SASKEN TECHNOLOGIES LIMITED ,BANGALORE vs. ACIT, CIRCLE-6(1)(1), BANGALORE

ITA 2058/BANG/2025Status: DisposedITAT Bangalore29 June 2026AY 2020-2121 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal allowed the appeal concerning disallowance of payments to Forrester Research Ltd. as the assessee satisfied the conditions for deduction under Section 80G. For payments made through the US branch, the Tribunal remanded the issue to the Assessing Officer to examine the scope of work for Tangent International, UK, allowing the assessee an opportunity to furnish details.

What were the facts?

The assessee, engaged in telecom software services, made payments to its US branch and to Forrester Research Ltd. without deducting tax at source. The Assessing Officer disallowed these payments under Section 40(a)(i) read with Section 195, treating them as fees for technical services sourced in India. The assessee argued that the services were utilized for business outside India and did not make available technical knowledge.

What were the issues?

Whether payments made to foreign entities for services utilized by an Indian company's overseas branch are chargeable to tax in India and require TDS. Whether disallowance under Section 14A and eligibility for deduction under Section 80G were correctly determined.

Which sections of the Income-tax Act were involved?

Section 40(a)(i),Section 195,Section 14A,Section 80G,Section 9(1)(vii)(b),Section 234B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI, VICE – & SHRI SOUNDARARAJAN K.

PER PRASHANT MAHARISHI, VICE – PRESIDENT

1.

These two appeals have been filed by the assessee for different assessment years. Since they involve common issues and both parties advanced common arguments, they are disposed of together by this common order.

2.

ITA No. 2057/Bang/2025 is filed by M/s. Sasken Technologies Ltd. [ THE Assessee/ Appellant] for Assessment Year 2017-18 against the appellate order dated 31 July 2025 passed by the National Faceless Appeal Centre, Delhi [ the ld. CIT (A)]. By the said order, the appeal filed by the assessee against the assessment order dated 3 December 2019 passed under section 143(3) of

The order continues below.

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