ACIT Circle 40 (1) vs. Ranjeet Singh
Appeals are dismissed
ITA 419/DEL/2007[1998-1999]Status: DisposedITAT Delhi26 Jul 2016AY 1998-1999
Bench: Shri I.C. Sudhir & Shri Prashant Maharishi Assessment Year: 2007-08 Assessment Year : 2008-09 Assessment Year : 2009-10 Assessment Year : 2010-11 Dcit/Ito, Vs. Inter Globe Technology Quoteint Pvt. Ltd. Circle-11(1), Ground Floor 124, Central Wing, New Delhi. Thapar House, Janpath, New Delhi. (Pan: Aabci3241H) (Appellant) (Respondent) Assessee By: S/Shriajay Vohra, Sr. Adv., Rupesh Jain & Aditya Vohra, Adv. Department By: Shri Vijay Verma, Cit( Dr) Date Of Hearing : 09 .05.2016 Date Of Pronouncement: 26 :07.2016 Order Per I.C. Sudhir:The Revenue Has Questioned First Appellate Order In All The Above Appeals Solely On The Ground That The Learned Cit(Appeals) Has Erred In Deleting The Addition (Of Rs.27,83,45,741 In Assessment Year 2007-08, Rs.90,53,50,969 In Assessment Year 2008-09, Rs. 70,35,36,948 In Assessment Year 2009-10 & Rs.98,56,91,361 In Assessment Year 2010-11) Made On Account Of Disallowance Of Deduction Claimed Under Sec. 10Aa Of The Income-Tax Act, 1961. 2 2. Heard & Considered The Arguments Advanced By The Parties In View Of Orders Of The Authorities Below, Material Available On Record & The Decisions Relied Upon.
For Appellant: S/ShriAjay Vohra, Sr. Adv., Rupesh JainFor Respondent: Shri Vijay Verma, CIT( DR)
Section 10A
…processing services were rendered on the Galileo’s GDS in USA from the unit located in the Noida SEZ and not at the desk of the travel agents. The Learned CIT(DR) submitted that the decision of Delhi Bench of the ITAT in the case of Amadeus India Pvt. Ltd. – 79 ITD 407 (Del.) followed by the Learned CIT(Appeals) while allowing the claimed deduction to the assessee, 5 is having distinguishable facts and thus is not relevant in the present case. He submitted that in that case before Amadeus India Pvt. Ltd. (supra), the nature of activity of the assessee company was as data entry/data processing job which was soft…