M/S. Te Connectivity Services India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore
In the result, the appeal by the assessee is partly allowed
ITA 191/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Sept 2022AY 2017-18
Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.191/Bang/2022 Assessment Year : 2017-18 M/S. Te Connectivity Services India Private Vs. National Faceless Assessment Centre, Limited, Delhi. 59/2, 1St Floor, Gurudas Heritage, Block-B, 100 Feet Ring Road, Banashankari 2Nd Stage, Bengaluru – 560 070. Pan: Aafct 3474 R Appellant Respondent Assessee By : Shri. Sriram Seshadri, Ca Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 14.09.2022 Date Of Pronouncement : 16.09.2022 O R D E R Per N. V. Vasudevan:
For Appellant: Shri. Sriram Seshadri, CAFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144BSection 92Section 92C
…ad incurred expense by way of payment to its parent company which has in-turn issued shares to the employees of the assessee. He placed reliance on decision of the decision of the Hon’ble Jurisdictional Karnataka High Court decision in the case of Biocon Ltd. 430 ITR 151(Karn.) which upheld the decision rendered by the Jurisdictional Special Bench1 in the case of BIOCON 25 ITR (Tribunal) SB Bangalore. The Hon’ble High Court had observed that: “10. From perusal of section 37(1), which has been referred to supra, it is evident that an assessee is entitled to claim deduction under the aforesaid provision if the exp…
