CIT v. Infosys Technologies Ltd.

297 ITR 167Supreme Court of India2008#935 most cited

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

Allotment of shares to employees under an Employee Stock Option Plan (ESOP) before April 1, 2000, is not a taxable perquisite if the benefit's value is unascertainable at the time of option exercise due to conditions like a lock-in period.

115

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2015 to 2026.

Also referred to as

CIT v. Infosys Technologies Ltd. · Infosys Technologies Ltd. · ESOP · Employee Stock Option Plan · section 17(2) · section 17 · perquisite value · share allotment · pre-Finance Act 1999 · unascertainable benefit · lock-in period

Also reported as

166 Taxmann 204

Sections most often in play

Section 143(3)Section 147Section 40(a)(i)Section 9(1)(vii)Section 37(1)Section 36(1)(vii)Section 17(2)(vi)Section 133(6)

Issues it is cited on

section 17(2)(iiia)section 2(15a)perquisite valuesection 17(2)section 17fees for included servicesmercantile system of accountingprofits and gains of business or professionsection 9(1)(vii)section 201section 30section 194a

Judgments citing CIT v. Infosys Technologies Ltd.

DCIT, MUMBAI vs. NOVARTIS HEALTHCARE PRIVATE LIMITED , MUMBAI

In the result, appeal by Revenue is dismissed and C

ITA 7386/MUM/2025[2021-22]Status: DisposedITAT Mumbai08 Jan 2026AY 2021-22

Bench: Shri Pawan Singh & Shri Arun Khodpia(Physical Hearing) Dcit Novartis Healthcare Private Limited, Room No.320, 3Rd Floor, Mtnl Te Vs 7Th Floor Inspire Bkc, G Block, Bkc Building, Pedder Road, Cumballa Main Road, Mumbai Hill, Mumbai [Pan:Aaacn5094N] Appellant / Assessee Respondent / Revenue

Section 194HSection 254(1)

…liable to tax in the hands of employee. This issue is squarely covered in favour of the appellant in the following cases: • Total Energies Marketing India Pvt. Ltd. [ITA Nos. 127 to 133/MUM/2023 dated 16 August 2023 (Mumbai ITAT)] • Infosys Technologies Ltd [297 ITR 167 (SC)] • Bharat Financial Inclusion Ltd. [ITA No. 237/Hyd/2017 dated 3 August 2018 (Hyderabad ITAT)] 8c. In view of the above, the addition made by Ld. AO is deleted. The Appeal of the Revenue is DISMISSED. C.O. No. 121/Mum/2025 The Respondent company filed a Cross Objection by raising following three grounds of appeal on the issue of applicabi…

DCIT(TDS)-2(3), MUMBAI vs. NOVARTIS HEALTHCARE PRIVATE LIMITED, MUMBAI

Appeal is allowed

ITA 2768/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Dec 2025AY 2020-21

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Dcit(Tds)-2(3) Novartis Healthcare Private 320, 3Rd Floor, Cumbala Hill, Limited Mtnl Te Bldg. Peddar Road Vs. 7Th Floor, Inspire Bkc, G Gopalrao Deshmukh Marg Block, Bkc Main Road Mumbai-400 026. Bandra, Mumbai-400 051. Appellant Respondent C.O. No. 121/Mum/2025 (Assessment Year : 2020-21)

For Respondent: S/Shri Anish Thacker (CA)
Section 133ASection 192Section 194Section 194HSection 201

…liable to tax in the hands of employee. This issue is squarely covered in favour of the appellant in the following cases : • Total Energies Marketing India Pvt. Ltd. [ITA Nos. 127 to 133/MUM/2023 dated 16 August 2023 (Mumbai ITAT)] • Infosys Technologies Ltd [297 ITR 167 (SC)] • Bharat Financial Inclusion Ltd. [ITA No. 237/Hyd/2017 dated 3 August 2018 (Hyderabad ITAT)] 8c. In view of the above, the addition made by Ld. AO is deleted. The Appeal of the Revenue is DISMISSED. C.O. No. 121/Mum/2025 The Respondent company filed a Cross Objection by raising following three grounds of appeal on the issue of applicabil…

DCIT-2(3)(1), MUMBAI vs. INDUSIND BANK LTD., MUMBAI

ITA 3675/MUM/2023[2018-19]Status: DisposedITAT Mumbai17 Jul 2025AY 2018-19
Section 143(3)Section 14ASection 250Section 35DSection 36(1)(via)Section 36(1)(viia)Section 43B

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\nBEFORE MS PADMAVATHY S, AM & SHRI RAJ KUMAR CHAUHAN, JM\nI.T.A. No. 1841/Mum/2023\n(Assessment Year: 2018-19)\nI.T.A. No. 1842/Mum/2023\n(Assessment Year: 2019-20)\nIndusind Bank Limited.,\n8th Floor, Tower 1, One India Bulls\nCentre, Delisle Road,\nMumbai-400013.\nPAN: AAACI1314G\nAppellant)\nDCIT-2(3)(1),\n5th Floor, Room No. 552,\nVs. Aayakar Bhavan, M.K. Road,\nMumbai-400020.\n: Respondent)\nI.T.A. No. 3775/Mum/2023\n(Assessment Year: 2018-19)\nI.T.A. No. 3774/Mum/2023\n(Assessment Year: 2019-20)\nDCIT-2(3)(1),\n552, Aayakar Bhavan, M…

INDUSIND BANK LTD,MUMBAI vs. THE DCIT-2(3)(1), MUMBAI

In the result, the Income Tax Appeal is\ndismissed

ITA 1842/MUM/2023[2019-20]Status: DisposedITAT Mumbai17 Jul 2025AY 2019-20
Section 143(3)Section 14ASection 250Section 35DSection 36(1)(via)Section 36(1)(viia)Section 43B

…{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL\n“I” BENCH, MUMBAI\n\nBEFORE MS PADMAVATHY S, AM & SHRI RAJ KUMAR CHAUHAN, JM\n\nI.T.A. No. 1841/Mum/2023\n(Assessment Year: 2018-19)\n\nI.T.A. No. 1842/Mum/2023\n(Assessment Year: 2019-20)\n\nIndusind Bank Limited.,\n8th Floor, Tower 1, One India Bulls\nCentre, Delisle Road,\nMumbai-400013.\nPAN: AAACI1314G\nAppellant)\n\nDCIT-2(3)(1),\n5th Floor, Room No. 552,\nVs. Aayakar Bhavan, M.K. Road,\nMumbai-400020.\nRespondent)\n\nI.T.A. No. 3775/Mum/2023\n(Assessment Year: 2018-19)\n\nI.T.A. No. 3774/Mum/2023\n(Assessment Year: 2019-20)\n\nDCIT-2(3)(1),\n552, Aay…

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

ITA 111/MUM/2016[2011-12]Status: DisposedITAT Mumbai01 Jul 2025AY 2011-12
Section 115Section 14ASection 250

…ount of remuneration to the employees would be\nonly the amount of actual discounted premium at the time of exercise of option.\nThe Hon'ble Supreme Court in the case of CIT vs. Infosys Technologies Ltd.\n(2008) 214 CTR (SC) 293: (2008) 1 DTR (SC) 330: (2008) 297 ITR 167 (SC)\nrelevant to the asst. yrs.1997-98 to 1999-2000 has held that the allotment of\nshares to employees under ESOP subject to a lock in period of five years and\nother conditions could not be treated as a perquisite as there was no benefit and\nthe value of benefit, if any, was unascertainable at the time when options were\nexercised. The Financ…

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 110/MUM/2016[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

…amount of remuneration to the employees would be only the amount of actual discounted premium at the time of exercise of option. The Hon'ble Supreme Court in the case of CIT vs. Infosys Technologies Ltd. (2008) 214 CTR (SC) 293: (2008) 1 DTR (SC) 330: (2008) 297 ITR 167 (SC) relevant to the asst. yrs. 1997-98 to 1999-2000 has held that the allotment of shares to employees under ESOP subject to a lock in period of five years and other conditions could not be treated as a perquisite as there was no benefit and the value of benefit, if any, was unascertainable at the time when options were exercised. The Finance Ac…

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned\nissue back to the AO with similar directions. The grounds raised by the assessee in\nthis regard are allowed for statistical purposes

ITA 5750/MUM/2015[2011-12]Status: DisposedITAT Mumbai01 Jul 2025AY 2011-12
Section 115Section 14ASection 250

…ount of remuneration to the employees would be\nonly the amount of actual discounted premium at the time of exercise of option.\nThe Hon'ble Supreme Court in the case of CIT vs. Infosys Technologies Ltd.\n(2008) 214 CTR (SC) 293: (2008) 1 DTR (SC) 330: (2008) 297 ITR 167 (SC)\nrelevant to the asst. yrs.1997-98 to 1999-2000 has held that the allotment of\nshares to employees under ESOP subject to a lock in period of five years and\nother conditions could not be treated as a perquisite as there was no benefit and\nthe value of benefit, if any, was unascertainable at the time when options were\nexercised. The Financ…

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 5749/MUM/2015[2010-11]Status: DisposedITAT Mumbai01 Jul 2025AY 2010-11

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

…amount of remuneration to the employees would be only the amount of actual discounted premium at the time of exercise of option. The Hon'ble Supreme Court in the case of CIT vs. Infosys Technologies Ltd. (2008) 214 CTR (SC) 293: (2008) 1 DTR (SC) 330: (2008) 297 ITR 167 (SC) relevant to the asst. yrs. 1997-98 to 1999-2000 has held that the allotment of shares to employees under ESOP subject to a lock in period of five years and other conditions could not be treated as a perquisite as there was no benefit and the value of benefit, if any, was unascertainable at the time when options were exercised. The Finance Ac…

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

ITA 4172/MUM/2013[2009-10]Status: DisposedITAT Mumbai01 Jul 2025AY 2009-10

Bench: Hon’Ble Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Rakesh Ranjan-CIT-DR &
Section 115Section 14ASection 250

…amount of remuneration to the employees would be only the amount of actual discounted premium at the time of exercise of option. The Hon'ble Supreme Court in the case of CIT vs. Infosys Technologies Ltd. (2008) 214 CTR (SC) 293: (2008) 1 DTR (SC) 330: (2008) 297 ITR 167 (SC) relevant to the asst. yrs. 1997-98 to 1999-2000 has held that the allotment of shares to employees under ESOP subject to a lock in period of five years and other conditions could not be treated as a perquisite as there was no benefit and the value of benefit, if any, was unascertainable at the time when options were exercised. The Finance Ac…

DCIT, CIRCLE-1(1), HYDERABAD, HYDERABAD vs. PRAKASH NIMMAGADDA, HYDERABAD, SECUNDERABAD

In the result, appeal filed by the Revenue is dismissed

ITA 974/HYD/2017[2008-09]Status: DisposedITAT Hyderabad16 Dec 2024AY 2008-09

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita No.974/Hyd/2017 (िनधा"रण वष"/Assessment Year: 2008-09) Dy.Cit Vs. Shri Prakash Nimmagadda Circle 1(1) Hyderabad Hyderabad Pan:Acbpn4246R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri K.C. Devdas, Ca राज" व "ारा/Revenue By:: Dr. Meghnath Chowhan, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 06/11/2024 घोषणा की तारीख/Pronouncement: 16/12/2024 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Revenue Is Directed Against The Order, Dated 20/03/2017 Of The Learned Cit (A)-9, Hyderabad, Relating To A.Y.2008-09. 2. The Revenue Has Raised The Following Grounds:

For Appellant: Shri K.C. Devdas, CAFor Respondent: : Dr. Meghnath Chowhan, CIT(DR)
Section 17(2)(c)Section 28

…9, which defines cost. In the absence of such provisions, the value of the benefit in the form of shares allotted at face value, cannot be ascertained and taxed. In this regard the decision of the Supreme Court in the case of CIT Vs. Infosys Technologies Ltd (297 ITR 167) has been duly considered. 9.6 It is a vital aspect in tax jurisprudence that in a taxing Act one has to look at what is clearly said. There is no room any intendment. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used. It is a constitutional mandate that no tax c…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -1(1)(1), BENGALURU, BENGALURU vs. ALGONOMY SOFTWARE PRIVATE LIMITED, BENGALURU

In the result, the appeals filed by the Revenue for AY 2016-17 to 2018-

ITA 1229/BANG/2024[2018-19]Status: DisposedITAT Bangalore15 Oct 2024AY 2018-19

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri R.N. Siddappaji, CIT-DR
Section 133ASection 14Section 195Section 37Section 40Section 9(1)(vii)

…ount.” The Ld.DR relied upon the order passed by the authorities below. 15. We also find that in the case of CIT, LTU vs. Biocon Ltd. (supra), the revenue relied upon the judgment in case of CIT vs. Infosys Technologies Ltd. reported in (2008) 166 Taxman 204/297 ITR 167 which has also been taken care by the Jurisdictional High Court and distinguished to this effect that the question raised therein i.e. the ESOP benefit was not in the provision of law at that material point of time rather the same was inserted by the Finance Act, 1999 w.e.f. 01.04.2000 and not applicable to the case of CIT, LTU vs. Biocon Ltd. (s…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(1), BENGALURU, BENGALURU vs. ALGONOMY SOFTWARE PRIVATE LIMITED, BENGALURU

In the result, the appeals filed by the Revenue for AY 2016-17 to 2018-

ITA 1226/BANG/2024[2017-18]Status: DisposedITAT Bangalore15 Oct 2024AY 2017-18

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri R.N. Siddappaji, CIT-DR
Section 133ASection 14Section 195Section 37Section 40Section 9(1)(vii)

…ount.” The Ld.DR relied upon the order passed by the authorities below. 15. We also find that in the case of CIT, LTU vs. Biocon Ltd. (supra), the revenue relied upon the judgment in case of CIT vs. Infosys Technologies Ltd. reported in (2008) 166 Taxman 204/297 ITR 167 which has also been taken care by the Jurisdictional High Court and distinguished to this effect that the question raised therein i.e. the ESOP benefit was not in the provision of law at that material point of time rather the same was inserted by the Finance Act, 1999 w.e.f. 01.04.2000 and not applicable to the case of CIT, LTU vs. Biocon Ltd. (s…

DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE-1(1)(1), BANGALORE., BENGALURU vs. ALGONOMY SOFTWARE PRIVATE LIMITED, BENGALURU

In the result, the appeals filed by the Revenue for AY 2016-17 to 2018-

ITA 1196/BANG/2024[2016-17]Status: DisposedITAT Bangalore15 Oct 2024AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S.

For Appellant: Shri Narendra Kumar Jain, AdvocateFor Respondent: Shri R.N. Siddappaji, CIT-DR
Section 133ASection 14Section 195Section 37Section 40Section 9(1)(vii)

…ount.” The Ld.DR relied upon the order passed by the authorities below. 15. We also find that in the case of CIT, LTU vs. Biocon Ltd. (supra), the revenue relied upon the judgment in case of CIT vs. Infosys Technologies Ltd. reported in (2008) 166 Taxman 204/297 ITR 167 which has also been taken care by the Jurisdictional High Court and distinguished to this effect that the question raised therein i.e. the ESOP benefit was not in the provision of law at that material point of time rather the same was inserted by the Finance Act, 1999 w.e.f. 01.04.2000 and not applicable to the case of CIT, LTU vs. Biocon Ltd. (s…

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

ITA 946/BANG/2023[2015-16]Status: DisposedITAT Bangalore19 Jan 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Respondent: Ms. Neera Malhotra, CIT-DR
Section 143(3)Section 147Section 148Section 40

…unt.” The Ld.DR relied upon the order passed by the authorities below. 15. We also find that in the case of CIT, LTU vs. Biocon Ltd. (supra), the revenue relied upon the judgment in case of CIT vs. Infosys Technologies Ltd. reported in (2008) 166 Taxman 204/297 ITR 167 which has also been taken care by the Jurisdictional High Court and distinguished to this effect that the question raised therein i.e. the ESOP benefit was not in the provision of law at that material point of time rather the same was inserted by the Finance Act, 1999 w.e.f. 01.04.2000 and Page 23 ITA Nos. 943 to 946/Bang/2023 & C.O. Nos. 14 to 1…

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

ITA 945/BANG/2023[2014-15]Status: DisposedITAT Bangalore19 Jan 2024AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Respondent: Ms. Neera Malhotra, CIT-DR
Section 143(3)Section 147Section 148Section 40

…unt.” The Ld.DR relied upon the order passed by the authorities below. 15. We also find that in the case of CIT, LTU vs. Biocon Ltd. (supra), the revenue relied upon the judgment in case of CIT vs. Infosys Technologies Ltd. reported in (2008) 166 Taxman 204/297 ITR 167 which has also been taken care by the Jurisdictional High Court and distinguished to this effect that the question raised therein i.e. the ESOP benefit was not in the provision of law at that material point of time rather the same was inserted by the Finance Act, 1999 w.e.f. 01.04.2000 and Page 23 ITA Nos. 943 to 946/Bang/2023 & C.O. Nos. 14 to 1…

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. ALGONOMY SOFTWARE PRIVATE LIMITED (FORMERLY KNOWN AS MANTHAN SOFTWARE SERVICES PVT LTD), BANGALORE

In the result, all the appeals filed by the revenue stands dismissed and the cross objections being C

ITA 944/BANG/2023[2013-14]Status: DisposedITAT Bangalore19 Jan 2024AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Ms. Madhumita Roy

For Respondent: Ms. Neera Malhotra, CIT-DR
Section 143(3)Section 147Section 148Section 40

…unt.” The Ld.DR relied upon the order passed by the authorities below. 15. We also find that in the case of CIT, LTU vs. Biocon Ltd. (supra), the revenue relied upon the judgment in case of CIT vs. Infosys Technologies Ltd. reported in (2008) 166 Taxman 204/297 ITR 167 which has also been taken care by the Jurisdictional High Court and distinguished to this effect that the question raised therein i.e. the ESOP benefit was not in the provision of law at that material point of time rather the same was inserted by the Finance Act, 1999 w.e.f. 01.04.2000 and Page 23 ITA Nos. 943 to 946/Bang/2023 & C.O. Nos. 14 to 1…

GE INDIA INDUSTRIAL PVT. LTD. (FORMERLY KNOWN AS GE INDIA EXPORTS P.LTD),NEW DELHI vs. JCIT, SPECIAL RANGE-4, NEW DELHI

In the result, we do not find any merit in this appeal, the same fails and is hereby dismissed

ITA 9031/DEL/2019[2015-16]Status: DisposedITAT Delhi21 Nov 2023AY 2015-16

Bench: Shri Challa Nagendra Prasada N D Shri M. Balaganesh

For Appellant: Shri Sachit Jolly, Adv. &
Section 143(3)Section 144C(5)Section 2Section 37Section 37(1)

…has been prepared in accordance with Securities and Exchange Board of India (Employee Stock Option Scheme and Employee Stock Purchase Scheme) Guidelines, 1999. 12 So far as reliance placed by the Revenue in the case of CIT v. Infosys Technologies Ltd. [2008] 297 ITR 167 (SC) is concerned, it is noteworthy that in the aforesaid decision, the Supreme Court was dealing with a pro- ceeding under section 201 of the Act for non-deduction of tax at source and it was held that there was no cash inflow to the employees. The afore- said decision is of no assistance to decide the issue of allowability of expenses in the ha…

MANESSH SHARMA,JABALPUR vs. JOINT COMMISSIONER OF INCOME TAX OFFICER (TDS) BHOPAL, BHOPAL

In the result, all appeals filed by the assessee are allowed

ITA 99/JAB/2023[2010-11]Status: DisposedITAT Jabalpur22 Sept 2023AY 2010-11

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 201(1)Section 250Section 271Section 271C

…ithout specifying to which quarter it pertains makes the charge vague. In this respect, the following judgment is relevant: 7 | P a g e ITA No.99 to 103/Jab/2023 Manessh Sharma vs JCIT-TDS In the case of CIT Bangalore Vs. Infosys Technologies Limited (2008) 297 ITR 167/214 CTR293/166 Taxman 204 the Hon'ble Supreme Court in para 6 of the said judgment cited the following:- 6. In the case of Govind Saran Ganga Saran Vs. CST[1985] 155 ITR 144 this Court held that there are four components of tax. The first component is the character of the imposition, the second is the person on whom the levy is imposed, the third…

MANESSH SHARMA ,JABALPUR vs. JOINT COMMISSIONER OF INCOME OFFICER (TDS), BHOPAL

In the result, all appeals filed by the assessee are allowed

ITA 103/JAB/2023[2014-15]Status: DisposedITAT Jabalpur22 Sept 2023AY 2014-15

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 201(1)Section 250Section 271Section 271C

…ithout specifying to which quarter it pertains makes the charge vague. In this respect, the following judgment is relevant: 7 | P a g e ITA No.99 to 103/Jab/2023 Manessh Sharma vs JCIT-TDS In the case of CIT Bangalore Vs. Infosys Technologies Limited (2008) 297 ITR 167/214 CTR293/166 Taxman 204 the Hon'ble Supreme Court in para 6 of the said judgment cited the following:- 6. In the case of Govind Saran Ganga Saran Vs. CST[1985] 155 ITR 144 this Court held that there are four components of tax. The first component is the character of the imposition, the second is the person on whom the levy is imposed, the third…

MANESSH SHARMA,JABALPUR vs. JOINT COMMISSIONER OF INCOME OFFICER (TDS), BHOPAL

In the result, all appeals filed by the assessee are allowed

ITA 102/JAB/2023[2013-14]Status: DisposedITAT Jabalpur22 Sept 2023AY 2013-14

Bench: Shri Om Prakash Kantshri Pavan Kumar Gadale

Section 201(1)Section 250Section 271Section 271C

…ithout specifying to which quarter it pertains makes the charge vague. In this respect, the following judgment is relevant: 7 | P a g e ITA No.99 to 103/Jab/2023 Manessh Sharma vs JCIT-TDS In the case of CIT Bangalore Vs. Infosys Technologies Limited (2008) 297 ITR 167/214 CTR293/166 Taxman 204 the Hon'ble Supreme Court in para 6 of the said judgment cited the following:- 6. In the case of Govind Saran Ganga Saran Vs. CST[1985] 155 ITR 144 this Court held that there are four components of tax. The first component is the character of the imposition, the second is the person on whom the levy is imposed, the third…

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