ACIT-13(1)(1), MUMBAI vs. ORACLE FINANCIAL SERVICES SOFTWARE LIMITED, MUMBAI

ITA 1580/MUM/2018Status: DisposedITAT Mumbai20 February 2026AY 2007-08Bench: SMT. BEENA PILLAI (Judicial Member), SHRI GIRISH AGRAWAL, ( (Accountant Member)1 pages
AI SummaryAssessee appeal allowed and revenue appeal partly allowed

What did the Tribunal hold?

The Tribunal noted that the issues in the present appeals were identical to those decided in the assessee's own case for A.Y. 2008-09. The Tribunal found that the previous order had examined the identical issues in detail, and in the absence of any distinguishing facts, the findings and conclusions from that order were respectfully followed and applied mutatis mutandis to the present assessment years. An additional ground raised by the assessee for A.Y. 2007-08, challenging the validity of the assessment order on the ground of limitation, was withdrawn by the assessee and consequently dismissed.

What were the facts?

The appeals filed by the assessee and the Revenue arose from separate orders passed by the Ld. CIT(A) for Assessment Years 2007-08, 2009-10, and 2010-11. The issues involved in these appeals were identical to those previously heard and decided by the Tribunal in the assessee's own case for A.Y. 2008-09. The assessee's AR submitted that the facts and circumstances remain unchanged and requested that the previous decision be followed.

What were the issues?

The appeals involved common issues such as deduction u/s 10A, disallowance u/s 14A, retention of revenue by overseas subsidiaries, benefit of +/-5% variation on ALP, notional interest on delayed receivables, interest charged on loans to AEs, and customization fees paid to AEs. An additional ground regarding the assessment order being passed beyond the period of limitation was withdrawn.

Which sections of the Income-tax Act were involved?

Section 10A,Section 14A,Section 92C,Section 153,Section 155

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “J” BENCH, MUMBAI

Before: SMT. BEENA PILLAI & SHRI GIRISH AGRAWAL

For Appellant: Shri G.C. Srivastava (virtually present), AR
For Respondent: Shri Pankaj Kumar, CIT D/R
Hearing: 29.01.2026Pronounced: 20.02.2026

Heard together (6 matters)

I.T.A. No. 1474/Mum/2018
I.T.A. No. 3431/Mum/2019
I.T.A. No. 4794/Mum/2019
I.T.A. No. 1580/Mum/2019
I.T.A. No. 3996/Mum/2019
I.T.A. No. 5377/Mum/2019

Read from the judgment's own cause title. This page is filed under one of them.

Per Bench: Present cross-appeals filed by the assessee as well as the Revenue arise out of the separate orders passed by the Ld. CIT(A)-57, Mumb

The order continues below.

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