CIT v. Yokogawa India Ltd.

391 ITR 274Supreme Court of India2017#271 most cited

What is CIT v. Yokogawa India Ltd. authority for?

Deduction under Section 10A or 10AA of the Income-tax Act is computed on the profits of the eligible unit without first setting off losses from other units or non-eligible units. Conversely, losses incurred by an eligible unit are allowed to be set off against the assessee's other taxable business profits.

290

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. Yokogawa India Ltd. · Section 10A · Section 10AA · Section 70 · set off of losses · eligible unit deduction · profits of SEZ unit · losses of other units · computation of 10A deduction · set off losses of 10AA units · gross total income

Also reported as

77 Taxmann.com 41291 CTR 1244 Taxmann 273

Sections most often in play

Section 10ASection 10AASection 139(1)Section 143(3)Section 10BSection 143(1)Section 115JBSection 139(5)
Read the full judgment

Issues it is cited on

section 70section 10aset off of lossessection 10bsection 10aasection 80hhunabsorbed depreciationsection 80hhccomputer softwaretested partyeligible businessgross total income

Judgments citing CIT v. Yokogawa India Ltd.

San Disk India Device Design Centre Pvt. Ltd., Bangalore vs. ITO, Bangalore

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

ITA 543/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

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

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER IT(TP)A No. and Appellant Respondent Assessment Year 543/Bang/2015 M/s. SanDisk India Device Design The Income Tax Officer, 2010-11 Centre Pvt. Ltd., Ward - 6(1)(1), Survey No.143/1, Amani Bellandur Bengaluru. Khane Village, Prestige Excelsior, Prestige Tech Park, Marathalli- Sarjapur Outer Ring Road, Kadubeesanahalli, Varthu Hobli, Bengaluru – 560 103. PAN : AAICS 9204 M 341/Bang/2015 The Income Tax Officer, M/s. SanDisk India Device 2010-11 Ward - 6(1)(1), Design C…

DCIT, Bangalore vs. M/S Sandisk India Device Design Centre Private Limited, Bangalore

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

ITA 341/BANG/2015[2010-11]Status: DisposedITAT Bangalore15 Dec 2021AY 2010-11

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

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Shri. Sunil Kumar Singh, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(3)Section 154Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER IT(TP)A No. and Appellant Respondent Assessment Year 543/Bang/2015 M/s. SanDisk India Device Design The Income Tax Officer, 2010-11 Centre Pvt. Ltd., Ward - 6(1)(1), Survey No.143/1, Amani Bellandur Bengaluru. Khane Village, Prestige Excelsior, Prestige Tech Park, Marathalli- Sarjapur Outer Ring Road, Kadubeesanahalli, Varthu Hobli, Bengaluru – 560 103. PAN : AAICS 9204 M 341/Bang/2015 The Income Tax Officer, M/s. SanDisk India Device 2010-11 Ward - 6(1)(1), Design C…

M/S. Arctern Consulting Pvt. Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-1(1)(2), Bengaluru

ITA 2747/BANG/2017[2013-14]Status: DisposedITAT Bangalore03 Nov 2021AY 2013-14

Bench: Shri B.R. Baskaran & Smt Beena Pillaiit(Tp)A. No. 2747/Bang/2017 Assessment Year: 2013-14 M/S. Arctern Consulting Pvt. Ltd., Embassy Tech Village, The Deputy Tower 2B, Commissioner Of Hibiscus 5Th Floor, Income Tax, Outer Ring Road, Circle – 1(1)(2), Vs. Deverabeesanahalli, Bangalore. Bangalore – 560103. Pan: Aaeca9113F (Appellant) (Respondent) Smt. Tanmayee Rajkumar, Appellant By : Advocate Respondent By : Shri Gopinath C.H., Cit (Dr) Date Of Hearing : 23.09.2021 Date Of Pronouncement : 03.11.2021 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 17/10/2017 Passed Under Section 143(3) R.W.S. 144C(13) Of The Act By The Ld.Dcit, Circle1(1)(2), Bangalore On Following Grounds Of Appeal: “1. That The Order Of The Respondent / Assessing Officer ('Ao' For Short) Pursuant To The Directions Of The Dispute Resolution Panel (The Drp' For Short). To The Extent Prejudicial To The Appellant. Is Bad In Law & Liable To Be Set Aside. 2. Adjustment To The Prices Charged By The Appellant For International Transactions-

For Appellant: AdvocateFor Respondent: Shri Gopinath C.H., CIT (DR)
Section 133(6)Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “C” BENCH: BANGALORE BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SMT BEENA PILLAI, JUDICIAL MEMBER IT(TP)A. No. 2747/Bang/2017 Assessment Year: 2013-14 M/s. Arctern Consulting Pvt. Ltd., Embassy Tech Village, The Deputy Tower 2B, Commissioner of Hibiscus 5th Floor, Income Tax, Outer Ring Road, Circle – 1(1)(2), vs. Deverabeesanahalli, Bangalore. Bangalore – 560103. PAN: AAECA9113F (Appellant) (Respondent) Smt. Tanmayee Rajkumar, Appellant by : Advocate Respondent by : Shri Gopinath C.H., CIT (DR) Date of Hearing : 23.09.2021 Date of Pronouncement : 03.1…

Deputy Commissioner of Income Tax, Circle - 1(1)(1), Bangalore vs. M/S. Atria Power Corporation Private Limited, Bangalore

In the result, both the appeals of the assessee are dismissed

ITA 1097/BANG/2019[2014-15]Status: DisposedITAT Bangalore12 Oct 2021AY 2014-15

Bench: Shri George George K.And Shri B.R. Baskaran

For Appellant: Shri K. Sankar Ganesh, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 143(3)Section 148Section 14ASection 80I

…mann.com 134 (SC) SUPREME COURT OF INDIA Makino India (P.) Ltd CIVIL APPEAL NO. 1062 OF 2017 APRIL 3, 2017 'Section 10A of the Income-tax Act, 1961 - Free trade zone (Computation of deduction) - Whether in view of judgment in CIT v. Yokogawa India Ltd. [20171 391 ITR 274/244 Taxman 273/77 taxmann.com 41 (SC), after amendment of section 10A by Finance Act, 2000 with effect from 1-4-2001, said section has become a provision for deduction but stage of deduction would be while computing gross total income of eligible undertaking under Chapter IV of Act and not at stage of computation of total income under Chapter VI…

Deputy Commissioner of Income Tax, Circle - 1(1)(1), Bangalore vs. M/S. Atria Power Corporation Private Limited, Bangalore

In the result, both the appeals of the assessee are dismissed

ITA 1096/BANG/2019[2013-14]Status: DisposedITAT Bangalore12 Oct 2021AY 2013-14

Bench: Shri George George K.And Shri B.R. Baskaran

For Appellant: Shri K. Sankar Ganesh, D.RFor Respondent: Shri V. Srinivasan, A.R
Section 143(3)Section 148Section 14ASection 80I

…mann.com 134 (SC) SUPREME COURT OF INDIA Makino India (P.) Ltd CIVIL APPEAL NO. 1062 OF 2017 APRIL 3, 2017 'Section 10A of the Income-tax Act, 1961 - Free trade zone (Computation of deduction) - Whether in view of judgment in CIT v. Yokogawa India Ltd. [20171 391 ITR 274/244 Taxman 273/77 taxmann.com 41 (SC), after amendment of section 10A by Finance Act, 2000 with effect from 1-4-2001, said section has become a provision for deduction but stage of deduction would be while computing gross total income of eligible undertaking under Chapter IV of Act and not at stage of computation of total income under Chapter VI…

Asst. CIT CC 5 (1), Mumbai vs. M/S Datamatics Business Solutions Ltd., Mumbai

In the result, Revenue’s appeal is dismissed

ITA 6534/MUM/2019[2011-12]Status: DisposedITAT Mumbai27 Sept 2021AY 2011-12

Bench: Shri Mahavir Singh & Shri S. Rifaur Rahman

For Appellant: Shri Anuj KisnadwalaFor Respondent: Shri Bharat Andhale
Section 10ASection 10A(1)Section 115JSection 143(1)Section 143(3)Section 14ASection 154Section 2

…IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA no.6534/Mum./2019 (Assessment Year : 2011–12) Asstt. Commissioner of Income Tax ……………. Appellant Central Circle–5(1), Mumbai v/s M/s. Datamatics Business Solution Ltd. Plot no.B–05, Part–B, Cross Lane ……………. Respondent MIDC, Andheri (E), Mumbai 400 093 PAN – AAACD2538D Revenue by : Shri Bharat Andhale Assessee by : Shri Anuj Kisnadwala Date of Hearing – 28.07.2021 Date of Order – 27.09.21 O R D E R PER S. RIFAUR RAHMAN, A.M. The present appeal has been filed by t…

The Pr Commissioner of Income Tax vs. M/S Sasken Technologies Ltd

ITA/55/2021HC Karnataka03 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 260Section 260A

…IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 3RD DAY OF SEPTEMBER, 2021 PRESENT THE HON’BLE MRS.JUSTICE S.SUJATHA AND THE HON’BLE MR. JUSTICE RAVI V. HOSMANI I.T.A.No.55/2021 BETWEEN : 1 . THE PR. COMMISSIONER OF INCOME TAX, 5TH FLOOR, BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU-560095 2 . THE DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE-6(1)(1) 2ND FLOOR, BMTC BUILDING, 6TH BLOCK 80 FEET ROAD, KORAMANGALA BENGALURU-560095 ...APPELLANTS (BY SRI K.V.ARAVIND, ADV.) AND : M/s SASKEN TECHNOLOGIES LTD., (FORMERLY KNOWN AS SASKEN COM…

The Pr Commissioner of Income Tax vs. M/S Exide Life Insurance Company Ltd

In the result, both the appeals stand dismissed

ITA/112/2020HC Karnataka31 Aug 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 10Section 260Section 260ASection 44

…IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 31ST DAY OF AUGUST, 2021 PRESENT THE HON’BLE MRS.JUSTICE S.SUJATHA AND THE HON’BLE MR. JUSTICE RAVI V. HOSMANI I.T.A.No.112/2020 c/w I.T.A.No.118/2020 IN I.T.A.No.112/2020: BETWEEN : 1 . THE PR. COMMISSIONER OF INCOME TAX 5TH FLOOR, BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU-560 095 2 . THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 (1) (2) 2ND FLOOR, BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU-560 095 ...APPELLANTS (BY SRI K.V.ARAVIND, ADV.) AND : M/s EXIDE LIFE INSURANCE C…

The Pr Commissioner of Income Tax vs. M/S Exide Life Insurance Co Ltd

In the result, both the appeals stand dismissed

ITA/118/2020HC Karnataka31 Aug 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 10Section 260Section 260ASection 44

…IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 31ST DAY OF AUGUST, 2021 PRESENT THE HON’BLE MRS.JUSTICE S.SUJATHA AND THE HON’BLE MR. JUSTICE RAVI V. HOSMANI I.T.A.No.112/2020 c/w I.T.A.No.118/2020 IN I.T.A.No.112/2020: BETWEEN : 1 . THE PR. COMMISSIONER OF INCOME TAX 5TH FLOOR, BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU-560 095 2 . THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2 (1) (2) 2ND FLOOR, BMTC BUILDING 80 FEET ROAD, KORAMANGALA BENGALURU-560 095 ...APPELLANTS (BY SRI K.V.ARAVIND, ADV.) AND : M/s EXIDE LIFE INSURANCE C…

M/S Sasken Technologies Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-6(1)(1), Bangalore

Accordingly this ground raised by assessee stands allowed

ITA 2471/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Aug 2021AY 2013-14

Bench: Shri Br Baskaran & Smt. Beena Pillai

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Shri Pradeep Kumar, CIT(DR)
Section 92CSection 92C(2)

…already reduced Rs.1,59,19,069/- from the export turnover while computing the deduction which is attributable to the eligible units. 6.2 Admittedly this issue is now settled by the decision of Hon’ble Supreme Court in case of Yokogawa India Ltd., reported in 391 ITR 274 wherein it has been held as under: “That from a reading of the relevant provisions of section 10A it is more than clear that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of deduct…

Cargotec India Pvt Ltd., Navi Mumbai vs. Asst CIT 15(1)(2), Mumbai

In the result, the appeal of the assessee in ITA No

ITA 399/MUM/2020[2013-14]Status: DisposedITAT Mumbai18 Aug 2021AY 2013-14
Section 143(3)Section 37(1)

…PI unit which is eligible for deduction u/s 10A of the Act, which action was upheld by the ld CITA also. We find that this issue is no longer res integra in view of the decision of the Hon‟ble Supreme Court in the case of CIT vs Yokogawa India Ltd reported in 391 ITR 274 (SC) wherein it was held as under:- 16. From a reading of the relevant provisions of Section 10A it is more than clear to us that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of…

Asst CIT 10 (1)(1), Mumbai vs. M/S Indofil Industries Ltd., Mumbai

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

ITA 8049/MUM/2019[2012-13]Status: DisposedITAT Mumbai18 Aug 2021AY 2012-13
Section 10ASection 115JSection 143(3)

…osses of non-eligible units need not be set off M/s. Indofil Industries Ltd., with the profits of the eligible unit. This issue is no longer res integra in view of the decision of the Hon’ble Supreme Court in the case of CIT vs Yokogawa India Ltd reported in 391 ITR 274 (SC) wherein it was held as under:- 16. From a reading of the relevant provisions of Section 10A it is more than clear to us that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of d…

M/S. Tcs E-Serve International Ltd., Mumbai vs. ACIT, Gurgaon

In the result, the appeal of the assessee is allowed

ITA 1372/DEL/2016[2010-11]Status: DisposedITAT Delhi06 Aug 2021AY 2010-11

Bench: Shri N.K. Billaiya & Shri K. Narasimha Charyassessment Year: 2010-11

For Appellant: Sh. S.P. Singh, CA &For Respondent: Ms. Anima, Sr. DR
Section 10A

…under Chapter-III, the income of a unit has to be excluded before arriving or computing the gross total income of the assessee. In support of this proposition, he places reliance on the decision of Hon’ble Supreme Court in CIT vs. Yokogawa India Ltd. (2017) 391 ITR 274(SC) and proceeded to submit that deduction u/s. 10AA of the Act should be treated as exempt and cannot be brought to form part of the tax computation and consequently, brought forward losses and unabsorbed depreciation cannot be set off against the income which cannot form part of total income. 8. In respect of assessee’s claim for grant of cred…

M/S. Ocwen Financial Solutions Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Special Range-5, Bengaluru

In the result, appeal filed by the assessee for assessment year

ITA 2292/BANG/2019[2010-11]Status: DisposedITAT Bangalore12 Jul 2021AY 2010-11

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2012-13 Ocwen Financial Solutions Pvt. Ltd. Pritech Park, Survey No.51 To 64/4 Acit Circle- Block No.12, 5Th Floor Of B Wing & 6Th Floor Of 5(1)(2) Vs. A Wing, Bellandur Village, Marathahalli Ring Bengaluru Road, Bengaluru 560 103 Pan No : Aaaco3764E Appellant Respondent Assessment Year : 2010-11 Ocwen Financial Solutions Pvt. Ltd. Jcit Spl.Range-5 Vs. Bangalore Bangalore Appellant Respondent Appellant By : Shri K.R. Vasudevan, A.R. Respondent : Ms. Neera Malhotra & By Shri Kannan Narayanan, D.Rs Date Of Hearing : 23.06.2021 Date Of Pronouncement : 12.07.2021 O R D E R

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Ms. Neera Malhotra &
Section 10ASection 143(3)

…ITA No.153/Bang/2017 & ITA 2292/Bang/2019 Ocwen Financial Solutions Pvt. Ltd., Bengaluru IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B.R. BASKARAN, ACCOUNTANT MEMBER Assessment Year : 2012-13 Ocwen Financial Solutions Pvt. Ltd. Pritech Park, Survey No.51 to 64/4 ACIT Circle- Block No.12, 5th Floor of B Wing & 6th Floor of 5(1)(2) Vs. A Wing, Bellandur village, Marathahalli Ring Bengaluru Road, Bengaluru 560 103 PAN NO : AAACO3764E APPELLANT RESPONDENT Assessment Year : 2010-11 Ocwen Financial Solutions Pvt. Ltd. JCIT Spl.Range-5 Vs. Bangalore…

Ocwen Financial Solutions Pvt Ltd, Bangalore vs. Assistant Commissioner of Income Tax Circle-5(1)(2), Bangalore

In the result, appeal filed by the assessee for assessment year

ITA 153/BANG/2017[2012-13]Status: DisposedITAT Bangalore12 Jul 2021AY 2012-13

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranassessment Year : 2012-13 Ocwen Financial Solutions Pvt. Ltd. Pritech Park, Survey No.51 To 64/4 Acit Circle- Block No.12, 5Th Floor Of B Wing & 6Th Floor Of 5(1)(2) Vs. A Wing, Bellandur Village, Marathahalli Ring Bengaluru Road, Bengaluru 560 103 Pan No : Aaaco3764E Appellant Respondent Assessment Year : 2010-11 Ocwen Financial Solutions Pvt. Ltd. Jcit Spl.Range-5 Vs. Bangalore Bangalore Appellant Respondent Appellant By : Shri K.R. Vasudevan, A.R. Respondent : Ms. Neera Malhotra & By Shri Kannan Narayanan, D.Rs Date Of Hearing : 23.06.2021 Date Of Pronouncement : 12.07.2021 O R D E R

For Appellant: Shri K.R. Vasudevan, A.RFor Respondent: Ms. Neera Malhotra &
Section 10ASection 143(3)

…ITA No.153/Bang/2017 & ITA 2292/Bang/2019 Ocwen Financial Solutions Pvt. Ltd., Bengaluru IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI B.R. BASKARAN, ACCOUNTANT MEMBER Assessment Year : 2012-13 Ocwen Financial Solutions Pvt. Ltd. Pritech Park, Survey No.51 to 64/4 ACIT Circle- Block No.12, 5th Floor of B Wing & 6th Floor of 5(1)(2) Vs. A Wing, Bellandur village, Marathahalli Ring Bengaluru Road, Bengaluru 560 103 PAN NO : AAACO3764E APPELLANT RESPONDENT Assessment Year : 2010-11 Ocwen Financial Solutions Pvt. Ltd. JCIT Spl.Range-5 Vs. Bangalore…

M/S Altisource Business Solutions Pvt. Ltd., Bangalore vs. ACIT, Bangalore

In the result appeal filed by assessee stands allowed partly as indicated hereinabove

ITA 208/BANG/2016[2011-12]Status: DisposedITAT Bangalore02 Jul 2021AY 2011-12

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.208/Bang/2016 Assessment Year : 2011-12

For Appellant: Shri K.R Vasudevan, AdvocateFor Respondent: Shri Shishir Srivastava, CIT
Section 143Section 144C(13)Section 144C(5)Section 92C

…us now. 13. In the appeal filed by revenue, only issue is in respect of deduction computed under section 10A/10AA of the Act. 14. Admittedly this issue is res integra settled by the decision of Hon’ble Supreme Court in case of Yokogawa India Ltd., reported in 391 ITR 274 wherein it has been held as under: “That from a reading of the relevant provisions of section 10A it is more than clear that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of deduct…

DCIT, Bangalore vs. M/S Core Objects India Pvt. Ltd., Bangalore

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH : BANGALORE BEFORE SHRI. CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No.517/Bang/2015 Assessment Year : 2010-11 The Dy. Commissioner of M/s Harman Connected Income-Tax, Services Corporation Pvt. Circle-6(1)(1), Ltd., Bengaluru. Vs. No.3&3A, EOIZ Industrial Area, Survey No.85 & 86, Sadamangala Village, Krishnarajapuram Hobli, Bangalore-560 066. PAN – AACCC 2040 B APPELLANT RESPONDENT IT(TP)A No.570/Bang/2015 Assessment Year : 2010-11 M/s Harman Connected The Dy. Commissioner of Services Corporation Pvt. Income-Tax, Ltd., Circle…

Eit Services India Private vs. Assistant Commissioner

The appeal is disposed of

ITA/118/2017HC Karnataka24 Mar 2021

Bench: ALOK ARADHE,M.G.S. KAMAL

Section 10ASection 143(3)Section 260Section 263

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 24TH DAY OF MARCH, 2021 PRESENT THE HON’BLE MR. JUSTICE ALOK ARADHE AND THE HON’BLE MR. JUSTICE M.G.S. KAMAL I.T.A. NO.118 OF 2017 BETWEEN: EIT SERVICES INDIA PRIVATE LIMITED (FORMERLY KNOWN AS HEWLETT PACKARD GLOBALSOFT PVT. LTD.) 39/40, ELECTRONIC CITY, PHASE-II, HOSUR ROAD, BANGALORE-560 100 REPRESENTED HEREIN BY ITS DIRECTOR, MR. M.S. PRAKASH ...APPELLANT (BY MS.MAHIMA GOUD, ADVOCATE FOR SRI T.SURYANARAYANA, ADVOCATE) AND: 1. ASSISTANT COMMISSIONER OF INCOME-TAX-CIRCLE 3(1)(2)(ERSTWHI…

Altisource Business Solutions Private Limited, Bangalore vs. DCIT, Bangalore

In the result, the revenue’s appeal is partly allowed

ITA 335/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Mar 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(5)

…s retained after giving effect to this order of the Tribunal. It is ordered accordingly. 50. Ground Nos. 7 & 8 by the revenue read as under:- 51. This issue is squarely covered by the judgment of the Hon’ble Supreme Court in the case of Yokogawa India Ltd., 391 ITR 274 wherein it was held as follows:- “That from a reading of the relevant provisions of section 10A it is more than clear that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of deducti…

DCIT, Bangalore vs. M/S Altisource Business Solutions Pvt. Ltd., Bangalore

In the result, the revenue’s appeal is partly allowed

ITA 178/BANG/2015[2010-11]Status: DisposedITAT Bangalore11 Mar 2021AY 2010-11

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(5)

…s retained after giving effect to this order of the Tribunal. It is ordered accordingly. 50. Ground Nos. 7 & 8 by the revenue read as under:- 51. This issue is squarely covered by the judgment of the Hon’ble Supreme Court in the case of Yokogawa India Ltd., 391 ITR 274 wherein it was held as follows:- “That from a reading of the relevant provisions of section 10A it is more than clear that the deductions contemplated therein is qua the eligible undertaking of an assessee standing on its own and without reference to the other eligible or non-eligible units or undertakings of the assessee. The benefit of deducti…