M/S Sap Labs India Private Limited, Bangalore vs. Addl.CIT, Bangalore
In the result, appeal of the assessee is partly allowed for statistical purpose
ITA 1006/BANG/2011[2007-08]Status: DisposedITAT Bangalore30 Jun 2016AY 2007-08
Bench: Shri. Sunil Kumar Yadav & Shri. Abraham P. Georgei.T(Tp).A No.1006/Bang/2011 (Assessment Year : 2007-08) M/S. Sap Labs India P. Ltd, No.138, Export Promotion Industrial Park, Whitefield, Bengaluru 560 066 .. Appellant Pan : Aafcs3649P
For Appellant: Shri. KanchanKoushal, CAFor Respondent: Shri. Rajesh K. R. Jha, CIT -DR
Section 234BSection 92C
…ove amount was unjustly rejected. Argument of the assessee before the DRP was that the conditions required to be fulfilled u/s.80JJA of the Act, were met by it. Relying on the coordinate bench decision in the case of ACIT v. Texas Instruments (India) P. Ltd, [115 TTJ 976], Ld. AR submitted that computer engineers who were not in supervisory position were eligible to be considered as workmen. However, DRP was not impressed. According to the DRP, decision in the case of Texas Instruments (supra) was appealed by the Revenue before the jurisdictional High Court and the issue had not reached a finality. Assessment was…