CIT v. Hewlett Packard Global Soft Ltd.

Hewlett-Packard Globalsoft Private Limtied, Bangalore vs. DCIT, Bangalore

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

…est income should be considered to be part of business income rather than income from other sources. In this connection reliance can be placed on the Hon'ble Karnataka High Court's decision in case of CIT vs Hewlett Packard Global Soft Ltd. reported in (2017) 403 ITR 453. The Ld.AR placed reliance on the decision of Hon’ble Karnataka High Court held as under: "37. On the above legal position discussed by us, we are of the opinion that the Respondent assessee was entitled to 100% exemption or deduction under Section 10-A of the Act in respect of the interest income earned by it on the deposits made by it with the…

DCIT, Bangalore vs. M/S Hewlett Packard Globalsoft Pvt. Ltd., Bangalore

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

…est income should be considered to be part of business income rather than income from other sources. In this connection reliance can be placed on the Hon'ble Karnataka High Court's decision in case of CIT vs Hewlett Packard Global Soft Ltd. reported in (2017) 403 ITR 453. The Ld.AR placed reliance on the decision of Hon’ble Karnataka High Court held as under: "37. On the above legal position discussed by us, we are of the opinion that the Respondent assessee was entitled to 100% exemption or deduction under Section 10-A of the Act in respect of the interest income earned by it on the deposits made by it with the…

Xerox Business Services India Private Limited, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes and the appeal filed by the Revenue is partly allowed

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

…ith regard to deduction claimed only on interest earned from fixed deposits. 19.1. After hearing both the parties, we find that this issue is covered by the judgement of Hon’ble Karnataka High Court in the case of CIT vs. Hewlett Packard Global Software Ltd. 403 ITR 453 in favour of the assessee. As such the interest earned from fixed deposit invested in the export earning of the assessee to be included in the profit of the undertaking while computing the deduction under Section 10A of the Act. Accordingly, this ground of Revenue is dismissed. 20. In the result, the appeal filed by the assessee is partly allowe…

Asst.CIT, Bangalore vs. M/S Xerox Business Services of India Pvt. Ltd., Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes and the appeal filed by the Revenue is partly allowed

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai, Jm

…ith regard to deduction claimed only on interest earned from fixed deposits. 19.1. After hearing both the parties, we find that this issue is covered by the judgement of Hon’ble Karnataka High Court in the case of CIT vs. Hewlett Packard Global Software Ltd. 403 ITR 453 in favour of the assessee. As such the interest earned from fixed deposit invested in the export earning of the assessee to be included in the profit of the undertaking while computing the deduction under Section 10A of the Act. Accordingly, this ground of Revenue is dismissed. 20. In the result, the appeal filed by the assessee is partly allowe…

DCIT, Bangalore vs. M/S Apotex Pharmachem India Pvt. Ltd., Bangalore

In the result, the appeal filed by revenue stands partly allowed for statistical purposes as indicated hereinabove

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI. CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER Assessment Year : 2010-11 M/s. Apotex Pharmachem India Pvt. The Deputy Ltd., Commissioner of Plot No. 1A, 4th Phase, Income Tax, Bommasandra Industrial Circle – 1(1)(1), Estate, Bangalore. Vs. Bangalore – 560 099. PAN: AACCB1658E APPELLANT RESPONDENT : Shri Padam Chand Khincha, Assessee by CA : Shri Sumer Singh Meena, CIT Revenue by DR (OSD) Date of Hearing : 03-01-2022 Date of Pronouncement : 28-03-2022 ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal by revenue…

JCIT, Bangalore vs. M/S Biocon Ltd., Bangalore

In the result appeal filed by assessee for assessment year

Bench: Shri B.R. Baskaran & Smt Beena Pillai

…f under section 10AA and 10B of the Act needs to be allowed on the interest income earned from bank deposits, intercorporate loans etc., basis the full bench ruling of the Hon'ble Jurisdictional High Court in the case of CIT v Hewlett Packard Global Soft Ltd (403 ITR 453) which has held that incidental income by way of interest on bank deposits or staff loans would be entitled to hundred percent deduction under section 10A and 10B of the Act. The Appellant craves, leave to add, alter. delete or modify all or any of the above grounds of appeal.” It has been submitted that the above grounds emanates from the asses…

Biocon Limited, Bangalore vs. JCIT, Bangalore

In the result appeal filed by assessee for assessment year

Bench: Shri B.R. Baskaran & Smt Beena Pillai

…f under section 10AA and 10B of the Act needs to be allowed on the interest income earned from bank deposits, intercorporate loans etc., basis the full bench ruling of the Hon'ble Jurisdictional High Court in the case of CIT v Hewlett Packard Global Soft Ltd (403 ITR 453) which has held that incidental income by way of interest on bank deposits or staff loans would be entitled to hundred percent deduction under section 10A and 10B of the Act. The Appellant craves, leave to add, alter. delete or modify all or any of the above grounds of appeal.” It has been submitted that the above grounds emanates from the asses…

M/S Safran Engineering Services India Pvt. Ltd., Bangalore vs. Asst.C.I.T., Bangalore

In the result corporate grounds raised by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI. CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No.701/Bang/2016 Assessment Year : 2011-12 M/s Safran Engineering The Asst. Commissioner of Services India Pvt. Ltd., Income-Tax, The HUB, Property No.8/2 & Circle-6(1)(1), 9, Ambalipura Village, Vs. Bengaluru. Varthur Hobli, Begaluru East Taluk, Sarjapura Road, Bengaluru-560 102. PAN – AAFCS 9003 D APPELLANT RESPONDENT Assessee by : Smt. Rashmi R, Advocate Revenue by : Ms. Neera Malhotra, CIT (DR) Date of Hearing : 11-03-2021 Date of Pronouncement : 07-04-2…