Kiran Kapoor v. ITO

150 ITD 237Income Tax Appellate Tribunal#10439 most cited
10

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2018.

Judgments citing Kiran Kapoor v. ITO

ACIT, NEW DELHI vs. M/S WNS BUSINESS CONSULTING SERVICES PVT. LTD.,, MUMBAI

In the result, Appeal of the Department is dismissed

ITA 919/DEL/2013[2008-09]Status: DisposedITAT Delhi14 Aug 2018AY 2008-09

Bench: Shri Bhavnesh Saini & Shri L.P. Sahu

For Appellant: Shri Tarandeep SinghFor Respondent: Shri Kumar Pranav, Sr. D.R
Section 10ASection 92

…29, 2009. In the circumstances, we will find it difficult to hold that the assessee could not prove the actual development or export of the software. 8. Reliance is placed by the AR on a decision of a coordinate bench of this Tribunal in Kiran Kapoor vs. ITO 150 ITD 237 (Del.), wherein at Page No.8 Paragraph No.15 it was held that “in our considered opinion the meaning of phrase or word had to be seen in the framework of the context in which it has been used. Phrase “Manufacture or produce” will have a different contextual meaning when it is read in a statute let us say for e.g. the Excise law, since the parliam…

M/S. WNS MORTGAGE SERVICES PVT. LTD.,MUMBAI vs. ITO, NEW DELHI

In the result, the appeal of the Revenue is

ITA 2716/DEL/2012[2007-08]Status: DisposedITAT Delhi26 May 2017AY 2007-08

Bench: Shri H.S. Sidhu & Shri O.P. Kant, Accoutant Member

Section 10ASection 142(1)Section 143(1)Section 143(2)Section 1OSection 40

…2009. In the circumstances, we will find it difficult to hold that the assessee could not prove the actual development or export of the software. 8. Reliance is placed by the AR on a decision of a coordinate bench of this Tribunal in Kiran Kapoor vs. ITO 150 ITD 237 (Del.), wherein at page no. 8 paragraph no. 15 it was held that “in our considered opinion the meaning of phrase or word had to be seen in the framework of the context in which it has been used. Phrase “Manufacture or produce” will have a different contextual meaning when it is read in a statute let us say for e.g. the Excise law, since the p…

ITO, NEW DELHI vs. M/S. WNS MORTGAGE SERVICES PVT. LTD., MUMBAI

In the result, the appeal of the Revenue is

ITA 2571/DEL/2012[2007-08]Status: DisposedITAT Delhi26 May 2017AY 2007-08

Bench: Shri H.S. Sidhu & Shri O.P. Kant, Accoutant Member

Section 10ASection 142(1)Section 143(1)Section 143(2)Section 1OSection 40

…2009. In the circumstances, we will find it difficult to hold that the assessee could not prove the actual development or export of the software. 8. Reliance is placed by the AR on a decision of a coordinate bench of this Tribunal in Kiran Kapoor vs. ITO 150 ITD 237 (Del.), wherein at page no. 8 paragraph no. 15 it was held that “in our considered opinion the meaning of phrase or word had to be seen in the framework of the context in which it has been used. Phrase “Manufacture or produce” will have a different contextual meaning when it is read in a statute let us say for e.g. the Excise law, since the p…

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO, MUMBAI

In the result, all the appeals of the Revenue are dismissed

ITA 6604/MUM/2012[2009-10]Status: DisposedITAT Mumbai19 Aug 2016AY 2009-10

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri N.P. Singh, DR
Section 10Section 10BSection 143Section 147

…tored in an electronic form it becomes a customized electronic data, which cab be exported to qualify for deduction. The process information technology enabled. Further, case law relied on by the assessee on identical facts in the case of Kiran Kapoor v. ITO, 150 ITD 237 (2014) (Delhi ITAT) which was also approved by Delhi High Court, 372 ITR 321, (2015) (Delhi), it was held that the nature of activity done in the EOU was that of producing designs, drawings, layouts and scanning for the projects of foreign clients on the basis of specifications. The activity was done by taking into consideration the data collecte…

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

ITA 3067/MUM/2012[2008-09]Status: DisposedITAT Mumbai19 Aug 2016AY 2008-09

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri N.P. Singh, DR
Section 10Section 10BSection 143Section 147

…tored in an electronic form it becomes a customized electronic data, which cab be exported to qualify for deduction. The process information technology enabled. Further, case law relied on by the assessee on identical facts in the case of Kiran Kapoor v. ITO, 150 ITD 237 (2014) (Delhi ITAT) which was also approved by Delhi High Court, 372 ITR 321, (2015) (Delhi), it was held that the nature of activity done in the EOU was that of producing designs, drawings, layouts and scanning for the projects of foreign clients on the basis of specifications. The activity was done by taking into consideration the data collecte…

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

ITA 3066/MUM/2012[2007-08]Status: DisposedITAT Mumbai19 Aug 2016AY 2007-08

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri N.P. Singh, DR
Section 10Section 10BSection 143Section 147

…tored in an electronic form it becomes a customized electronic data, which cab be exported to qualify for deduction. The process information technology enabled. Further, case law relied on by the assessee on identical facts in the case of Kiran Kapoor v. ITO, 150 ITD 237 (2014) (Delhi ITAT) which was also approved by Delhi High Court, 372 ITR 321, (2015) (Delhi), it was held that the nature of activity done in the EOU was that of producing designs, drawings, layouts and scanning for the projects of foreign clients on the basis of specifications. The activity was done by taking into consideration the data collecte…

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

ITA 3065/MUM/2012[2006-07]Status: DisposedITAT Mumbai19 Aug 2016AY 2006-07

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri N.P. Singh, DR
Section 10Section 10BSection 143Section 147

…tored in an electronic form it becomes a customized electronic data, which cab be exported to qualify for deduction. The process information technology enabled. Further, case law relied on by the assessee on identical facts in the case of Kiran Kapoor v. ITO, 150 ITD 237 (2014) (Delhi ITAT) which was also approved by Delhi High Court, 372 ITR 321, (2015) (Delhi), it was held that the nature of activity done in the EOU was that of producing designs, drawings, layouts and scanning for the projects of foreign clients on the basis of specifications. The activity was done by taking into consideration the data collecte…

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

ITA 3064/MUM/2012[2005-06]Status: DisposedITAT Mumbai19 Aug 2016AY 2005-06

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri N.P. Singh, DR
Section 10Section 10BSection 143Section 147

…tored in an electronic form it becomes a customized electronic data, which cab be exported to qualify for deduction. The process information technology enabled. Further, case law relied on by the assessee on identical facts in the case of Kiran Kapoor v. ITO, 150 ITD 237 (2014) (Delhi ITAT) which was also approved by Delhi High Court, 372 ITR 321, (2015) (Delhi), it was held that the nature of activity done in the EOU was that of producing designs, drawings, layouts and scanning for the projects of foreign clients on the basis of specifications. The activity was done by taking into consideration the data collecte…

ACIT 11(3), MUMBAI vs. MAJMUDAR & CO., MUMBAI

In the result, all the appeals of the Revenue are dismissed

ITA 3063/MUM/2012[2004-05]Status: DisposedITAT Mumbai19 Aug 2016AY 2004-05

Bench: Shri Mahavir Singh & Shri Rajesh Kumarita Nos. 3063 To 3067/Mum/2012 (Assessment Year‟S: 2004-05 To 2008-09) Asst. Commissioner Of Income-Tax 11(3), Mumbai .... Appellant Vs. M/S. Majmudar & Co., 601/604, Naman Centre, A Wing, G-31, G Block, Bandra Kurla Complex, Bandra, Mumbai - 400028. .... Respondent Appellant By : Shri N.P. Singh, Dr Respondent B: Shri Arvind Sonde, Ar Date Of Hearing : 25/05/2016 Date Of Pronouncement : 19/08/2016 Order Per Mahavir Singh: These Six Appeals By Revenue Are Arising Out Of Different Orders Of Cit (A) In Appeal No.Cit (A)-2/It/376 To 379/2010-11 For The Assessment Years 2004-05 To 2005-06 & 2008-09 Vide Order Of Common Date 07-02-2012, In Appeal No.Cit (A)-2/It/382/2009-10 Dated 07-02-2012 & In Appeal No.Cit (A)-2/It/210/2011-12 Order Dated 23- 08-2012. Assessments Were Framed By The Acit-11 (3), Mumbai For The Assessment Years 2004-05 To 2009-10 Vide His Orders Of Different Dates Acit Vs. M/S. Majmudar & Co. U/S 143 (3) Read With Section 147 Of The Income Tax Act, 1961 (Hereinafter “The Act”).

For Appellant: Shri N.P. Singh, DR
Section 10Section 10BSection 143Section 147

…tored in an electronic form it becomes a customized electronic data, which cab be exported to qualify for deduction. The process information technology enabled. Further, case law relied on by the assessee on identical facts in the case of Kiran Kapoor v. ITO, 150 ITD 237 (2014) (Delhi ITAT) which was also approved by Delhi High Court, 372 ITR 321, (2015) (Delhi), it was held that the nature of activity done in the EOU was that of producing designs, drawings, layouts and scanning for the projects of foreign clients on the basis of specifications. The activity was done by taking into consideration the data collecte…

ACIT, NEW DELHI vs. SMT. KIRAN KAPOOR, NEW DELHI

In the result, the appeal of the department is dismissed

ITA 5964/DEL/2014[2007-08]Status: DisposedITAT Delhi01 Jul 2016AY 2007-08

Bench: Sh. N. K. Saini

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. A. Sreenivasa Rao, Sr. DR
Section 10B

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC-1’, NEW DELHI Before Sh. N. K. Saini, Accountant Member ITA No. 5964/Del/2014 : Asstt. Year : 2007-08 Asstt. Commissioner of Income Vs Smt. Kiran Kapoor, Tax, Circle-23(1), Prop. M/s Ramsa Enterprises, New Delhi M-75, Greater Kailash-II. New Delhi-110048 (APPELLANT) (RESPONDENT) PAN No. AALPK5311M Assessee by : Sh. Tarandeep Singh, Adv. Revenue by : Sh. A. Sreenivasa Rao, Sr. DR Date of Hearing : 30.06.2016 Date of Pronouncement : 01.07.2016 ORDER This is an appeal by the department against the order dated 27.08.2014 of ld. CIT(A)-XXIII, New Delhi. 2. The…

Kiran Kapoor v. ITO (150 ITD 237) — Cited in 10 Judgments | BharatTax