M/S. GENPACT INDIA,GURGAON vs. DCIT, NEW DELHI

ITA 6543/DEL/2016Status: DisposedITAT Delhi13 June 2025AY 2013-14Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal dismissed the Revenue's grounds concerning deductions on interest income and foreign exchange gains, upholding the CIT(A)'s decision. The assessee's appeal was partly allowed, with directions to allow TDS credit and dismissal of the additional ground on dividend distribution tax.

What were the facts?

The Revenue and assessee filed cross-appeals against the CIT(A)'s order concerning assessment year 2013-14. The appeals dealt with issues related to deductions under Sections 10A and 10AA, foreign exchange gains, and dividend distribution tax.

What were the issues?

Whether interest income, foreign exchange gains, and other receipts are eligible for deduction under Sections 10A/10AA, and the applicability of Section 14A when no exempt income is earned. Also, the rate of Dividend Distribution Tax under the India-Mauritius DTAA.

Which sections of the Income-tax Act were involved?

Section 10A,Section 10AA,Section 14A,Section 115-O

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Income Tax Appellate Tribunal, DELHI BENCH ‘C’: NEW DELHI

For Appellant: Shri Tarandeep Singh, Advocate, Shri Sandeep Yadav, Advocate
For Respondent: Shri Kailash Dan Ratnoo, CIT DR
Hearing: 01.05.2025
1.

The Revenue and assessee has filed cross appeals against the order of ld.

Commissioner of Income-tax (Appeals)-37, New Delhi dated 18.10.2024 for Assessment Year 2013-14. 2. First we take up Revenue’s appeal being ITA No.6415/Del/2016 wherein the following grounds are raised :- “1. Whether on the facts and circumstances of the case & in law, the Ld. CIT(A) erred in treating income of Rs.19,85,67,669/- from interest on fixed deposits as e

The order continues below.

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