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INCOME TAX APPELLATE TRIBUNAL (CHENNAI BENCH)
SHRI S. R. RAGHUNATHA, ACJ, SHRI MANU KUMAR GIRI, J
ZF COMMERCIAL VEHICLE CONTROL SYSTEMS INDIA LIMITED CHENNAI – Appellant
Versus
DCIT CORPORATE CIRCLE 3(1) CHENNAI – Respondent
| Table of Content |
|---|
| 1. assessee incorporated and engaged in business. (Para 1 , 2 , 3) |
| 2. adjustments on other income including grants and non-operating income classification. (Para 5 , 15 , 38) |
| 3. judicially established rules on comparables and operational expenses. (Para 18 , 19 , 20 , 24) |
| 4. arguments related to outstanding receivables and their impact. (Para 55 , 86 , 101) |
| 5. r&d expenditure claims and approval requirements under various sections. (Para 126 , 141 , 156) |
| 6. deduction related to subscription charges for business purposes. (Para 154 , 158) |
| 7. consequential allowances related to tcs and associated interests. (Para 178 , 179) |
आदेश /ORDER
PER S. R. RAGHUNATHA, ACCOUNTANT MEMBER:
These appeals filed by the assessee are directed against the final assessment orders dated 23.07.2024 and dated 18.10.2024 passed by the DCIT, Corporate Circle 3(1), Chennai, u/s. 143(3) r.w.s. 144C (13) r.w.s. 144B of the Income Tax Act, 1961 (hereinafter the ‘Act’) for the assessment years 2020-21 & 2021-22 respectively in pursuant to the directions of the Dispute Resolution Panel-2, Bengaluru vide orders dated 21.06.2024 & 13.09.2024.
2. The brief facts of the case are that the assessee M/s.ZF Commer
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