CIT v. Samsung Electronics Ltd.

345 ITR 494High Court2012#153 most cited

What is CIT v. Samsung Electronics Ltd. authority for?

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

461

judgments rely on this decision, according to BharatTax’s citation analysis of 367,154 Indian tax judgments — from 2012 to 2026.

Also referred to as

CIT v. Samsung Electronics Ltd. · section 9(1)(v) · section 9(1)(vi) · section 195 · computer software royalty · non-resident payments · deemed income India · tax deduction at source · foreign software suppliers · royalty income · software licensing

Sections most often in play

Section 9(1)(vi)Section 195Section 9(1)(vii)Section 40(a)(i)Section 13(4)Section 13(3)(a)Section 13(4)(c)Section 144C(5)
Read the full judgment

Issues it is cited on

section 9(1)(vi)computer softwaresection 9(1)section 195fees for technical servicespermanent establishmentsection 30non-residentdouble taxationsection 19transferperson

Judgments citing CIT v. Samsung Electronics Ltd.

Kennametal Inc, Bangalore vs. Assistant Commissioner of Income Tax (International Taxation), Circle-1(2), Bangalore

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13

ITA 35/BANG/2021[2017-18]Status: DisposedITAT Bangalore16 Feb 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranit(It)A No.35/Bang/2021 Assessment Year :2017-18 M/S. Kennametal Inc., Vs. Acit (International Taxation), C/O. Kennametal India, Circle – 1(2), 8/9Th Mile, Tumkur Road, Bengaluru. Bengaluru – 560 073. Pan: Aacck 6397 B Assessee Respondent Assessee By : Shri. K. R. Vasudevan, Advocate Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 14.02.2022 Date Of Pronouncement : 16.02.2022 O R D E R Per N. V. Vasudevan:

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B. R. BASKARAN, ACCOUNTANT MEMBER IT(IT)A No.35/Bang/2021 Assessment Year :2017-18 M/s. Kennametal Inc., Vs. ACIT (International Taxation), C/o. Kennametal India, Circle – 1(2), 8/9th Mile, Tumkur Road, Bengaluru. Bengaluru – 560 073. PAN: AACCK 6397 B ASSESSEE RESPONDENT Assessee by : Shri. K. R. Vasudevan, Advocate Revenue by : Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru. Date of hearing : 14.02.2022 Date of Pronouncement : 16.02.2022 O R D E R Per N. V. Vasudevan, Vice President : This is an ap…

M/S Nds Limited, Bangalore vs. Deputy Commissioner of Income Tax International Taxation Circle-1(2), Bangalore

In the result, assessee’s appeal is partly allowed

ITA 3350/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Feb 2022AY 2014-15

Bench: Shri George George K & Ms. Padmavathy Sassessment Year : 2014-15

For Appellant: Shri Sharath Rao, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT(DR)
Section 133(6)Section 143(2)Section 143(3)Section 234ASection 234B

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K, JUDICIAL MEMBER AND MS. PADMAVATHY S, ACCOUNTANT MEMBER Assessment year : 2014-15 Synamedia Limited [formerly known Vs. The Dy. Commissioner of Income- as NDS Limited] tax (Intl. Taxation), Block 9A & 9B, Pritech Park, Circle-1(2), Bengaluru. Survey No.51-64/4, Sarjapur Outer Ring Road, Bellandur Village, Bengaluru-560 103. PAN –AABCN 2524 L APPELLANT RESPONDENT Assessee by : Shri Sharath Rao, Advocate Revenue by : Shri Muzaffar Hussain, CIT(DR) Date of hearing : 09.02.2022 Date of Pronouncement : 14.02.2022 O R D E R Pe…

DCIT, Circle- 3(1)(2), Intl. Taxation, New Delhi vs. Siemens Product Lifecycle Management Software Inc., Gurgaon

In the result, the appeal of the Revenue is dismissed

ITA 3413/DEL/2018[2013-14]Status: DisposedITAT Delhi08 Feb 2022AY 2013-14

Bench: Shri G.S. Pannu, Hon’Ble & Shri C.N. Prasadasstt. Year: 2013-14

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Munesh Kumar, CIT DR
Section 143(3)Section 144C(3)(b)Section 9

…th under the Act as well as the India-USA DTAA. The AO followed the order of his predecessor for earlier years in assessee’s own case and relied upon the judgement of the Hon’ble Karnataka High Court in the case of CIT vs. Samsung Electronics Co. Ltd. [(2012) 345 ITR 494 (KAR)] and several other cases to decide the matter against the assessee. 4. On appeal, the Ld. CIT(A) following his predecessor’s order pertaining to AY 2011-12 and 2012-13 concluded that the payments made to the assessee from the supply of software to Indian end users is for a copyrighted article and cannot be considered as royalty payments. T…

Nagravision Sa, Gurgaon vs. DCIT Circle-2(2)(2) Internatioanl Taxation, New Delhi

In the result the Appeal filed by the Appellant is partly allowed for statistical purposes

ITA 140/DEL/2021[2017-18]Status: DisposedITAT Delhi31 Jan 2022AY 2017-18

Bench: Sh. R.K. Panda & Sh. N. K. Choudhry(Through Video Conferencing) Assessment Year: 2017-18 M/S. Nagravision S.A. Vs Dcit C/O. Ernst & Young Llp, Circle-2(2)(2), Golf View Corporate International Taxation, Tower,Tower B, Sector 42, New Delhi Golf Course Road, Gurugram Pan : Aadcn6048B (Appellant) (Respondent) Appellant By Smt. Ananya Kapoor, Adv. Respondent By Ms. Naina Soin Kapil, Cit Date Of Hearing: 06/01/2022 Date Of Pronouncement: 31/01/2022 Order Per N. K. Choudhry, Jm:

Section 143(3)Section 144CSection 154Section 270Section 270ASection 9

…re for ExcellencePrivateLimitedVsCommissioner of IncomeTax&Another (Supra) are reproduced asunder: “ 3. One group of appeals arises from a common judgment of the High Court of Karnataka dated 15.10.2011 reported as CIT v. Samsung Electronics Co. Ltd., (2012) 345 ITR 494, by which the question which was posed before the High Court, was answered stating that the amounts paid by the concerned persons resident in India to non-resident, foreign software suppliers, amounted to royalty and as this was so, the same constituted taxable income deemed to accrue in India under section 9(1)(vi) of the Income Tax Act, 1961 [“…

M/S.Nds Limited, Bangalore vs. Asst. Commissioner of Income Tax, Bangalore

In the result, the appeal filed by assessee stands allowed

ITA 364/BANG/2017[2007-2008]Status: DisposedITAT Bangalore28 Dec 2021AY 2007-2008

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(It)A No. 364/Bang/2017 Assessment Year : 2007-08 M/S. Synamedia Ltd. [Formerly Known As ‘Nds Limited’], The Assistant C/O. M/S. Synamedia India Pvt. Commissioner Of Ltd., Income Tax, Block 9A & 9B, Pritech Park, International Survey No. 51-64/4, Taxation, Sarjapur Outer Ring Road, Vs. Circle – 1(2), Bellandur Village, Bangalore. Bangalore – 560 103. Pan: Aabcn2524L Appellant Respondent Assessee By : Shri Sharath Rao, Advocate : Shri Dilip, Standing Revenue By Counsel For Dept. Date Of Hearing : 16-12-2021 Date Of Pronouncement : 28-12-2021

For Appellant: Shri
Section 143(3)Section 147Section 234B

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI. B.R. BASKARAN, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(IT)A No. 364/Bang/2017 Assessment Year : 2007-08 M/s. Synamedia Ltd. [formerly known as ‘NDS Limited’], The Assistant C/o. M/s. Synamedia India Pvt. Commissioner of Ltd., Income Tax, Block 9A & 9B, Pritech Park, International Survey No. 51-64/4, Taxation, Sarjapur Outer Ring Road, Vs. Circle – 1(2), Bellandur Village, Bangalore. Bangalore – 560 103. PAN: AABCN2524L APPELLANT RESPONDENT Assessee by : Shri Sharath Rao, Advocate : Shri Dilip, Standing Revenue by Counsel f…

Mountain Trail Foods Private Limited, Bangalore vs. Principal Commissioner of Income Tax, Bengaluru-4, Bengaluru

In the result, all the miscellaneous applications are allowed and all the appeals filed by the assessee are treated as allowed for statistical purposes

ITA 99/BANG/2021[2015-16]Status: HeardITAT Bangalore13 Dec 2021AY 2015-16

Bench: Shri B.R Baskaran & Shri Beena Pillai

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Smt. Priyadarshini Besaganni, JCIT (DR)
Section 248

…IN THE INCOME TAX APPELLATE TRIBUNAL “C’’ BENCH : BANGALORE BEFORE SHRI B.R BASKARAN, ACCOUNTANT MEMBER AND SHRI BEENA PILLAI, JUDICIAL MEMBER Sl. M.P No. A.Y No. 1 99/Bang/2021 2016-17 (In 1971/Bang/2019) 2 100 to 111/Bang/2021 2017-18 (In 1972 to 1983/Bang/2019) 3 112 to 122/Bang/2021 2018-19 (In 1984 to 1994/Bang/2019) 4 123 to 132/Bang/2021 2019-20 (In 1995 to 2004/Bang/2019) Sl. IT(ITA) No. A.Y No. 1 1971/Bang/2019 2016-17 2 1972 to 1983/Bang/2019 2017-18 3 1984 to 1994/Bang/2019 2018-19 4 2019-20 1995 to 2004/Bang/2019 M/s Edgeverve Systems Ltd., Vs. The Asst. Commissioner of Income-tax 44/97A Konappa…

Kennametal Inc., Bangalore vs. Joint Commissioner of Income Tax (OSD) (Int. Taxn), Circle-1(2), Bengaluru

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13 is treated as partly allowed for statistical purposes

ITA 806/BANG/2019[2013-14]Status: DisposedITAT Bangalore09 Dec 2021AY 2013-14

Bench: Shri N.V. Vasudevan, Vice- & Shri Chandra Poojari

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

…us. We find the issue to be decided in the grounds raised by the assessee is in relation to taxability of payment in question in India in the hands of the recipient. The decision of Hon'ble Karnataka High Court in the case of CIT vs. Samsung Electronics Ltd. 345 ITR 494 on the basis of which the revenue authorities concluded that the payment in question is in the nature of royalty, now stand overruled by the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. (2021) 125 Taxmann.com 42 (SC). The Hon’ble Supreme Court in the case of Engineering Analysis Centre of…

M/S. Kennametal Inc., Bangalore vs. Income Tax Officer, (Intl. Taxn), Ward - 1(2), Bangalore

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13 is treated as partly allowed for statistical purposes

ITA 805/BANG/2019[2012-13]Status: DisposedITAT Bangalore09 Dec 2021AY 2012-13

Bench: Shri N.V. Vasudevan, Vice- & Shri Chandra Poojari

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

…us. We find the issue to be decided in the grounds raised by the assessee is in relation to taxability of payment in question in India in the hands of the recipient. The decision of Hon'ble Karnataka High Court in the case of CIT vs. Samsung Electronics Ltd. 345 ITR 494 on the basis of which the revenue authorities concluded that the payment in question is in the nature of royalty, now stand overruled by the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. (2021) 125 Taxmann.com 42 (SC). The Hon’ble Supreme Court in the case of Engineering Analysis Centre of…

M/S Kennametal Inc, Bangalore vs. Income Tax Officer (International Taxation) Ward-1(2), Bangalore

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13 is treated as partly allowed for statistical purposes

ITA 804/BANG/2019[2011-12]Status: DisposedITAT Bangalore09 Dec 2021AY 2011-12

Bench: Shri N.V. Vasudevan, Vice- & Shri Chandra Poojari

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

…us. We find the issue to be decided in the grounds raised by the assessee is in relation to taxability of payment in question in India in the hands of the recipient. The decision of Hon'ble Karnataka High Court in the case of CIT vs. Samsung Electronics Ltd. 345 ITR 494 on the basis of which the revenue authorities concluded that the payment in question is in the nature of royalty, now stand overruled by the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. (2021) 125 Taxmann.com 42 (SC). The Hon’ble Supreme Court in the case of Engineering Analysis Centre of…

M/S Kennametal Inc, Bangalore vs. Income Tax Officer (International Taxation) Ward-1(2), Bangalore

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13 is treated as partly allowed for statistical purposes

ITA 803/BANG/2019[2010-11]Status: DisposedITAT Bangalore09 Dec 2021AY 2010-11

Bench: Shri N.V. Vasudevan, Vice- & Shri Chandra Poojari

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

…us. We find the issue to be decided in the grounds raised by the assessee is in relation to taxability of payment in question in India in the hands of the recipient. The decision of Hon'ble Karnataka High Court in the case of CIT vs. Samsung Electronics Ltd. 345 ITR 494 on the basis of which the revenue authorities concluded that the payment in question is in the nature of royalty, now stand overruled by the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. (2021) 125 Taxmann.com 42 (SC). The Hon’ble Supreme Court in the case of Engineering Analysis Centre of…

M/S Kennametal Inc, Bangalore vs. Deputy Director of Income Tax ( International Taxation) Circle-1(1), Bangalore

In the result, the appeal for AY 2014-15 is treated as allowed for statistical purpose while the appeal for AY 2012-13 is treated as partly allowed for statistical purposes

ITA 802/BANG/2019[2009-10]Status: DisposedITAT Bangalore09 Dec 2021AY 2009-10

Bench: Shri N.V. Vasudevan, Vice- & Shri Chandra Poojari

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

…us. We find the issue to be decided in the grounds raised by the assessee is in relation to taxability of payment in question in India in the hands of the recipient. The decision of Hon'ble Karnataka High Court in the case of CIT vs. Samsung Electronics Ltd. 345 ITR 494 on the basis of which the revenue authorities concluded that the payment in question is in the nature of royalty, now stand overruled by the decision of the Hon’ble Supreme Court in the case of Engineering Analysis Centre of Excellence (P) Ltd. (2021) 125 Taxmann.com 42 (SC). The Hon’ble Supreme Court in the case of Engineering Analysis Centre of…

J and P Coats Limited, Bangaluru vs. Deputy Commissioner of Income Tax (International Taxation), Circle 1(2), Bangalore

In the result, the appeals are allowed

ITA 1367/BANG/2019[2015-16]Status: DisposedITAT Bangalore29 Nov 2021AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri K. V. Arvind, Standing Counsel for Department
Section 143(3)Section 144C(13)

…ped software, which the Assessee purchased from software vendors and sold to the Assessee. The taxed the aforesaid receipt treating it as royalty by following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Samsung Electronics Co. Ltd. 345 ITR 494 (Karn.). It was the plea of the Assessee before DRP that there was no transfer of right in respect of the copyright by the software vendors to the Assessee. There was no commercial exploitation of the copyright of the software vis-à-vis third parties. The Assessee had a right to use the software only within its own business, as end-user software.…

J and P Coats Limited, Bengaluru vs. Deputy Commissioner of Income Tax (International Taxation), Circle 1(2), Bangalore

In the result, the appeals are allowed

ITA 1366/BANG/2019[2014-15]Status: DisposedITAT Bangalore29 Nov 2021AY 2014-15

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri K. V. Arvind, Standing Counsel for Department
Section 143(3)Section 144C(13)

…ped software, which the Assessee purchased from software vendors and sold to the Assessee. The taxed the aforesaid receipt treating it as royalty by following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Samsung Electronics Co. Ltd. 345 ITR 494 (Karn.). It was the plea of the Assessee before DRP that there was no transfer of right in respect of the copyright by the software vendors to the Assessee. There was no commercial exploitation of the copyright of the software vis-à-vis third parties. The Assessee had a right to use the software only within its own business, as end-user software.…

J and P Coats Limited, Bengaluru vs. Deputy Commissioner of Income Tax (International Taxation), Circle 1(1), Bangalore

In the result, the appeals are allowed

ITA 1365/BANG/2019[2013-14]Status: DisposedITAT Bangalore29 Nov 2021AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri K. V. Arvind, Standing Counsel for Department
Section 143(3)Section 144C(13)

…ped software, which the Assessee purchased from software vendors and sold to the Assessee. The taxed the aforesaid receipt treating it as royalty by following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Samsung Electronics Co. Ltd. 345 ITR 494 (Karn.). It was the plea of the Assessee before DRP that there was no transfer of right in respect of the copyright by the software vendors to the Assessee. There was no commercial exploitation of the copyright of the software vis-à-vis third parties. The Assessee had a right to use the software only within its own business, as end-user software.…

J & P Coats Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, the appeals are allowed

ITA 2135/BANG/2016[2012-13]Status: DisposedITAT Bangalore29 Nov 2021AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri K. V. Arvind, Standing Counsel for Department
Section 143(3)Section 144C(13)

…ped software, which the Assessee purchased from software vendors and sold to the Assessee. The taxed the aforesaid receipt treating it as royalty by following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Samsung Electronics Co. Ltd. 345 ITR 494 (Karn.). It was the plea of the Assessee before DRP that there was no transfer of right in respect of the copyright by the software vendors to the Assessee. There was no commercial exploitation of the copyright of the software vis-à-vis third parties. The Assessee had a right to use the software only within its own business, as end-user software.…

J & P Coats Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeals are allowed

ITA 382/BANG/2015[2010-11]Status: DisposedITAT Bangalore29 Nov 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri K. V. Arvind, Standing Counsel for Department
Section 143(3)Section 144C(13)

…ped software, which the Assessee purchased from software vendors and sold to the Assessee. The taxed the aforesaid receipt treating it as royalty by following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Samsung Electronics Co. Ltd. 345 ITR 494 (Karn.). It was the plea of the Assessee before DRP that there was no transfer of right in respect of the copyright by the software vendors to the Assessee. There was no commercial exploitation of the copyright of the software vis-à-vis third parties. The Assessee had a right to use the software only within its own business, as end-user software.…

J & P Coats Limited, U.K vs. DCIT, Bangalore

In the result, the appeals are allowed

ITA 1493/BANG/2015[2011-12]Status: DisposedITAT Bangalore29 Nov 2021AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri Ajay Rotti, CAFor Respondent: Shri K. V. Arvind, Standing Counsel for Department
Section 143(3)Section 144C(13)

…ped software, which the Assessee purchased from software vendors and sold to the Assessee. The taxed the aforesaid receipt treating it as royalty by following the decision of the Hon’ble Karnataka High Court in the case of CIT Vs. Samsung Electronics Co. Ltd. 345 ITR 494 (Karn.). It was the plea of the Assessee before DRP that there was no transfer of right in respect of the copyright by the software vendors to the Assessee. There was no commercial exploitation of the copyright of the software vis-à-vis third parties. The Assessee had a right to use the software only within its own business, as end-user software.…

M/S Infosys Bpm Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-3, Bangalore

In the result, the appeal of the assessee is treated as partly allowed

ITA 2884/BANG/2018[2009-10]Status: DisposedITAT Bangalore22 Nov 2021AY 2009-10

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year:2009-10

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Shri Sumer Singh, D.R
Section 10ASection 115JSection 143(3)Section 14ASection 40

…of section 40(a)(i) of the Act for the year under consideration. He submitted that the financial year under consideration is 1.4.2010 to 31.3.2011. The Hon'ble Jurisdictional Karnataka High Court has held in the case of Samsung Electronics Company Ltd. (2012) 345 ITR 494 that the payment made for obtaining software licenses are in the nature of royalty and hence it is liable for deduction of tax at source. However the above said decision came to be rendered on 15.10.2011. Prior to that, there were certain Tribunal decisions holding that the payment made for purchase of software licenses are not in the nature of r…

Nds Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-1(2) International Taxation, Bangalore

In the result, all these appeals are partly allowed

ITA 505/BANG/2017[2013-14]Status: DisposedITAT Bangalore12 Nov 2021AY 2013-14

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranit(It)A Nos. & Appellant Respondent Assessment Year 363/Bang/2017 M/S. Synamedia Limited The Assistant Commissioner Of 2006-07 (Formerly Known As ‘Nds Limited), Income Tax (International Taxation), C/O M/S. Synamedia India Private Circle -1(2), Limited, Bengaluru. Block 9A & 9B, Pritech Park, Survey No.51-64/4, Sarjapur Outer Ring Road, Bellandur Village, Bengaluru – 560 103. Pan : Aabcn 2524 L 504/Bang/2017 -Do- -Do- 2012-13 505/Bang/2017 -Do- -Do- 2013-14 255/Bang/2014 -Do- The Assistant Director Of Income 2010-11 Tax, (International Taxation), Circle – 1(1) [Now Assistant Commissioner Of Income Tax (International Taxation), Circle – 1(2), Bengaluru. Appellant By : Shri Sharath Rao, Advocate Respondent By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 01.11.2021 Date Of Pronouncement : 12.11.2021

For Appellant: Shri Sharath Rao, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B. R. BASKARAN, ACCOUNTANT MEMBER IT(IT)A Nos. and Appellant Respondent Assessment Year 363/Bang/2017 M/s. Synamedia Limited The Assistant Commissioner of 2006-07 (formerly known as ‘NDS Limited), Income Tax (International Taxation), C/o M/s. Synamedia India Private Circle -1(2), Limited, Bengaluru. Block 9A and 9B, Pritech Park, Survey No.51-64/4, Sarjapur Outer Ring Road, Bellandur Village, Bengaluru – 560 103. PAN : AABCN 2524 L 504/Bang/2017 -do- -do- 2012-13 505/Bang/2017 -do- -do- 2013-14 255/Bang/…

Nds Limited, Bangalore vs. Assistant Commissioner of Income Tax Circle-1(2) International Taxation, Bangalore

In the result, all these appeals are partly allowed

ITA 504/BANG/2017[2012-13]Status: DisposedITAT Bangalore12 Nov 2021AY 2012-13

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranit(It)A Nos. & Appellant Respondent Assessment Year 363/Bang/2017 M/S. Synamedia Limited The Assistant Commissioner Of 2006-07 (Formerly Known As ‘Nds Limited), Income Tax (International Taxation), C/O M/S. Synamedia India Private Circle -1(2), Limited, Bengaluru. Block 9A & 9B, Pritech Park, Survey No.51-64/4, Sarjapur Outer Ring Road, Bellandur Village, Bengaluru – 560 103. Pan : Aabcn 2524 L 504/Bang/2017 -Do- -Do- 2012-13 505/Bang/2017 -Do- -Do- 2013-14 255/Bang/2014 -Do- The Assistant Director Of Income 2010-11 Tax, (International Taxation), Circle – 1(1) [Now Assistant Commissioner Of Income Tax (International Taxation), Circle – 1(2), Bengaluru. Appellant By : Shri Sharath Rao, Advocate Respondent By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 01.11.2021 Date Of Pronouncement : 12.11.2021

For Appellant: Shri Sharath Rao, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 9(1)(vi)

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B. R. BASKARAN, ACCOUNTANT MEMBER IT(IT)A Nos. and Appellant Respondent Assessment Year 363/Bang/2017 M/s. Synamedia Limited The Assistant Commissioner of 2006-07 (formerly known as ‘NDS Limited), Income Tax (International Taxation), C/o M/s. Synamedia India Private Circle -1(2), Limited, Bengaluru. Block 9A and 9B, Pritech Park, Survey No.51-64/4, Sarjapur Outer Ring Road, Bellandur Village, Bengaluru – 560 103. PAN : AABCN 2524 L 504/Bang/2017 -do- -do- 2012-13 505/Bang/2017 -do- -do- 2013-14 255/Bang/…