DDIT v. Reliance Infocom Ltd.

64 SOT 137Income Tax Appellate Tribunal2014#25407 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2017 to 2022.

Judgments citing DDIT v. Reliance Infocom Ltd.

Interactive Avenues Pvt. Limited, Mumbai vs. DCIT 14(2)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 3130/MUM/2019[2015-16]Status: DisposedITAT Mumbai07 Jul 2022AY 2015-16

Bench: Us :-

Section 143(3)Section 40

…e Limited vs ADIT reported in 86 taxmann.com 237 b) Decision of Hon’ble Karnataka High Court in the case of CIT vs Samsung Electronics Co. Ltd reported in 345 ITR 494 (Kar) c) Decision of Mumbai Tribunal in the case of DDIT vs Reliance Infocom Ltd reported in 64 SOT 137 3.4. We find that the assessee had pleaded that payment made by it to Facebook Ireland Limited was for services rendered for uploading and display of banner advertisement. The banner hosting and uploading advertisement did not involve use by the assessee of any industrial, commercial or scientific equipment, copyright and no such use was granted b…

M/S. Tata Technologies Ltd., Pune vs. Deputy Director of Income-Tax

In the result, appeal of assessee is partly allowed

ITA 1433/PUN/2014[2007-08]Status: DisposedITAT Pune05 Apr 2018AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1433/Pun/2014 यििाारण वषा / Assessment Year : 2007-08 M/S. Tata Technologies Limited, Plot No.25, Rajiv Gandhi Infotech Park, अऩीऱाथी/Appellant Hingewadi, Pune – 411057 …. Pan: Aaact3092N Vs. The Dy. Director Of Income Tax …. प्रत्यथी / Respondent (International Taxation)-Ii, Pune

For Appellant: S/Shri Dhanesh Bafna and Arpitha ChoudaryFor Respondent: S/Shri Vivek Aggarwal and Mukesh Jha

Section 115ASection 195Section 201Section 201(1)Section 9(1)(vi)Section 90(2)

…lhi Tribunal in Motorola Inc. Vs. DCIT reported in 147 Taxman 39 (Del) (SB), which decided the issue of deductibility of software and intra-software. He fairly admitted that the decision which was against the assessee in DDIT Vs. Reliance Infocom Ltd. (2014) 64 SOT 137 (Mum) but the said decision has been recalled by the Tribunal vide Miscellaneous Application. The learned Authorized Representative for the assessee also filed small written note against reliance placed upon by the learned Departmental Representative for the Revenue on the ratio laid down in Verizon Communications Singapore Pte. Ltd. Vs. ITO (supr…

Shri Hiren K. Bhandari, Ahmedabad vs. The Income Tax Officer, International Taxation-II, Ahmedabad

In the result, the appeal is allowed

ITA 179/AHD/2014[2009-10]Status: DisposedITAT Ahmedabad19 Sept 2017AY 2009-10

Section 195Section 201Section 9(1)(vi)Section 9(1)(vii)

…. 195, for an amount of Rs.35,366/- was raised by the Assessing Officer. Aggrieved, assessee carried the matter in appeal before the CIT(A) but without any success. Relying upon a decision of this Tribunal, in the case of DDIT vs. Reliance Infocom Ltd [(2014) 64 SOT 137 (Mum)], learned CIT(A) confirmed the action of the Assessing Officer. The assessee is aggrieved and is in further appeal before us. 4. We have heard the rival contentions, perused the material on record and duly considered facts of the case in the light of applicable legal position. 5. We find that the Tribunal decision relied upon by the learne…