KPIT CUMMINS GLOBAL BUSINESS SOLUTIONS LTD.,,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX,,
In the result, appeal of assessee relating to assessment year 2008-09 is partly allowed, appeal of assessee relating to assessment year 2009-10 and appeal of Revenue are partly allowed
ITA 525/PUN/2014[2009-10]Status: DisposedITAT Pune09 Apr 2018AY 2009-10
Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.246/Pun/2013 यििाारण वषा / Assessment Year : 2008-09
For Appellant: Shri Kishore PhadkeFor Respondent: Shri Rajeev Kumar, CIT
Section 10ASection 143(3)Section 37(1)Section 92CSection 92C(2)
…commercial rights, business was given to the assessee. He further placed reliance on the ratio laid down by the Hon’ble Bombay High Court in CIT Vs. Gem Plus Jewellery India Ltd. (supra) and Mumbai Bench of Tribunal in Skyline Caterers (P) Ltd. Vs. ITO (2008) 116 ITD 348 (Mum-Trib). 11. We have heard the rival contentions and perused the record. The first issue which is raised in the present appeal is against claim of depreciation on payment made for acquiring right to render BPO services to Cummins Inc, USA. The assessee during the year under consideration had entered into tripartite Ltd. on one hand and the as…