How many judgments cite CIT v. HCL Technologies Ltd.?

174 judgments on BharatTax cite CIT v. HCL Technologies Ltd. (404 ITR 719), spanning 2012 to 2026.

Which sections of the Income Tax Act does CIT v. HCL Technologies Ltd. come up under?

It is most often cited in judgments turning on Section 10A, Section 10AA, Section 143(3), Section 234B, Section 234C, Section 115-O.

CIT v. HCL Technologies Ltd.

404 ITR 719Supreme Court of India2018#556 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 366,470 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 10A Section 10AA Section 143(3)Section 234B Section 234C Section 115-O Section 14A Section 194R

Read the full judgment

Issues it is cited on

section 10a working capital adjustment computer software transfer pricing order tested party comparable companies related party transaction section 10aa dividend distribution tax most appropriate method tnmm section 40(a)(i)

Judgments citing CIT v. HCL Technologies Ltd.

Indecomm Global Services India Private Limited, Bangalore vs. DCIT, Bangalore

In the result, assessee’s C

ITA 553/BANG/2015[2010-11]Status: DisposedITAT Bangalore13 Feb 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao, CIT-DR-I

Section 10ASection 143(1)Section 143(3)Section 144C(5)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N. V. VASUDEVAN, VICE PRESIDENT AND SHRI JASON P. BOAZ, ACCOUNTANT MEMBER Appeal No. and APPELLANT RESPONDENT Assessment year IT(TP)A No.404/Bang/2015 The Deputy M/s. Indecomm Global Services 2010-11 Commissioner of India Pvt. Ltd., Income Tax, (formerly known as IGS Imaging Circle - 3(1)(1), Services India Private Limited) Bengaluru. Indecom House, #30, Lasker Road, Augugodi, Banalore – 560 030. PAN : AABCI 2902 H IT(TP)A No.553/Bang/2015 M/s. Indecomm Global The Deputy Commissioner of 2010-11 Services India Pvt. Ltd., Income Tax, Banalore –…

Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore vs. M/S Tata Elxsi. Ltd, Bangalore

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

ITA 1517/BANG/2017[2011-12]Status: DisposedITAT Bangalore05 Dec 2018AY 2011-12

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)

Section 10ASection 115JSection 143(3)Section 155

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, BENGALURU BEFORE SHRI N.V.VASUDEVAN, VICE PRESIDENT and SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER M/s.Tata Elxsi Ltd., ITPB Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant PAN:AAACT 7872 Q Vs Deputy Commissioner of Income-tax, Circle 7(1)(1), Bengaluru. … Respondent AND ITA Nos.1516 & 1517/Bang/2017 (Assessment years: 2010-11 & 2011-12) (By Revenue) Assessee by : Shri Padamchand Khincha, CA. Revenue by : Shri Pradeep Kumar, CIT(DR) Date of hearing : 13/11/2018 Date of pronouncement : 05/12/2018 O R D E R Per INTURI RAMA RAO, AM : ITA Nos.1516 & 1517/Ba…

Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore vs. M/S Tata Elxsi. Ltd., Bangalore

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

ITA 1516/BANG/2017[2010-11]Status: DisposedITAT Bangalore05 Dec 2018AY 2010-11

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)

Section 10ASection 115JSection 143(3)Section 155

M/S Tata Elxsi Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

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

ITA 1222/BANG/2017[2011-12]Status: DisposedITAT Bangalore05 Dec 2018AY 2011-12

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Pradeep Kumar, CIT(DR)

Section 10ASection 115JSection 143(3)Section 155

Pr. Commissioner of Income Tax vs. M/S Sasken

Appeals are dismissed at the stage of admission

ITA/44/2016HC Karnataka31 Oct 2018

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

Section 10ASection 260

…held the issue in favour of the assessee confirming the order of the Appellate Authority. The learned counsel for the respondent – assessee further relying upon the decision in Commissioner of Income Tax, Central - III vs. HCL Technologies Ltd. : (2018) 404 ITR 719 (SC), would submit that the question raised by the revenue is answered by the Hon’ble Supreme I.T.A.Nos.44-45/2016 - 7 - Court. The Hon’ble Supreme Court in the said decision has taken note of the decision of this Court in Tata Elxsi Ltd. (supra) and held that what is excluded from export turnover must also be excluded from total…

Hydro Pneumatic Accessories India P.Ltd, Mumbai vs. ITO 10(3)1, Mumbai

In the result, the appeal is allowed

ITA 7735/MUM/2012[2008-09]Status: DisposedITAT Mumbai26 Oct 2018AY 2008-09

Bench: Shri C.N. Prasad () & Shri N.K. Pradhan () Assessment Year: 2008-09 Hydro Pneumatic Ito-10(3)(1), Mumbai. Accessories India Pvt. Ltd. Vs. 17, Raja Industrial Estate, P.K. Road, Nahur Village, Mulund (W), Mumbai- 400080. Pan No. Aaach1351A Respondent Appellant Assessee By : Mr. Dharan V. Gandhi, Ar Revenue By : Mr. Abiram Kartikeyan, Dr Date Of Hearing : 31/07/2018 Date Of Pronouncement: 26/10/2018

For Appellant: Mr. Dharan V. Gandhi, ARFor Respondent: Mr. Abiram Kartikeyan, DR

Section 143(3)

…rupees as a result of a foreign exchange fluctuation that took place in the course of the export transaction. The gains had to be taken into account for the purpose of section 10A.” 11.1 In a recent decision in the case of CIT v. HCL Technologies Ltd. (2018) 404 ITR 719 (SC), the Hon’ble Supreme Court referring to the Hydro Pneumatic 14 formula for computation of deduction u/s 10A of the Act held at page 731 as under: “In the instant case, if the deductions on freight, telecommunication and insurance attributable to the delivery of computer software under section 10A of the Income-tax Act are allowed only in exp…

Principal Commissioner of Income Tax-4 vs. M/S Mcml Systems Pvt Ltd

ITA/36/2018HC Karnataka11 Oct 2018

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

Section 10ASection 260

…ounsel for the appellants – revenue frankly submits that the question proposed in these appeals stands answered in terms of the decision of the Hon’ble Supreme Court in the case of Commissioner of Income Tax, Central-III vs. HCL Technologies Ltd. : (2018) 404 ITR 719 (SC) at paragraphs 10, 15 and 17 to 21 of the said decision, the Supreme Court has held as follows:- “10. The question arises here that when the particular term has not been defined in any particular Section, is it allowed to import the meaning of such term from the other provisions of the same Act? Section 10A of the IT Act is a ITA…

Director of Income Tax (International Taxation) vs. Smt. D. Lakshmi Reddy

ITTA/427/2012HC Telangana24 Aug 2018

Bench: M.GANGA RAO,RAMESH RANGANATHAN

The Prl Commissioner of Income Tax [Central] Hyderabad vs. M/S Sree Nagendra Constructions, Khammam

ITTA/490/2016HC Telangana21 Aug 2018

Bench: RAMESH RANGANATHAN,KONGARA VIJAYA LAKSHMI

Little Eye Software Labs Private Limited

In the result, the appeal is disposed of

COP/210/2016HC Karnataka25 Nov 2016

Bench: VINEET KOTHARI

Section 10ASection 195Section 260Section 40

…ion of Bombay High Court in 'CIT Vs. GEMS PLUS JEWELLERY 4 INDIA LIMITED' (2011) 330 ITR 175 (BOMBAY) and the second substantial question of law has been answered in favour of the assessee by the Supreme Court in 'CIT Vs. HCL TECHNOLOGIES LTD.' (2018) 404 ITR 719 (SC). Learned counsel for the assessee has further submitted that the first substantial question of law has been rendered academic. 4. On the other hand, learned counsel for the revenue fairly submitted that the first substantial question of law has been rendered academic. However, the finding of the Tribunal with regard to this substantia…

The Commissioner of Income Tax (Central) vs. M/s. sAtyam Computer SErvices Ltd

ITTA/200/2011HC Telangana22 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

The Commissioner of Income Tax-II vs. M/s.The AP Vardhman [Mahila] Coop Urban Bank Ltd

ITTA/411/2010HC Telangana01 Mar 2016

Bench: RAMESH RANGANATHAN,M.SATYANARAYANA MURTHY

The Commissioner of Income Tax (Central) vs. M/s. Hyderabad House Pvt. ltd

ITTA/247/2013HC Telangana11 Jul 2013

Commissioner of Income Tax vs. M/S Canara Hotel and

RP/351/2012HC Karnataka22 Jun 2012

Bench: RAVI MALIMATH,N.KUMAR

Section 10ASection 260Section 260A

…by the learned counsel for the assessee that the aforesaid issues are no longer res integra and they have already been answered against the revenue by judgment of the Supreme Court in 'COMMISSIONER OF INCOME-TAX, CENTRAL -III VS. HCL TECHNOLOGIES LTD.', 404 ITR 719. Learned counsel was unable to dispute the aforesaid legal position. 4. Learned counsel for the assessee further submitted that the third substantial question of law has already been decided against the revenue and in favour of the assessee by a judgment passed by a division bench of this court dated 22.11.2011 passed in I.T.A.No.1189/200…