ASSISTANT COMMISSIONER OF INCOME TAX, TIRUPUR vs. SRI SHANMUGAVEL MILLS PRIVATE LIMITED, TIRUPUR

In the result, appeal filed by the Revenue is dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

transfer of such goods or services is a specified domestic transaction referred to in section 92BA.” 18. As regards the above, the Ld.AR submitted that the explanation to section 80-IA(8) provides that for the purposes of section 80-IA(8), the market value of any goods and services would mean either clause (i) which states the price

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1,TIRUPPUR, TIRUPPUR vs. PRABHU SPINNING MILLS PRIVATE LIMITED, TIRUPPUR

In the result all the grounds raised by the revenue for the A

80-IA(8) of the Act, \"market value\" in relation\nto any goods or services, means (a) the price that such goods or services would\nordinarily fetch in the open market; or (b) the arm's length price as defined in clause\n(ii) of section 92F,where the transfer

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 of goods are recorded at the market value of goods. The relevant extracts of the provision of section 80- IA(8) of the Act is as follows: …. 5.12 From the above it is clear that, the sale price

ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI vs. M/S. ASHOK LEYLAND LIMITED, CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

price at which the goods manufactured were sold to the customers viz., based on the invoices raised upon the third parties. According to us therefore, this basis of revenue recognition followed by the assessee is in line with Section 80-IC(6) read with Section 80-IA(8) of the Act. We therefore see no reason to tinker with

M/S. ASHOK LEYLAND LIMITED,CHENNAI vs. ACIT NON CORPORATE CIRCLE 8(1)-LTU-2, , CHENNAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Jagadish

price at which the goods manufactured were sold to the customers viz., based on the invoices raised upon the third parties. According to us therefore, this basis of revenue recognition followed by the assessee is in line with Section 80-IC(6) read with Section 80-IA(8) of the Act. We therefore see no reason to tinker with

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 of goods are recorded at the market\nvalue of goods. The relevant extracts of the provision of section 80-\nIA(8) of the Act is as follows:\n5.12 From the above it is clear that, the sale price

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

The appeal of the assessee is allowed

Bench: Shri George George Kand Ms. Padmavathy.Sआयकर अपील सं./Ita No.2663/Chny/2025 धििाजरण वर्ज /Assessment Year: 2021-22

transfer, then for the purpose of deduction under section 80-IA, the profits and gains of such eligible business shall be computed by adopting arm's length pricing

TITAN COMPANY LIMITED,HOSUR vs. ACIT, CHENNAI

In the result, both the appeals filed by the assessee are allowed

Bench: Hon’Ble Shri Manu Kumar Giri & Shri Hon’Ble S.R. Raghunathaआयकर अपील सं./ Ita No.393/Chny/2018 & आयकर अपील सं./ It(Tp)A No.89/Chny/2018 िनधा>रण वष> /Assessment Years: 2013-14 & 2014-15 Titan Company Ltd., The Dy. Commissioner Of Income No.3, Spicot Industrial Complex, Vs. Tax, Hosur, Krishnagiri – 635 126. Ltu-2, [Pan: Aaact 5131A] Chennai. (अपीलाथ"/Appellant) (""यथ"/Respondent)

80-IC units and submissions made in case of disallowance of provision made for customer loyalty programme. I. Transfer Pricing 2. The Hon'ble DRP/ learned Assessing Officer ('AO') / Transfer Pricing Officer (TPO) erred in ignoring the transfer pricing analysis undertaken by the Appellant in accordance with provisions of the Income-tax Act, 1961 ('the Act') read with Income

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

price and hence, such transfers cannot be a basis for denying the claim for deduction u/s.10AA of the Act. The relevant provisions are reproduced below for your ready reference: Section 10AA of the Act “(9) The provisions of sub-section (8) and sub-section (10) of section 80

M/S. ALKRAF THERMOTECHNOLOGIES PVT. LTD.,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeals of the assessee for AYs 2011-12, 2012-\n13, 2013-14, 2017-18 & 2018-19 are allowed\nOrder pronounced on the 18th day of February, 2026, in Chennai

Section 80-IA(8)/(10) to ensure that the\ntransfer of such materials/components between non-eligible and eligible\n:: 29 ::\nunits are at arm's length. It is not the Revenue's case before us that the\ninter-unit transfers were at low prices

FAIVELEY TRANSPORT TECHNOLOGIES INDIA PVT. LTD.,HOSUR vs. ACIT, CORPORATE CIRCLE-1(1), CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S.R. RAGHUNATHA (Accountant Member)

Transfer Pricing Officer, as the case may be,] shall be deemed to be erroneous in so far as it is prejudicial to the interests of the revenue, if, in the opinion of the Principal [Chief Commissioner or Chief Commissioner or Principal] Commissioner or Commissioner, ‘(a) the order is passed without making inquiries or verification which should have been made

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 order u/s.92CA(3) of the Act for the AY 2013-14 was completed after the conclusion of the search, wherein the TPO proposed TP downward adjustment of Rs.407.25 crores on the imports from MIPP. The TPO did not propose any adjustment on the receipt of share capital reported in the Form 3CEB. The assessee had filed appeal against

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

80-IA.”\n\nSection 801A of the Act\n“(8) Where any goods or services held for the purposes of the eligible\nbusiness are transferred to any other business carried on by the\nassessee, or where any goods or services held for the purposes of any\nother business carried on by the assessee are transferred to the eligible\nbusiness

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

80-IA.\"\nSection 801A of the Act\n“(8) Where any goods or services held for the purposes of the eligible\nbusiness are transferred to any other business carried on by the\nassessee, or where any goods or services held for the purposes of any\nother business carried on by the assessee are transferred to the eligible\nbusiness

M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

80-IAB of the Act. 20. In order to adjudicate the issue before us, it is first relevant to examine the SEZ provisions and Rules, which are applicable to the assessee. The relevant Rule 11 of the SEZ Rules 2006, being referred to by both the parties, as it stood then, read as follows: “11. Processing and non-processing area

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 order\nu/s.92CA(3) of the Act for the AY 2013-14 was completed after\nthe conclusion of the search, wherein the TPO proposed TP\ndownward adjustment of Rs.407.25 crores on the imports from\nMIPP. The TPO did not propose any adjustment on the receipt of\nshare capital reported in the Form 3CEB. The assessee had filed\nappeal against

M/S. ALKRAFT THERMOTECHNOLOGIES PVT. LTD.,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeals of the assessee for AYs 2011-12, 2012-

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 80-IA(8)/(10) to ensure that the transfer of such materials/components between non-eligible and eligible ITA Nos.1946-1950/Chny/2025 (AYs 2011-12 to 2013-14, 2017-18 & 2018-19) M/s. Alkraft Thermotechnologies Pvt. Ltd. :: 29 :: units are at arm’s length. It is not the Revenue’s case before us that the inter-unit transfers were at low prices

M/S. ALKRAFT THERMOTECHNOLOGIES PVT. LTD.,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeals of the assessee for AYs 2011-12, 2012-

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 80-IA(8)/(10) to ensure that the transfer of such materials/components between non-eligible and eligible ITA Nos.1946-1950/Chny/2025 (AYs 2011-12 to 2013-14, 2017-18 & 2018-19) M/s. Alkraft Thermotechnologies Pvt. Ltd. :: 29 :: units are at arm’s length. It is not the Revenue’s case before us that the inter-unit transfers were at low prices

M/S. ALKRAFT THERMOTECHNOLOGIES PVT. LTD.,CHENNAI vs. DCIT, CC-1(1), CHENNAI

In the result, the appeals of the assessee for AYs 2011-12, 2012-

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 80-IA(8)/(10) to ensure that the transfer of such materials/components between non-eligible and eligible ITA Nos.1946-1950/Chny/2025 (AYs 2011-12 to 2013-14, 2017-18 & 2018-19) M/s. Alkraft Thermotechnologies Pvt. Ltd. :: 29 :: units are at arm’s length. It is not the Revenue’s case before us that the inter-unit transfers were at low prices