCIT NON CORP CIRCLE 8(1) LTU - II, CHENNAI

Bench: SHRI ABY T. VARKEY (Judicial Member), SHRI AMITABH SHUKLA, ACCOUNTANT MEMBER\nआयकर अपील सं./ITA No.1402/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nM/s. Ashok Leyland Ltd.,\nNo.1, Sardar Patel Road,\nGuindy, Chennai-600 032.\n[PAN: AAAСА 4651 L]\n(अपीलार्थी/Appellant)\nv.\nThe DCIT,\nNCC-8(1),\nLTU-II,\nChennai.\n(प्रत्यर्थी/Respondent)\nआयकर अपील सं./ITA No.1663/Chny/2024\nनिर्धारण वर्ष/Assessment Year: 2019-20\nThe DCIT,\nNCC-8,\nChennai.\n(अपीलार्थी/Appellant)\nv.\nM/s. Ashok Leyl

transfer pricing provisions. Accordingly, the first plea of the assessee is\nhereby rejected.\n5.3 The next issue now to be adjudicated is the ALP value of the\nguarantee commission. In this regard, the Ld. AR has relied on the quote\nprovided by Bank(s) in which they have proposed to extend bank\nguarantee at 0.325% and has urged that

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

73,618 shares of M/s ETL Power Services Limited (in short ‘ETL Power’) at the rate of Rs.14.30/- per share, which worked out to a total consideration of Rs.263,65,42,737/-. Both these shares were purchased from M/s Green Grid Group Pte Ltd., Singapore (in short ‘G3’). According to the AO, this transaction involving acquisition of shares from

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

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

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

transfer pricing provisions. Accordingly, the first plea of the assessee is hereby rejected. 5.3 The next issue now to be adjudicated is the ALP value of the guarantee commission. In this regard, the Ld. AR has relied on the quote provided by Bank(s) in which they have proposed to extend bank guarantee at 0.325% and has urged that

CONFERENCECALL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT,

In the result, appeals filed by the assessee for assessment years 2010-11 & 2012-13 are allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 584/Chny/2015 & 529/Chny/2017 िनधा"रण वष" / Assessment Year: 2010-11 & 2012-13 Conferencecall Services India Assistant Commissioner Of Private Ltd V. Income Tax, Rmz Titanium, No. 135, Corporate Circle -1(2), 1St Floor, Chennai – 34. Old Airport Road, Bangalore – 560 017. [Pan: Aaccc-6574-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Soumen Adak, Ca & Shri. Ashish Poddar, Ca ""यथ" क" ओर से/Respondent By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 20.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 15.09.2023 आदेश /O R D E R

Section 92C(3) of the Income-tax Act, 1961 ('the Act'). 3. That on the facts & circumstances of the case, the Ld. AO/ Ld. TPO on the directions issued by the Ld. DRP erred in analyzing the transaction separately by inappropriate application of Comparable Uncontrolled Price ('CUP') method without furnishing details of price charged in any comparable uncontrolled transaction

CONFERENCECALL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. ACIT, CHENNAI

In the result, appeals filed by the assessee for assessment years 2010-11 & 2012-13 are allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita No.: 584/Chny/2015 & 529/Chny/2017 िनधा"रण वष" / Assessment Year: 2010-11 & 2012-13 Conferencecall Services India Assistant Commissioner Of Private Ltd V. Income Tax, Rmz Titanium, No. 135, Corporate Circle -1(2), 1St Floor, Chennai – 34. Old Airport Road, Bangalore – 560 017. [Pan: Aaccc-6574-A] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Shri. Soumen Adak, Ca & Shri. Ashish Poddar, Ca ""यथ" क" ओर से/Respondent By : Shri. A. Sasikumar, Cit सुनवाई क" तारीख/Date Of Hearing : 20.06.2023 घोषणा क" तारीख/Date Of Pronouncement : 15.09.2023 आदेश /O R D E R

Section 92C(3) of the Income-tax Act, 1961 ('the Act'). 3. That on the facts & circumstances of the case, the Ld. AO/ Ld. TPO on the directions issued by the Ld. DRP erred in analyzing the transaction separately by inappropriate application of Comparable Uncontrolled Price ('CUP') method without furnishing details of price charged in any comparable uncontrolled transaction

LOTUS FOOTWEAR ENTERPRISES LIMITED-INDIA BRANCH,TIRUVANNAMALAI vs. DCIT, INTERNATIONAL TAX 1(2), CHENNAI

In the result all the four appeals of the assessee are allowed

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

section 115JB of the Act. A survey proceeding u/s.133A of the Act was conducted in the premises of the assessee on 31.10.2018. Following the survey, assessment was concluded u/s.143(3) of the Act for the AY 2016- 17, wherein the AO had computed the taxable income by making the following adjustment - o LU2 was considered to have been formed

CONFERENCECALL SERVICES INDIA PRIVATE LTD,BANGALORE vs. DCIT, CORPORATE CIRCLE -1(2), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.319/Chny/2018 िनधा"रणवष"/Assessment Year: 2013-14 V. M/S.Conferencecall – The Dy. Commissioner- Services India Pvt. Ltd., Of Income Tax, Rmz Titanium, No.135, 1St Floor, Corporate Circle-1(2), Old Airport Road, Chennai. Bangalore-560 017. [Pan: Aaccc 6574 A] (अपीलाथ"/Appellant) (""यथ"/Respondent)

Transfer Pricing Officer (hereinafter ‘the TPO’) to determine the Arms Length Price (hereinafter ‘ALP’) in respect of the international transaction entered into by the assessee with its AE. Pursuant thereto, the TPO vide order dated 24.10.2016 made a downward adjustment of Rs.7,53,90,367/- in respect of the international transaction of the assessee. Pursuant thereto, the AO passed

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

73,79,990/- taxable income under the normal provisions of the Income-tax Act,\n1961(the 'Act') and book profits of Rs.6,66,95,090/- as per the provisions of Section\n115JB of the Act. Accordingly, Rs.1,35,98,362/- tax liability was determined under\nthe provisions of section 115JB of the Act.\n5.\nA reference was made u/s.92CA

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

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

Transfer Pricing Officer\nfor determining the Arm's Length Price. The TPO (Deputy\nCommissioner of Income-tax, TPO-2(1), Chennai) has passed order\nu/s 92(A)(3) of the Income-tax Act, 1961 suggesting downward\nadjustment of Rs.6,73,54,391/- on account of purchases from\nAssociated Enterprises. Sufficient opportunity was given to the\nassessee for filing the submissions

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

The appeal of the assessee is allowed for statistical\npurposes

Transfer Pricing Officer\nfor determining the Arm's Length Price. The TPO (Deputy\nCommissioner of Income-tax, TPO-2(1), Chennai) has passed order\nu/s 92(A)(3) of the Income-tax Act, 1961 suggesting downward\nadjustment of Rs.6,73,54,391/- on account of purchases from\nAssociated Enterprises. Sufficient opportunity was given to the\nassessee for filing the submissions

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

In the result the appeal of the assessee is allowed

73,393 shares allotted to\nDomestic shareholders, under sec 56(2)(viib) at Rs.72,69,89,420/-.\n7. The Assessee is in further appeal before us. The issue in appeal, in\neffect, concerns the applicability of section 56(2)(viib) of the Act and the\nvaluation of a running hotel with all its facilities for determining the fair market\nvalue

DCIT,CORPORATE CIRCLE, MADURAI vs. M/S STANDARD MATCH INDUSRIES PRIVATE LIMITED, SIVAKASI

The appeal stand allowed for statistical purposes

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं./ Ita No.485/Chny/2023 (िनधा)रण वष) / Assessment Year: 2009-10) Dcit M/S. Standard Match Industries Pvt. Ltd. बनाम/ Corporate Circle 5-2-15C, Sattur Road, Vs. Madurai. Sivakasi-626 123. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaccs-5742-A (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri R. Clement Ramesh Kumar (Cit)- Ld. Dr " थ"कीओरसे/Respondent By : Shri S. Sridhar (Advocate) -Ld. Ar सुनवाईकीतारीख/Date Of Final Hearing : 31-01-2024 घोषणाकीतारीख /Date Of Pronouncement : 22-03-2024 आदेश / O R D E R

73(1) of the Act restricts the set off of speculation loss against the other business income in only those cases were speculative transaction carried on by the company. The assessee also relied on various judicial decisions to support the submissions. 4.3 The assessee’s submission were subjected to remand proceedings vide AO’s remand report dated

DCIT CORPORATE CIRCLE 2(2), CHENNAI vs. INDIAN ADDITIVES LTD., CHENNAI

In the result, appeals filed by the assessee for A

Bench: Shri Manjunatha. G & Shri Manomohan Dasआयकर अपील सं./It(Tp)A Nos.9, 10 & 11/Chny/2018 िनधा)रण वष) /Assessment Years: 2011-12, 2012-13 & 2013-14

73,812/-: The Appellant has adopted different methods for each type of transactions and the same has been already produced before the TPO and Assessing Officer. However, TPO has ignored the method adopted by the Appellant and applied TNMM for the transaction as a whole. Even assuming but not admitting in the event of Lubrizol as comparison the following adjustments