Commissioner of Income Tax v. Vegetable Product Ltd.

DASSAULT SYSTEMS SOLIDWORKS CORPORATION,CHENNAI vs. THE ACIT (INTL TAX) -2(1) (2) , MUMBAI

In the result, the appeal is allowed

…Tax Appeal No.9 of 2011 vide order dated 15th September, 2011 while relying upon the decision of the Hon’ble Supreme Court in the Commissioner of Income Tax V. Vegetable Product Ltd. (1973) 88 ITR 192 and in Mauri Yeast India Pvt. Ltd. Vs. Stte of U.P. (2008) 14 VST 259 (SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the 7 ITA No. 7027/MUM/2018 (A.Y: 2015-16) Dassault Systems Solidworks Corporation decision of Hon’b…

DASSAULT SYSTEMES SOLIDWORKS CORPORATION,CHENNAI vs. THE ACIT (INT. TAX) 2(1) (2) , MUMBAI

Bench: Shri M. Balaganesh & Shri Kuldip Singhassessment Year: 2017-18

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “I”, MUMBAI BEFORE SHRI M. BALAGANESH, ACCOUNTANT MEMBER AND SHRI KULDIP SINGH, JUDICIAL MEMBER Assessment Year: 2017-18 M/s. Dassault Systemes The Asst. Commissioner Solid Works Corporation, of Income-tax C/o Deloitte Haskins and (International Taxation)- Sells LLP, 2(1)(2), Vs. 7th Floor, ASV Ramana Mumbai Towers 52, Venkatnarayana Road, Chennai – 600 017 PAN: AAFCS8787E (Appellant) (Respondent) Present for: Assessee by : Shri Pranith Golecha, A.R. Revenue by : Shri Milind Chavan, Sr. D.R. Date of Hearing : 05 . 05 . 2022 Date of Pronouncement : 27 . 05 . 2…

DASSAULT SYSTEMES SOLIDWORKS CORPORATION ,CHENNAI vs. DY CIT (IT) 2 (1)(2), MUMBAI

Bench: Shri Pramod Kumar() & Shri Ravish Sood () Assessment Year: 2016-17 Dassault Systems Solid The Dy. Commissioner Of Income Works Corporation, Vs. Tax– (International Taxation)- C/O Deloitte Haskins & 2(1)(2) Sells Llp , 7Th Floor, Asv Mumbai Ramana Towers 52, Venkatnarayana Road, Chennai – 600 017 Pan No. Aafcs8787E Appellant Respondent

…Tax Appeal No.9 of 2011 vide order dated 15th September, 2011 while relying upon the decision of the Hon’ble Supreme Court in the Commissioner of Income Tax V. Vegetable Product Ltd. (1973) 88 ITR 192 and in Mauri Yeast India Pvt. Ltd. Vs. Stte of U.P. (2008) 14 VST 259 (SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the 7 ITA No. 7027/MUM/2018 (A.Y: 2015-16) Dassault Systems Solidworks Corporation decision of Hon’b…

DASSAULT SYSTEMS SOLIDWORKS CORPORATION,CHENNAI vs. DDIT (IT) 2(1)(2), MUMBAI

In the result, the appeal filed by the assessee is hereby ordered to be Allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri G. Manjunatha, Hon'Bledassault Systems Solidworks Corporation Dy. Cit (International Taxation) – 2(1)(2) V. Mumbai C/O Deloitte Haskins & Sells Llp 7Th Floor, Asv Ramana Towers 52, Venkatnaryana Road Chennai – 600 017 Pan: Aafcs8787E (Appellant) (Respondent) Assessee By : Shri Anantha Krishnan N Department By : Shri V. Sreekar

…Tax Appeal No.9 of 2011 vide order dated 15th September, 2011 while relying upon the decision of the Hon’ble Supreme Court in the Commissioner of Income Tax V. Vegetable Product Ltd. (1973) 88 ITR 192 and in Mauri Yeast India Pvt. Ltd. Vs. Stte of U.P. (2008) 14 VST 259 (SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the 7 Dassault Systems Solidworks Corporation decision of Hon’ble Supreme Court in Bihar State Elect…

INTEC BILLING IRELAND,MUMBAI vs. DCIT (IT) 2 (2)(1), MUMBAI

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

Bench: Shri G.S. Pannu & Shri Sandeep Gosain: A.Y : 2013-14

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I”, MUMBAI BEFORE SHRI G.S. PANNU, VICE PRESIDENT AND SHRI SANDEEP GOSAIN, JUDICIAL MEMBER : A.Y : 2013-14 Intec Billing Ireland Vs. DDIT (IT), Range-3(1), C/o. S.R.B.C & Associates LLP Mumbai. (Respondent) 14th floor, The Ruby, 29, Senapati Bapat Marg, Dadar (W), Mumbai 400 028. PAN : AADCA7890E (Appellant) Appellant by : Shri M.P. Lohia & Shri Nikhil Tiwari Respondent by : Shri Nishant Samaiya Date of Hearing : 19/03/2019 Date of Pronouncement : 19/03/2019 O R D E R PER G.S. PANNU, VICE PRESIDENT : This appeal by the assessee is directed against the orde…

DASSAULT SYSTEMS SOLDWORKS CORPORATION,CHENNAI vs. DDIT (IT) 2(1)(2), MUMBAI

In the result, the appeal filed by the assessee is hereby ordered to be Allowed

Bench: Shri R.C.Sharma, Am & Shri Pawan Singh, Jm

…Tax Appeal No.9 of 2011 vide order dated 15th September, 2011 while relying upon the decision of the Hon’ble Supreme Court in the Commissioner of Income Tax V. Vegetable Product Ltd. (1973) 88 ITR 192 and in Mauri Yeast India Pvt. Ltd. Vs. Stte of U.P. (2008) 14 VST 259 (SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the decision of Hon’ble Supreme Court in Bihar State Electricity Board and another Vs. M/s. Usha Mar…

INTECH BILLING IRELAND,MUMBAI vs. DDIT (IT) RG 3(1), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri C.N. Prasad, Hon'Ble & Shri Manjunatha, Hon'Bleintec Billing Ireland V. The Assistant Director Of Income –Tax C/O S.R.B.C & Associates Llp (International Taxation), 14Th Floor, The Ruby, Range 3(1), Scindia House, 29 Senapati Bapat Marg, Mumbai - 400 038 Dadar (West) Mumbai – 400 028 Pan No: Aadca 7890 E (Appellant) (Respondent) Assessee By : Shri M.P. Lohia Shri Nikhil Tiwari Department By : Shri Samuel Darse

…x Appeal No.9 of 2011 vide order dated 15 September, 2011 while relying upon the decisions of the Hon'ble Supreme Court in "The Commissioner of Income Tax V. Vegetable Product Ltd." (1973) 88 ITR 192 and in "Mauri Yeast India Pvt. Ltd. V. State of UP." (2008) 14 VST 259(SC) (2008) 5 S.C. C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the decision of Hon'ble Supreme Court in "Bihar State Electricity Board and another vs. M/s. Usha Mart…

M/S. I 2 TECHNOLOGIES (NETHERLAND) B.V.,MUMBAI vs. ADIT RG. - 3(1), MUMBAI

In the result, appeal filed by assessee for AYs 2002-03, 2004-05 are allowed and the appeal filed by Revenue against deletion of penalty levied u/s 271(1)(c) is dismissed

Bench: Shri Jason P. Boaz & Shri Pawan Singh

…Tax Appeal No.9 of 2011 vide order dated 15 September, 2011 while relying upon the decisions of the Hon‘ble Supreme Court in The Commissioner of Income Tax V. Vegetable Product Ltd. (1973) 88 ITR 192 and in Mauri Yeast India Pvt. Ltd. V. State of U.P. (2008) 14 VST 259(SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the decision of Hon‘ble Supreme Court in ―Bihar State Electricity Board and another vs. M/s. Usha Mar…

DASSAULT SYSTEMS SOLDWORKS CORPORATION,CHENNAI vs. DDIT (IT) 2(1)(2), MUMBAI

In the result, the appeal filed by the assessee is hereby ordered

Bench: Shri R.C.Sharma, Am & Shri Amarjit Singh, Jm

…of 2011 vide order dated 15th September, 9 A.Y.2011-12 2011 while relying upon the decision of the Hon’ble Supreme Court in the Commissioner of Income Tax V. Vegetable Product Ltd. (1973) 88 ITR 192 and in Mauri Yeast India Pvt. Ltd. Vs. Stte of U.P. (2008) 14 VST 259 (SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the decision of Hon’ble Supreme Court in Bihar State Electricity Board and another Vs. M/s. Usha Mar…

SOLIDWORKS CORPORATION,MUMBAI vs. ADDL DIT (IT) 2, MUMBAI

In the result, the appeal is allowed

…Appeal No. 9 of 2011 vide order dated 15 September, 2011 while relying upon the decisions of the Hon’ble Supreme Court in “The Commissioner of Income Tax V. Vegetable Product Ltd.” (1973) 88 ITR 192 and in “Mauri Yeast India Pvt. Ltd. V. State of U.P.” (2008) 14 VST 259(SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the decision of Hon’ble Supreme Court in “Bihar State Electricity Board and another vs. M/s. Usha Mar…

DASSAULT SYSTEMES SOLIDWORKS CORPORATION,CHENNAI vs. DDIT (IT) 1(2), MUMBAI

In the result, the appeal is allowed

…Appeal No. 9 of 2011 vide order dated 15 September, 2011 while relying upon the decisions of the Hon’ble Supreme Court in “The Commissioner of Income Tax V. Vegetable Product Ltd.” (1973) 88 ITR 192 and in “Mauri Yeast India Pvt. Ltd. V. State of U.P.” (2008) 14 VST 259(SC) : (2008) 5 S.C.C. 680 has held that, if two views in regard to the interpretation of a provision are possible, the Court would be justified in adopting that construction which favours the assessee. Reliance can also be placed in this regard on the decision of Hon’ble Supreme Court in “Bihar State Electricity Board and another vs. M/s. Usha Mar…