ACIT, CIRCLE-18(2), NEW DELHI vs. NIIT TECHNOLOGIES LTD.,, NEW DELHI

ITA 2863/DEL/2018Status: DisposedITAT Delhi28 November 2025AY 2010-11Bench: SHRI S RIFAUR RAHMAN (Accountant Member), MS. MADHUMITA ROY (Judicial Member)27 pages
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What did the Tribunal hold?

The Tribunal dismissed the revenue's grounds concerning Section 10B deductions, finding them covered by previous favorable decisions. For transfer pricing, the issue of comparable companies was remitted back to the CIT(A) for fresh adjudication. The assessee's grounds related to Section 14A disallowances were allowed.

What were the facts?

The assessee, Coforge Limited, filed appeals against assessment orders for AY 2009-10 and 2010-11. The revenue also filed cross-appeals. The core issues involved deductions under Section 10B, transfer pricing adjustments for corporate support services, and disallowances under Section 14A.

What were the issues?

Whether the assessee is eligible for deduction under Section 10B despite not maintaining separate books, and the correctness of transfer pricing adjustments and Section 14A disallowances.

Which sections of the Income-tax Act were involved?

Section 10B,Section 14A,Section 115JB

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Income Tax Appellate Tribunal, “H” BENCH, DELHI

Before: SHRI S RIFAUR RAHMAN

For Appellant: Ms. Somya Jain, CA
Hearing: 18.09.2025Pronounced: 28.11.2025

PER MADHUMITA ROY, JM:

This group of cross appeals filed by the assessee and revenue are directed

against the orders dated 31.01.2018 passed by the Ld. CIT

The order continues below.

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