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

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

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

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

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

price of a product, apart from its market price, as prescribed in Section 80-IA(8) of the Act. According to us, the sale price cannot further be segregated by imputing price attributable to marketing and R&D efforts for the simple reason that there is no such provision contained in law. We agree with the Ld. AR that

M/S. SUPER AUTO FORGE PVT. LTD.,CHENNAI vs. ITO, CORPORATE WARD-3(1), CHENNAI

Appeal of the assessee is allowed

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

5. We heard the parties and perused the material on record. The PCIT has held the order of the AO to be erroneous and prejudicial to the interest of the revenue for the reason that the AO has not conducted proper enquiry towards deduction claimed under section 80G. The PCIT while holding so, has invoked the provisions of explanation

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

price minus all general\nexpenses which were attributable to the sales. Therefore, it is not\nreasonable to say that unreasonably the profit was escalated. The\nITA Nos.1402 & 1663/Chny/2024 (AY 2019-20)\nM/s. Ashok Leyland Ltd.\n:: 41 ::\ndifference between the two percentages of profit, i.e. about 28%\n(G.P. - N.P.) thus represented the expenditure which could be said

SUNDARAM FASTNERS LTD.,CHENNAI vs. ITO, CORPORATE WARD-6(1), CHENNAI

The appeal stand partly allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm 1. आयकरअपील सं./ Ita No.2501/Chny/2024 (िनधा)रण वष) / Assessment Year: 2020-21) & 2. आयकरअपील सं./ It(Tp)A No.92/Chny/2024 (िनधा)रण वष) / Assessment Year: 2021-22) M/S Sundram Fasteners Limited Ito बनाम/ 98-A, 7Th Floor, Dr. Radhakrishnan Salai Corporate Ward-6(1) Vs. Mylapore, Chennai-600 004. Chennai "थायीलेखासं./जीआइआरसं./Pan/Tan No. Aaacs-8779-D (अपीलाथ"/Appellant) : (""थ" / Respondent) Shri Vikram Vijayaraghavan (Advocate) – Ld. Ar अपीलाथ"कीओरसे/ Appellant By : ""थ"कीओरसे/Respondent By : Shri A. Sasikumar (Cit) -Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 08-01-2025 घोषणाकीतारीख /Date Of Pronouncement : 15-01-2025 आदेश / O R D E R Manoj Kumar Aggarwal ()

5) dated 24.06.2024. Since the assessee carried out certain international transactions with its Associated Enterprises (AE), the same were referred to Ld. Transfer Pricing Officer (TPO) DCIT (TPO)-3(1), Chennai for determination of Arm’s Length Price (ALP). The Ld. TPO passed an order u/s 92CA(3) on 28.09.2022 proposing certain Transfer Pricing (TP) adjustment. Incorporating the same

INVESTOR FINANCIAL EDUCATION ACADEMY,CHENNAI vs. ITO (EXEMPTION) - 4, CHENNAI

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

80G(5)(vi) as well as 12AA of the Income Tax Act, 1961 relevant to the assessment year 2018-19. 2. Brief facts of the case are that the assessee originally filed the application in Form No. 10A for registration under section 12AA of the 2 I.T.A. Nos. 3006 & 3007/Chny/18 Act on 02.03.2017. The ld. CIT(E), vide his order

INVESTOR FINANCIAL EDUCATION ACADEMY,CHENNAI vs. ITO (EXEMPTION) - 4, CHENNAI

In the result, the appeal filed by the assessee is allowed and the substantial questions of law framed for consideration, are answered in favour of the assessee

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.3006 & 3007/Chny/2018 िनधा"रण वष"/Assessment Years: 2018-19 M/S. Investor Financial Education Vs. The Income Tax Officer Academy, 5A, 5Th Floor, Kences Tower, (Exemption) - 4, No. 1, Ramakrishnan Street, T. Nagar, Chennai 600 034. Chennai 600 017. [Pan:Aacci5911R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri M. Rajan, Cit सुनवाई की तारीख/ Date Of Hearing : 08.02.2022 घोषणा की तारीख /Date Of Pronouncement : 12.04.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Exemptions), Chennai Both Dated 28.09.2018 Passed Under Section 80G(5)(Vi) As Well As 12Aa Of The Income Tax Act, 1961 Relevant To The Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Originally Filed The Application In Form No. 10A For Registration Under Section 12Aa Of The 2

80G(5)(vi) as well as 12AA of the Income Tax Act, 1961 relevant to the assessment year 2018-19. 2. Brief facts of the case are that the assessee originally filed the application in Form No. 10A for registration under section 12AA of the 2 I.T.A. Nos. 3006 & 3007/Chny/18 Act on 02.03.2017. The ld. CIT(E), vide his order

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

transfer pricing, information technology, background checks etc., would be independent personnel services and since these professional overseas companies had not fixed base or PE in India, the payments made to them would not be chargeable to tax in India and consequently, no TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5 (1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

transfer pricing, information technology, background checks etc., would be independent personnel services and since these professional overseas companies had not fixed base or PE in India, the payments made to them would not be chargeable to tax in India and consequently, no TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made

RANE ENGINE VALVE LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

transfer pricing, information technology, background checks etc., would be independent personnel services and since these professional overseas companies had not fixed base or PE in India, the payments made to them would not be chargeable to tax in India and consequently, no TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made

RANE ENGINE VALVE LTD,CHENNAI vs. DCIT CORPORATE CIRCLE-5(1), CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

transfer pricing, information technology, background checks etc., would be independent personnel services and since these professional overseas companies had not fixed base or PE in India, the payments made to them would not be chargeable to tax in India and consequently, no TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made

RANE ENGINE VALVES LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeals filed by the assessee for assessment year 2012-13 in ITA No

Bench: Shri Mahavir Singhand Shri Amitabh Shukla

transfer pricing, information technology, background checks etc., would be independent personnel services and since these professional overseas companies had not fixed base or PE in India, the payments made to them would not be chargeable to tax in India and consequently, no TDS is to be deducted. Consequently, no disallowance under 40(a)(i) of the Act can be made

M/S. TAJMAHAL AGRO INDUSTRIES (P) LTD.,CHENNAI vs. ITO, CHENNAI

In the result, the assessee’s appeal for the assessment year 2004-05 & 2006-07 are partly allowed and the appeal for assessment year 2007-08 is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

price at the time of purchase and considered such value as cost of purchase of land rather than assuming and presuming that the value of land was NIL. The courts have held that where a composite sale comprising of land and building was come across the value had to be split into value of land and value of other assets

M/S. TAJMAHAL AGRO INDUSTRIES (P) LTD.,CHENNAI vs. ITO, CHENNAI

In the result, the assessee’s appeal for the assessment year 2004-05 & 2006-07 are partly allowed and the appeal for assessment year 2007-08 is dismissed

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

price at the time of purchase and considered such value as cost of purchase of land rather than assuming and presuming that the value of land was NIL. The courts have held that where a composite sale comprising of land and building was come across the value had to be split into value of land and value of other assets