CIT v. HCL Technologies Ltd.

404 ITR 719Supreme Court of India2018#549 most cited

What is CIT v. HCL Technologies Ltd. authority for?

When calculating deductions under sections like 10A or 10AA, any expenses or items reduced from 'export turnover' in the numerator must also be reduced from 'total turnover' in the denominator to ensure consistent application of the deduction formula.

174

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. HCL Technologies Ltd. · HCL Technologies · 404 ITR 719 · Section 10A · Section 10AA · export turnover · total turnover · deduction computation · consistent exclusion · communication expenses · travel expenses

Also reported as

302 CTR 191

Sections most often in play

Section 10ASection 10AASection 143(3)Section 234BSection 234CSection 115-OSection 14ASection 194R

Issues it is cited on

section 10aworking capital adjustmentcomputer softwaretransfer pricing ordertested partycomparable companiesrelated party transactionsection 10aadividend distribution taxmost appropriate methodtnmmsection 40(a)(i)

Judgments citing CIT v. HCL Technologies Ltd.

HCL TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5465/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, C: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.5624/Del/2010 & 5465/Del/2011 [Assessment Years: 2006-07 and 2007-08] HCL Technologies Limited, Asst. Commissioner of 806, Siddhartha 96, Income Tax, Central Circle-2, Nehru Place, New Delhi. Vs New Delhi. PAN- AAACH1645P Assessee Revenue Assessee by Shri Ajay Vohra, Sr. Adv., Shri Neeraj Jain, Adv., Shri Aditya Vohra, Adv., Shri Arpit Goyal, CA & Shri Shashvat Dhamija, Adv. Revenue by Shri G.C. Srivastava, Special Counsel (VC), Shri Kalrav Malhotra, Adv…

HCL TECHNOLOGIES LTD,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5624/DEL/2010[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, C: NEW DELHI BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI BRAJESH KUMAR SINGH, ACCOUNTANT MEMBER ITA Nos.5624/Del/2010 & 5465/Del/2011 [Assessment Years: 2006-07 and 2007-08] HCL Technologies Limited, Asst. Commissioner of 806, Siddhartha 96, Income Tax, Central Circle-2, Nehru Place, New Delhi. Vs New Delhi. PAN- AAACH1645P Assessee Revenue Assessee by Shri Ajay Vohra, Sr. Adv., Shri Neeraj Jain, Adv., Shri Aditya Vohra, Adv., Shri Arpit Goyal, CA & Shri Shashvat Dhamija, Adv. Revenue by Shri G.C. Srivastava, Special Counsel (VC), Shri Kalrav Malhotra, Adv…

GE INDIA EXPORTS PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 293/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)
Section 143(3)Section 144C(5)Section 254

…f the assessee submitted that the said issue is now settled by the decision of Hon’ble Supreme Court in the case of Commissioner of Income-tax, Central - III vs. HCL Technologies Ltd. reported in [2018] 93 taxmann.com 33 (SC)/[2018] 255 Taxman 313 (SC)/[2018] 404 ITR 719 (SC)/[2018] 302 CTR 191 (SC)[24-04- 2018] where it has been held that expenses excluded from export turnover ought to be excluded from total turnover also, otherwise, any other interpretation makes the formula absurd. Hence the deduction shall be allowed from total turnover as well. 46. We have heard the rival contentions of both the parties and…

DCIT, BANGALORE vs. M/S GE INDIA EXPORT PVT. LTD.,, BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

ITA 253/BANG/2016[2011-12]Status: DisposedITAT Bangalore27 Jan 2026AY 2011-12

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sachit Jolly, Sr. Advocate & Ms. ViyushtiFor Respondent: Dr. KJ Divya, CIT (DR)
Section 143(3)Section 144C(5)Section 254

…f the assessee submitted that the said issue is now settled by the decision of Hon’ble Supreme Court in the case of Commissioner of Income-tax, Central - III vs. HCL Technologies Ltd. reported in [2018] 93 taxmann.com 33 (SC)/[2018] 255 Taxman 313 (SC)/[2018] 404 ITR 719 (SC)/[2018] 302 CTR 191 (SC)[24-04- 2018] where it has been held that expenses excluded from export turnover ought to be excluded from total turnover also, otherwise, any other interpretation makes the formula absurd. Hence the deduction shall be allowed from total turnover as well. 46. We have heard the rival contentions of both the parties and…

DCIT, BANGALORE vs. M/S THOMSON REUTERS INDIA SERVICES PVT. LTD.,, BANGALORE

In the result, appeal filed by revenue in IT(TP)

ITA 843/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

…a respond total turnover for the purposes of computation of deduction u/s 10A of the Act. Admittedly this issue squarely covered in favour of the assessee by the decision of Hon’ble Supreme Court in the case of CIT v. HCL Technologies Ltd. reported in (2018) 404 ITR 719. The issue has also been considered by following decisions of this Tribunal in assessee’s own case:-  IT(TP) A No. 1352/Bang/2010 - Bangalore Tribunal - AY 2006-07  IT(TP) A No. 1565/Bang/2012 - Bangalore Tribunal - AY 2008-09  ITA No. 2053/Mum/2016 - Mumbai Tribunal - AY 2011-12  IT(TP)A No. 231/Bang/2014 - Mumbai Tribunal - AY 2009-10 19.1…

M/S. GENPACT INDIA,GURGAON vs. DCIT, NEW DELHI

In the result, the appeal of the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6543/DEL/2016[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 10ASection 14A

…reduce the same from the ambit of total turnover, thereby reducing the claim of deduction u/s 10A/10AA of the Act. This issue is no longer res integra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs. HCL Technologies Ltd reported in 404 ITR 719 (SC), wherein it was held that the items that are subject matter of reduction from export turnover in the numerator need to be reduced in the denominator from the ambit of total turnover also as admittedly total turnover is nothing but the sum total of export turnover and domestic turnover. Hence, the export turnover reflected in the numerator ca…

DCIT, NEW DELHI vs. M/S. GENPACT INDIA, GURGAON

In the result, the appeal of the Revenue is dismissed and the appeal filed by the assessee is partly allowed

ITA 6415/DEL/2016[2013-14]Status: DisposedITAT Delhi13 Jun 2025AY 2013-14

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Kailash Dan Ratnoo, CIT DR
Section 10ASection 14A

…reduce the same from the ambit of total turnover, thereby reducing the claim of deduction u/s 10A/10AA of the Act. This issue is no longer res integra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs. HCL Technologies Ltd reported in 404 ITR 719 (SC), wherein it was held that the items that are subject matter of reduction from export turnover in the numerator need to be reduced in the denominator from the ambit of total turnover also as admittedly total turnover is nothing but the sum total of export turnover and domestic turnover. Hence, the export turnover reflected in the numerator ca…

HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, ,HYDERABAD vs. ADDL. COMMISSIONER OF INCOME TAX , RANGE-2, HYDERABAD

In the result, Ground No.6(b) is allowed and Ground

ITA 1613/HYD/2017[2010-11]Status: DisposedITAT Hyderabad27 Mar 2025AY 2010-11

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.1613/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2010-11) Hsbc Electronic Data Vs. Addl. C.I.T Processing India (P) Ltd Range-8 Hyderabad Hyderabad Pan:Aaach8235M (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Cas Nusrath Farheen & Shyam Agarwal राज" व "ारा/Revenue By:: Smt. M. Narmada, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 26/03/2025 घोषणा की तारीख/Pronouncement: 27/03/2025 आदेश/Order

For Appellant: CAs Nusrath Farheen &For Respondent: : Smt. M. Narmada, CIT(DR)
Section 10ASection 254(2)

…e has not been excluded from the total turnover. The learned AR has referred and relied upon the judgment of the Hon'ble Supreme Court in assessee’s own case along with a group of civil appeals including in case of Pr. CIT vs. HCL Technologies Ltd reported in 404 ITR 719 and submitted that the Hon'ble Supreme Court has decided this issue in favour of the assessee by holding that while computing the relief u/s 10A of the Act, what is excluded from the export total turnover must be excluded from the total turnover since one of the component of total turnover is export turnover. The learned AR has further submitted…

EATON TECHNOLOGIES PRIVATE LIMITED,PUNE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, PUNE

In the result, the appeal filed by the assessee is allowed

ITA 1160/PUN/2024[2017-18]Status: HeardITAT Pune03 Mar 2025AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Smt. Vishal KalraFor Respondent: Shri Amol Khairnar
Section 10ASection 143(2)Section 143(3)Section 14ASection 263Section 40

…Act by virtue of the judgement passed by the Jurisdictional High Court of Bombay in the case of CIT vs Gem Plus Jewellery India Ltd. [2010] 330 ITR 174 and duly confirmed by the Hon'ble Supreme Court of India in the case of CIT vs HCL Technologies Ltd. [2018] 404 ITR 719 (SC). Disallowance under section 10AA of the Act: 7. That on the facts and circumstances of the case and in law, the PCIT erred in denying the deduction claimed under section 10AA of the Act by INR 263,46,37,168 by invoking the provisions of section 10AA(9) read with section 80IA(10) of the Act, alleging that the Appellant earned more than 'ord…

DCIT, CIRCLE-10(1), NEW DELHI vs. GENPACT INDIA NOW MERGED WITH GENPACT INDIA PVT. LTD.), HARYANA

In the result, assessee’s appeal is partly allowed

ITA 6773/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Oct 2024AY 2010-11

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI S RIFAUR RAHMAN (Accountant Member)

Section 10ASection 10A(4)

…reduce the same from the ambit of total turnover, thereby reducing the claim of deduction u/s 10A/10AA of the Act. This issue is no longer resintegra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs. HCL Technologies Ltd reported in 404 ITR 719 (SC), wherein it was held that the items that are subject matter of reduction from export turnover in the numerator need to be reduced in the denominator from the ambit of total turnover also as admittedly total turnover is nothing but the sum total of export turnover and domestic turnover. Hence, the export turnover reflected in the numerator ca…

GENPACT INDIA PVT. LTD.,GURGAON vs. DCIT, CIRCLE-10(1), NEW DELHI

In the result, assessee’s appeal is partly allowed

ITA 6582/DEL/2019[2010-11]Status: DisposedITAT Delhi11 Oct 2024AY 2010-11

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI S RIFAUR RAHMAN (Accountant Member)

Section 10ASection 10A(4)

…reduce the same from the ambit of total turnover, thereby reducing the claim of deduction u/s 10A/10AA of the Act. This issue is no longer resintegra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs. HCL Technologies Ltd reported in 404 ITR 719 (SC), wherein it was held that the items that are subject matter of reduction from export turnover in the numerator need to be reduced in the denominator from the ambit of total turnover also as admittedly total turnover is nothing but the sum total of export turnover and domestic turnover. Hence, the export turnover reflected in the numerator ca…

DCIT, NEW DELHI vs. M/S. GENPACT INDIA, GURGAON

The appeal of the assessee is partly allowed and appeal of the

ITA 4251/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Apr 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usassessment Year: 2011-12

Section 10ASection 143(3)

…ce the same from the ambit of total turnover, thereby reducing the claim of deduction u/s 10A/10AA of the Act. This issue is no longer res- integra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs. HCL Technologies Ltd reported in 404 ITR 719 (SC), wherein it was held that the items that are subject matter of reduction from export turnover in the numerator need to be reduced in the denominator from the ambit of total turnover also as admittedly total turnover is nothing but the sum total of export turnover and domestic turnover. Hence, the export turnover reflected in the numerator…

MS. GENPACT INDIA,,NEW DELHI vs. DCIT, NEW DELHI

The appeal of the assessee is partly allowed and appeal of the

ITA 4060/DEL/2016[2011-12]Status: DisposedITAT Delhi29 Apr 2024AY 2011-12

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Usassessment Year: 2011-12

Section 10ASection 143(3)

…ce the same from the ambit of total turnover, thereby reducing the claim of deduction u/s 10A/10AA of the Act. This issue is no longer res- integra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs. HCL Technologies Ltd reported in 404 ITR 719 (SC), wherein it was held that the items that are subject matter of reduction from export turnover in the numerator need to be reduced in the denominator from the ambit of total turnover also as admittedly total turnover is nothing but the sum total of export turnover and domestic turnover. Hence, the export turnover reflected in the numerator…

CRISIL LTD,MUMBAI vs. ASST CIT RG 9(2)(2), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1114/MUM/2015[2010-11]Status: DisposedITAT Mumbai10 Jan 2024AY 2010-11

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…brought to our notice relevant facts relating to the grounds raised by them and relied on the order of the Transfer Pricing Officer. 42. On the other hand, Ld.AR of the assessee submitted that Hon'ble Supreme Court in the case of HCL Techologies Ltd. [(2018) 404 ITR 719] has affirmed the Hon’ble Bombay High Court's decision in the case of Gem Plus Jewellery India Ltd. and held that the expenses excluded from the export turnover have to be excluded from the total turnover as well while computing deduction u/s 10A of the Act. 43. Considered the rival submissions and material placed on record, we observe that in t…

CRISIL LTD,MUMBAI vs. DCIT (OSD) 8(1), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 1564/MUM/2014[2009-10]Status: DisposedITAT Mumbai10 Jan 2024AY 2009-10

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…brought to our notice relevant facts relating to the grounds raised by them and relied on the order of the Transfer Pricing Officer. 42. On the other hand, Ld.AR of the assessee submitted that Hon'ble Supreme Court in the case of HCL Techologies Ltd. [(2018) 404 ITR 719] has affirmed the Hon’ble Bombay High Court's decision in the case of Gem Plus Jewellery India Ltd. and held that the expenses excluded from the export turnover have to be excluded from the total turnover as well while computing deduction u/s 10A of the Act. 43. Considered the rival submissions and material placed on record, we observe that in t…

CRISIL LTD,MUMBAI vs. ADDL CIT 8(1), MUMBAI

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 7603/MUM/2012[2008-09]Status: DisposedITAT Mumbai10 Jan 2024AY 2008-09

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 133(6)Section 144C(5)

…brought to our notice relevant facts relating to the grounds raised by them and relied on the order of the Transfer Pricing Officer. 42. On the other hand, Ld.AR of the assessee submitted that Hon'ble Supreme Court in the case of HCL Techologies Ltd. [(2018) 404 ITR 719] has affirmed the Hon’ble Bombay High Court's decision in the case of Gem Plus Jewellery India Ltd. and held that the expenses excluded from the export turnover have to be excluded from the total turnover as well while computing deduction u/s 10A of the Act. 43. Considered the rival submissions and material placed on record, we observe that in t…

DCIT 2(3), MUMBAI vs. ZENSAR TECHNOLOGIES LTD, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 8389/MUM/2010[2005-06]Status: DisposedITAT Mumbai13 Nov 2023AY 2005-06

Bench: Shri Vikas Awasthy& Shri S. Rifaur Rahmanआअसं.8389/मुं/2010 (िन.व. 2005-06) Dcit-2(3), Room No.555, 5Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ...... अपीलाथ"/Appellant बनाम Vs. M/S. Zensar Technologies Ltd., Magnet House, 2Nd Floor, N.M.Marg, Ballard Estate, Mumbai – 400 001 Pan: Aaacz 0742 K ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Manoj Kumar, Cit - Dr "ितवादी"ारा/Respondent By : Shri Nitesh Joshi, Advocate सुनवाई की ितिथ/ Date Of Hearing : 22/08/2023 घोषणा की ितिथ/ Date Of Pronouncement : 13/11/2023 आदेश/Order Per Vikas Awasthy, Jm:

For Appellant: Shri Manoj Kumar, CIT - DRFor Respondent: Shri Nitesh Joshi, Advocate
Section 10ASection 244ASection 92C

…to arrive at the profit from export business, the expenses that are excluded from export turnover ought to have been excluded from total turnover as well. In support of his submissions, he placed reliance on the decision in the case of HCL Technologies Ltd., 404 ITR 719(SC). The CIT(A) in first appellate proceedings directed to exclude telecommunication charges from total turnover in accordance with this settled legal position. He thus prayed for upholding the findings of CIT(A) on the issue. 10. In respect of ground No.3 of appeal, the ld. Counsel for the assessee submitted that while filing return of income th…

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

ITA 1654/CHNY/2011[2007-08]Status: DisposedITAT Indore06 Oct 2023AY 2007-08

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

Section 10ASection 143(2)Section 143(3)Section 144C(5)Section 14ASection 92C

…आयकर अपील"य अ"धकरण, इंदौर "यायपीठ, इंदौर IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI B.M. BIYANI, ACCOUNTANT MEMBER Assessment Year: 2007-08 Computer Sciences ACIT, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, SDF Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) PAN: AAACC1351M Assessee by Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, CA Revenue by Shri P.K. Mishra, CIT DR Date of Hearing 12.07.2023 Da…

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes

ITA 2846/BANG/2017[2013-14]Status: DisposedITAT Bangalore07 Aug 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 133(6)Section 143(3)Section 144CSection 144C(5)Section 92C(3)

…018] 404 ITR 719). 21. The ld. D.R. relied on the order of lower authorities. 22. After hearing both the parties, we are of the opinion that this issue is squarely covered by the judgement of Hon’ble Supreme Court in the case of CIT Vs. HCL Technologies Ltd. (404 ITR 719), wherein held as under: “Neither section 10A nor section 2 of the Income-tax Act, 1961 defines the term “total turnover”. The term “total turnover” is defined in clause (ba) of the Explanation to section 80HHC of the Act. Explanation 2(iv) to section 10A of the Act defines “export turnover” to mean the consideration that has been received for ex…

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE-3, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

ITA 2301/BANG/2019[2015-16]Status: DisposedITAT Bangalore31 Jul 2023AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Anmol Anand and Ms. Priya Tandon AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)
Section 234BSection 234DSection 26Section 27Section 271(1)(c)

…IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER Assessee’s Appeals S.No. Appeal No. Asst. Year Assessee Revenue IT(TP)A No. The Deputy 1. 2010-11 68/Bang/2015 Commissioner of Income IT(TP)A No. Tax, 2. 2011-12 559/Bang/2016 Circle-3(1)(2), Bangalore. IT(TP)A No. The Assistant 3. 2012-13 387/Bang/2017 Commissioner of Income IT(TP)A No. Tax, 4. 2013-14 M/s. Google India Pvt. Circl…

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