DCIT v. Tata Sons Ltd.

Tata Consultancy Services Limited, Mumbai vs. Deputy Commissioner of Incometax 3(4), Mumbai

In the result, appeals of both, revenue and assessee are partly allowed for all the three assessment years

Bench: Shri Pawan Singh & Shri Girish Agrawal

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005-06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

DCIT 2(3)(1), Mumbai vs. Tata Industries Ltd, Mumbai

Accordingly, Ground No 2(a) & (b) of the revenue in ITA No. 4109/Mum/2012, therefore stands dismissed

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI ARUN KHODPIA (Accountant Member)

…A No. 4109/MUM/2012 ITA No.5690/MUM/2015 & CO No. 144/MUM/2016 under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005- 06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Addl CIT 2(3), Mumbai vs. Tata Industries Ltd, Mumbai

…No. 4109/MUM/2012 ITA No.5690/MUM/2015 & CO No. 144/MUM/2016 under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005- 06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

DCIT -3(4), Mumbai vs. M/S. Tata Consultancy Services Ltd., Mumbai

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy& Ms. Padmavathy.Sआअसं.1447/मुं/2023 (िन.व. 2017-18) Dcit-3(4),Mumbai, 29Th Floor, Center-1, World Trade Center, Cuffe Parade, Mumbai – 400 005 ...... अपीलाथ"/Appellant बनाम Vs. M/S. Tata Consultancy Services Limited, 9Th Floor, Nirmal Building, Nariman Point, Mumbai 400 020. Pan: Aaacr-4849-R ..... "ितवादी/Respondent

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee’s own case in assessment year 2005–06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

ACIT(Ltu-1), Mumbai vs. M/S. Tcs Ltd, Mumbai

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005-06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Tata Consultancy Serrvices Limited, Mumbai vs. DCIT-1, Mumbai

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005-06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Tata Consultancy Services Ltd, Mumbai vs. ACIT Large Tax Payer Unit-1, Mumbai

797/Mum/2018

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005-06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Tata Consultancy Services Ltd, Mumbai vs. Asst CIT Ltu-1, Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

…oubt, in assessee‘s own case in assessment year 2005–06, the Tribunal in the order referred to above Tata Consultancy Services Ltd. ITA No. 17/Mum./2011 ITA no.1650/Mum./2016 ITA no.1054/Mum./2016 following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Asst CIT (Ltu) 1, Mumbai vs. Tata Consultancy Services Ltd, Mumbai

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy () & Shri N.K. Pradhan () It(Tp)A No. 3262/Mum/2017 Assessment Year: 2007-08

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005-06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Tata Consultancy Services Ltd, Mumbai vs. Addl CIT Ltu 1, Mumbai

In the result, the appeal filed by the Revenue is dismissed

Bench: Shri Vikas Awasthy () & Shri N.K. Pradhan () It(Tp)A No. 3262/Mum/2017 Assessment Year: 2007-08

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee's own case in assessment year 2005-06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…

Tata Consultancy Services Ltd, Mumbai vs. Addl CIT Large Tax Payer Unit, Mumbai

In the result the appeal of the assessee in AY 2008-09 is partly allowed and

Bench: Shri Pawan Singh & Shri Rajesh Kumarvertual Court No. Iii It(Tp)A No. 3263/Mum/2017 For Ay 2008-09 It(Tp) No. 794/Mum/2018 For Ay 201-011 Tata Consultancy Services Vs Dcit Ltd.,9Th Floor, Nirmal Bldg, Large Tax Payer Unit-1, 29Th Floor, Wtc, Nariman Point. Mumbai – 21 Cufee Parade Pan Aaacr4849R Mumbai- 05. Appellant Respondednt

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI RAJESH KUMAR, ACCOUNTANT MEMBER Vertual Court No. III IT(TP)A No. 3263/Mum/2017 for AY 2008-09 IT(TP) No. 794/Mum/2018 For AY 201-011 Tata Consultancy Services Vs DCIT ltd.,9th Floor, Nirmal Bldg, Large Tax Payer Unit-1, 29th Floor, WTC, Nariman Point. Mumbai – 21 Cufee Parade PAN AAACR4849R Mumbai- 05. APPELLANT RESPONDEDNT IT(TP)A No. 3746/Mum2016 for AY 2008-09 IT(TP)A No. 1207/Mum2018 for AY 2010-11 DCIT Vs Tata Consultancy Services ltd.,9th Floor, Nirmal Large Tax Payer Unit-1, 29th Floor, WTC, Cufee…

Tata Consultancy Services Ltd, Mumbai vs. Addl CIT Ltu -1, Mumbai

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

Bench: Shri Saktijit Dey & Shri N.K. Pradhan

…e issue which arises is, whether it can be allowed as deduction under section 37 of the Act. No doubt, in assessee’s own case in assessment year 2005–06, the Tribunal in the order referred to above following its own decision in DCIT v/s Tata Sons Ltd., [2011] 43 SOT 27 (Mum.), has held that the State taxes paid overseas cannot be allowed as deduction in view of the provisions of section 40(a)(ii) of the Act. However, the aforesaid legal position has substantially changed after the decision of the Hon'ble Jurisdictional High Court in Reliance Infrastructure Ltd. (supra). While interpreting the provisions of sectio…