Reliance Infrastructure Ltd. v. CIT

390 ITR 271High Court2017#3563 most cited

What is Reliance Infrastructure Ltd. v. CIT authority for?

State tax paid in a foreign country is not allowable as a deduction when computing total world income. Foreign tax credit can be claimed only as per the prescribed procedure, not as an expenditure.

34

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

Reliance Infrastructure Ltd v CIT · foreign tax · state tax deduction · total world income · section 91 · foreign tax credit · expenditure · Bombay High Court

Also reported as

76 Taxmann.com 257

Sections most often in play

Section 10AASection 143(3)Section 234BSection 250Section 37(1)Section 90Section 91Section 144B

Issues it is cited on

section 10(4)section 2(43)section 115wasection 90(1)(b)section 115wsection 90(1)foreign tax creditsection 91section 40(a)(ii)real income theorysection 90acomputer software

Judgments citing Reliance Infrastructure Ltd. v. CIT

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

ITA 245/BANG/2024[2019-20]Status: DisposedITAT Bangalore06 Aug 2025AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt. Srinandini Das – CIT - DR
Section 1Section 10ASection 155Section 250

…ITA No.881/Bang/2023 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year: 2019-20 Infosys Limited Dy. Commissioner of Income Tax Plot 44, Konappana Agrahara Circle – 3(1)(1) Hosur Road, Konappana BMTC Building, 80 Feet Road Bangalore – 560100 Vs. Koramangala, Bangalore – 560095 Karnataka Karnataka PAN: AAACI4798L APPELLANT RESPONDENT Assessment Year: 2019-20 Jt. Commissioner of Income Tax (OSD) Infosys Limited Circle – 3(1)(1) Plot 44, Konappana Agrahara Room NO. 241, 2nd Floor Hosur Road…

INFOSYS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is also allowed for statistical purposes

ITA 1532/BANG/2024[2021-22]Status: DisposedITAT Bangalore06 Aug 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt Srinandini Das – CIT - DR
Section 10ASection 143(3)Section 234BSection 250

…ITA Nos.1531 & 1532/Bang/2024 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1531 & 1532/Bang/2024 Assessment Years: 2020-21 & 2021-22 Infosys Limited Dy. Commissioner of Income Tax Plot 44, Konappana Agrahara Circle – 3(1)(1) Hosur Road, Konappana BMTC Building, 80 Feet Road Bangalore – 560100 Vs. Koramangala, Bangalore – 560095 Karnataka Karnataka PAN: AAACI4798L APPELLANT RESPONDENT Assessee by : Sri Padam Chand Khincha – CA Department by : Smt Srinandini Das – CIT - DR Date of Hearing…

INFOSYS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

Accordingly, the appeal filed by the assessee is also allowed for statistical purposes

ITA 1531/BANG/2024[2020-21]Status: DisposedITAT Bangalore06 Aug 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt Srinandini Das – CIT - DR
Section 10ASection 143(3)Section 234BSection 250

…ITA Nos.1531 & 1532/Bang/2024 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER ITA Nos.1531 & 1532/Bang/2024 Assessment Years: 2020-21 & 2021-22 Infosys Limited Dy. Commissioner of Income Tax Plot 44, Konappana Agrahara Circle – 3(1)(1) Hosur Road, Konappana BMTC Building, 80 Feet Road Bangalore – 560100 Vs. Koramangala, Bangalore – 560095 Karnataka Karnataka PAN: AAACI4798L APPELLANT RESPONDENT Assessee by : Sri Padam Chand Khincha – CA Department by : Smt Srinandini Das – CIT - DR Date of Hearing…

INFOSYS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 1530/BANG/2024[2013-14]Status: DisposedITAT Bangalore06 Aug 2025AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2013-14

For Appellant: Sri Padam Chand Khincha – CAFor Respondent: Smt Srinandini Das – CIT - DR
Section 10ASection 143(3)Section 250Section 254Section 80A(5)

…ITA No.1530/Bang/2024 Infosys Limited IN THE INCOME TAX APPELLATE TRIBUNAL “A’’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI KESHAV DUBEY, JUDICIAL MEMBER Assessment Year : 2013-14 Infosys Limited Dy. Commissioner of Income Tax Plot 44, Konappana Agrahara Circle – 3(1)(1) Hosur Road, Konappana BMTC Building, 80 Feet Road Bangalore – 560100 Vs. Koramangala, Bangalore – 560095 Karnataka Karnataka PAN: AAACI4798L APPELLANT RESPONDENT Assessee by : Sri Padam Chand Khincha – CA Department by : Smt Srinandini Das – CIT - DR Date of Hearing : 09.05.2025 Date of Pronouncement : 06.08.2025 O…

BOSCH GLOBAL SOFTWARE TECHNOLOGIES PRIVATE LIMITED ,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

ITA 1696/BANG/2024[2016-17]Status: DisposedITAT Bangalore16 Apr 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

For Appellant: and Smt. Pratibha R – AdvocateFor Respondent: Smt. Nandini Das, CIT
Section 10ASection 32(1)(iia)

…assessee is in appeal before us. 27. The learned AR before us contended that the state tax paid in a foreign country is allowable deduction by virtue of the order of Hon’ble Bombay High Court in the case of Reliance Infrastructure Limited Vs. CIT reported in 390 ITR 271 and Bombay Tribunal in the case of Bank of India Vs. ACIT reported in 125 Taxmann.com 155. 28. On the other hand, the learned DR before us vehemently supported the order of the authorities below. 29. We have heard the rival contentions of both the parties and perused the materials available on record. From the material available on record, we no…

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE ACIT(OSD) CIRCLE-8, AHMEDABAD

In the result the appeal filed by the Assessee in ITA No

ITA 1621/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2008-09

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 90

…h the assessee has not been granted any tax credit. The Tribunal following decision of Hon'ble Bombay High I.T.A No. 1517 & 1621/Ahd/2019 A.Y.. 2008-09 Page No 13 DCIT Vs. Suzlon Energy Ltd. Court, in the case of Reliance Infrastructure Ltd. v. CIT reported 390 ITR 271 and allowed in favour of the assessee. 11.2. Further the Appellate Tribunal in the case of Bank of India also distinguished the decision rendered in the case of DCIT -Vs- Elitecore Technologies (P.) Ltd. 165 ITD 153(Ahd.), based on which the CIT(A) had given the directions in the impugned order against which the Assessee is in appeal before this…

THE DCIT, CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD., AHMEDABAD

In the result the appeal filed by the Assessee in ITA No

ITA 1517/AHD/2019[2008-09]Status: DisposedITAT Ahmedabad29 Oct 2024AY 2008-09

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 90

…h the assessee has not been granted any tax credit. The Tribunal following decision of Hon'ble Bombay High I.T.A No. 1517 & 1621/Ahd/2019 A.Y.. 2008-09 Page No 13 DCIT Vs. Suzlon Energy Ltd. Court, in the case of Reliance Infrastructure Ltd. v. CIT reported 390 ITR 271 and allowed in favour of the assessee. 11.2. Further the Appellate Tribunal in the case of Bank of India also distinguished the decision rendered in the case of DCIT -Vs- Elitecore Technologies (P.) Ltd. 165 ITD 153(Ahd.), based on which the CIT(A) had given the directions in the impugned order against which the Assessee is in appeal before this…

M/S WIPRO LIMITED ,BNAGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-7 , BANGALORE

ITA 3115/BANG/2018[2014-15]Status: DisposedITAT Bangalore13 Jun 2024AY 2014-15
For Appellant: Sri Dhyan Chinnappa, Sr. A.R. and Sri Sandeep Huilgol, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 37(1)Section 90Section 90(1)(b)Section 91

…ity arising in Australia over above the liability in the branch tax return 18.4 We notice that the above said claim of the assessee finds support from the decision rendered by Hon'ble Bombay High Court in the case of Reliance Infrastructure Ltd vs. CIT (2016)(390 ITR 271)(Bom). The relevant discussions made by Hon'ble Bombay High Court are extracted below:- “(j) This Court in S. Inder Singh Gill (supra) was required to answer the question whether for the purpose of computing total world income of the assessee as defined in Section 2(15) of the I. T. Act, the income accruing in Uganda has to be reduced by the tax…

M/S. WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX,CIRCLE-7(1)(2), BANGALORE

ITA 492/BANG/2017[2012-13]Status: DisposedITAT Bangalore13 Jun 2024AY 2012-13
For Appellant: Sri Dhyan Chinnappa, Sr. A.R. andFor Respondent: Ms. Neera Malhotra, D.R
Section 37(1)Section 90Section 91

…rising in Australia over above the liability in the branch tax\nreturn\n18.4\nWe notice that the above said claim of the assessee finds support\nfrom the decision rendered by Hon'ble Bombay High Court in the case\nof Reliance Infrastructure Ltd vs. CIT (2016)(390 ITR 271)(Bom). The\nrelevant discussions made by Hon'ble Bombay High Court are extracted\nbelow:-\n“(j) This Court in S. Inder Singh Gill (supra) was required to answer the\nquestion whether for the purpose of computing total world income of the\nassessee as defined in Section 2(15) of the I. T. Act, the income accruing\nin Uganda has to be reduced by th…

M/S WIPRO LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

ITA 2851/BANG/2017[2013-14]Status: DisposedITAT Bangalore13 Jun 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubeyit(Tp)A No.99/Bang/2014

For Appellant: Sri Dhyan Chinnappa, Sr. A.R. andFor Respondent: Ms. Neera Malhotra, D.R
Section 37(1)Section 90Section 90(1)(b)Section 91

…e case of Reliance ==End of OCR for page 11== IT(TP)A No.99/Bang/2014, IT(TP)A NO.398/Bang/2015, IT(TP)A No.222/Bang/2016, IT(TP)A Nos.492 & 2851/Bamg/2017 & IT(TP)A No.3115 of 2018 M/s. Wipro Limited, Bangalore Page 12 of 43 Infrastructure Ltd vs. CIT (2016)(390 ITR 271)(Bom). The relevant discussions made by Hon'ble Bombay High Court are extracted below:- “(j) This Court in S. Inder Singh Gill (supra) was required to answer the question whether for the purpose of computing total world income of the assessee as defined in Section 2(15) of the I. T. Act, the income accruing in Uganda has to be reduced by the tax…

SONY PICTUES NETORKS INDIA P. LTD.,MUMBAI vs. ADDL/JT/DY/ASSTT/CIT/ITO, NATIONAL E-ASSESSMENT CENTRE DELHI (NOW KNOWN AS NATIONAL FACELESS ASSESSMENT CENTRE), DELHI

In the result, both the appeals of the assessee are treated as allowed

ITA 925/MUM/2021[2016-17]Status: DisposedITAT Mumbai02 May 2024AY 2016-17

Bench: Justice (Retd.) C V Bhadang, Hon’Ble& Shri B.R. Baskaran: A.Y : 2015-16 : A.Y : 2016-17

For Appellant: Shri Percy Pardiwala with Shri Nitesh Joshi &For Respondent: Shri Salil Mishra – CIT-DR
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, HON’BLE PRESIDENT& SHRI B.R. BASKARAN, ACCOUNTANT MEMBER : A.Y : 2015-16 : A.Y : 2016-17 Culver Max Entertainment Private Vs. Assistant Commissioner of Limited. Income Tax, Circle -13(2)(2), (formerly known as Sony Pictures Mumbai/ Networks India Private Limited. National Faceless Assessment Interface Building 7, 4th Floor, Centre, Delhi. Off Malad Link Road, Malad (West) (Respondent) Mumbai – 400 064. PAN :AABCS-1728-D (Appellant) Appellant by : Shri Percy Pardiwala with Shri Nitesh Joshi & Ms. Mansi Chheda Res…

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BANGALORE vs. ONMOBILE GLOBAL LIMITED, BENGALURU

In the result, the appeals filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 254/BANG/2023[2012-13]Status: DisposedITAT Bangalore22 Dec 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 245/Bang/2023 Assessment Year : 2012-13 M/S. Onmobile Global Ltd., Tower #1, 94/1C & 94/2, The Deputy Veerasandra Village, Commissioner Attibele Hobli, Of Income Tax, Anekal Taluk, Circle – 5(1)(2), Electronic City Phase – 1, Vs. Bangalore. Bangalore – 560 100. Pan: Aaaco3900E Appellant Respondent & Assessment Year : 2012-13 M/S. Onmobile Global Ltd., Tower #1, 94/1C & The Deputy 94/2, Commissioner Of Veerasandra Village, Income Tax, Attibele Hobli, Central Circle – 1(2), Anekal Taluk, Bangalore. Vs. Electronic City Phase – 1, Bangalore – 560 100. Pan: Aaaco3900E Appellant Respondent : Shri T. Suryanarayana, Assessee By Senior Advocate Revenue By : Shri D.K. Mishra, Cit-Dr

For Respondent: Shri T. Suryanarayana
Section 271(1)(c)Section 92(3)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 245/Bang/2023 Assessment Year : 2012-13 M/s. OnMobile Global Ltd., Tower #1, 94/1C and 94/2, The Deputy Veerasandra Village, Commissioner Attibele Hobli, of Income Tax, Anekal Taluk, Circle – 5(1)(2), Electronic city Phase – 1, Vs. Bangalore. Bangalore – 560 100. PAN: AAACO3900E APPELLANT RESPONDENT & Assessment Year : 2012-13 M/s. OnMobile Global Ltd., Tower #1, 94/1C and The Deputy 94/2, Commissioner of Veerasandra Village, Income Tax, Attibele Hobli, Centr…

ONMOBILE GLOBAL LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-5(1)(2), BANGALORE

In the result, the appeals filed by the assessee as well as revenue stands partly allowed for statistical purposes

ITA 245/BANG/2023[2013-13]Status: DisposedITAT Bangalore22 Dec 2023AY 2013-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 245/Bang/2023 Assessment Year : 2012-13 M/S. Onmobile Global Ltd., Tower #1, 94/1C & 94/2, The Deputy Veerasandra Village, Commissioner Attibele Hobli, Of Income Tax, Anekal Taluk, Circle – 5(1)(2), Electronic City Phase – 1, Vs. Bangalore. Bangalore – 560 100. Pan: Aaaco3900E Appellant Respondent & Assessment Year : 2012-13 M/S. Onmobile Global Ltd., Tower #1, 94/1C & The Deputy 94/2, Commissioner Of Veerasandra Village, Income Tax, Attibele Hobli, Central Circle – 1(2), Anekal Taluk, Bangalore. Vs. Electronic City Phase – 1, Bangalore – 560 100. Pan: Aaaco3900E Appellant Respondent : Shri T. Suryanarayana, Assessee By Senior Advocate Revenue By : Shri D.K. Mishra, Cit-Dr

For Respondent: Shri T. Suryanarayana
Section 271(1)(c)Section 92(3)Section 92C

…IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH : BANGALORE BEFORE SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER AND SMT. BEENA PILLAI, JUDICIAL MEMBER IT(TP)A No. 245/Bang/2023 Assessment Year : 2012-13 M/s. OnMobile Global Ltd., Tower #1, 94/1C and 94/2, The Deputy Veerasandra Village, Commissioner Attibele Hobli, of Income Tax, Anekal Taluk, Circle – 5(1)(2), Electronic city Phase – 1, Vs. Bangalore. Bangalore – 560 100. PAN: AAACO3900E APPELLANT RESPONDENT & Assessment Year : 2012-13 M/s. OnMobile Global Ltd., Tower #1, 94/1C and The Deputy 94/2, Commissioner of Veerasandra Village, Income Tax, Attibele Hobli, Centr…

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

ITA 370/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Jun 2023AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

For Appellant: Shri Sandeep Huilgol, AdvocateFor Respondent: Dr. Manjunath Karkihallli, CIT(DR)(ITAT), Bengaluru
Section 10ASection 143(2)Section 143(3)Section 80G

…ity arising in Australia over above the liability in the branch tax return 18.4 We notice that the above said claim of the assessee finds support from the decision rendered by Hon’ble Bombay High Court in the case of Reliance Infrastructure Ltd vs. CIT (2016)(390 ITR 271)(Bom). The relevant discussions made by Hon’ble Bombay High Court are extracted below:- “(j) This Court in S. Inder Singh Gill (supra) was required to answer the question whether for the purpose of computing total world income of the assessee as defined in Section 2(15) of the I. T. Act, the income accruing in Uganda has to be reduced by the tax…

ACC LIMITED (FORMERLY KNOWN AS THE ASSOCIATED CEMENT COMPANIES LTD.),MUMBAI vs. ACIT - LTU, MUMBAI

ITA 417/MUM/2014[2006-07]Status: DisposedITAT Mumbai28 Feb 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Range 1(1) (Formerly Known As The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) M/S. Acc Limited V. Asst. Cit-Ltu (Formerly Known As The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Acit – Ltu V. M/S. Acc Limited 28Th Floor, Centre-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai - 400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 145ASection 251Section 44A

…d that issue is covered in favour of assessee by decision of Hon’ble Bombay High court and Karnataka High court referred herein below: (i) Wipro Limited v. DCIT [IT(TP)A No. 2556 of 2019 (Bangalore Tribunal)] (ii) Reliance Infrastructure Ltd. V. CIT [ (2016) 390 ITR 271 (Bom HC)] (iii) Wipro Ltd. v. DCIT (382 ITR 179 (Karnataka) (iv) Bank of India v. ACIT [ITA No.869 of 2018 dated March 04, 2021 (Mumbai Tribunal)] 147. On the other hand, Ld DR has argued that Assessing Officer was correct in making addition u/s 115JB of the Act and in support of her claim, she relied upon decision of AAR v. New Delhi Bank of In…

ADDL CIT RG 1(1), MUMBAI vs. ACC LTD, MUMBAI

ITA 5692/MUM/2011[2006-07]Status: DisposedITAT Mumbai28 Feb 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Range 1(1) (Formerly Known As The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) M/S. Acc Limited V. Asst. Cit-Ltu (Formerly Known As The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Acit – Ltu V. M/S. Acc Limited 28Th Floor, Centre-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai - 400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 145ASection 251Section 44A

…d that issue is covered in favour of assessee by decision of Hon’ble Bombay High court and Karnataka High court referred herein below: (i) Wipro Limited v. DCIT [IT(TP)A No. 2556 of 2019 (Bangalore Tribunal)] (ii) Reliance Infrastructure Ltd. V. CIT [ (2016) 390 ITR 271 (Bom HC)] (iii) Wipro Ltd. v. DCIT (382 ITR 179 (Karnataka) (iv) Bank of India v. ACIT [ITA No.869 of 2018 dated March 04, 2021 (Mumbai Tribunal)] 147. On the other hand, Ld DR has argued that Assessing Officer was correct in making addition u/s 115JB of the Act and in support of her claim, she relied upon decision of AAR v. New Delhi Bank of In…

ACC LTD ( FORMERLY KNOWN AS THE ASSOCIATED CEMENT COMPANIES LTD),MUMBAI vs. ADDL CIT RG 1(1), MUMBAI

ITA 5655/MUM/2011[2006-07]Status: DisposedITAT Mumbai28 Feb 2023AY 2006-07

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Acc Limited V. Addl. Cit -Range 1(1) (Formerly Known As The Associated Cement Mumbai Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) M/S. Acc Limited V. Asst. Cit-Ltu (Formerly Known As The Associated Mumbai Cement Companies Ltd.) Cement House, 121, M.K. Road Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent) Acit – Ltu V. M/S. Acc Limited 28Th Floor, Centre-1 (Formerly Known As The Associated Cement Companies Ltd.) World Trade Centre, Cuffe Parade Cement House, 121, M.K. Road Mumbai - 400005 Churchgate, Mumbai-400020 Pan: Aaact1507C (Appellant) (Respondent)

Section 143(3)Section 145ASection 251Section 44A

…d that issue is covered in favour of assessee by decision of Hon’ble Bombay High court and Karnataka High court referred herein below: (i) Wipro Limited v. DCIT [IT(TP)A No. 2556 of 2019 (Bangalore Tribunal)] (ii) Reliance Infrastructure Ltd. V. CIT [ (2016) 390 ITR 271 (Bom HC)] (iii) Wipro Ltd. v. DCIT (382 ITR 179 (Karnataka) (iv) Bank of India v. ACIT [ITA No.869 of 2018 dated March 04, 2021 (Mumbai Tribunal)] 147. On the other hand, Ld DR has argued that Assessing Officer was correct in making addition u/s 115JB of the Act and in support of her claim, she relied upon decision of AAR v. New Delhi Bank of In…

ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE -11,, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED , (FORMERLY IGATE GLOBAL SOLUTIONS LTD.),, PUNE

In the result, both the appeals are partly allowed

ITA 1935/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2022AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

Section 10ASection 115JSection 391Section 72ASection 74

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “C”, PUNE BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER आयकर अपील सं. / ITA No.1857/PUN/2017 "नधा"रण वष" / Assessment Year : 2013-14 Capgemini Technology Services India Limited Vs. DCIT, Circle-11, (earlier known as iGATE Global Solutions Pune Ltd.) Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase-III, MIDC-SEZ, Village Man, Taluka Mulshi, Pune – 411057 PAN: AABCM4573E Appellant Respondent आयकर अपील सं. / ITA No.1935/PUN/2017 "नधा"रण वष" / Assessment Year : 2013-14 ACIT, Circle-11, Vs. Capgemini Technology Services…

CAPGEMINI TECHNOLOGY SERVICES INDIA LTD,,PUNE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 11,, PUNE

In the result, both the appeals are partly allowed

ITA 1857/PUN/2017[2013-14]Status: DisposedITAT Pune30 Aug 2022AY 2013-14

Bench: Shri R.S. Syal & Shri Partha Sarathi Chaudhury

Section 10ASection 115JSection 391Section 72ASection 74

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “C”, PUNE BEFORE SHRI R.S. SYAL, VICE PRESIDENT AND SHRI PARTHA SARATHI CHAUDHURY, JUDICIAL MEMBER आयकर अपील सं. / ITA No.1857/PUN/2017 "नधा"रण वष" / Assessment Year : 2013-14 Capgemini Technology Services India Limited Vs. DCIT, Circle-11, (earlier known as iGATE Global Solutions Pune Ltd.) Plot No.14, Rajiv Gandhi Infotech Park, Hinjewadi, Phase-III, MIDC-SEZ, Village Man, Taluka Mulshi, Pune – 411057 PAN: AABCM4573E Appellant Respondent आयकर अपील सं. / ITA No.1935/PUN/2017 "नधा"रण वष" / Assessment Year : 2013-14 ACIT, Circle-11, Vs. Capgemini Technology Services…

M/S. ONMOBILE GLOBAL LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 5(1)(2), BENGALURU

In the result, both these appeals are partly allowed

ITA 2560/BANG/2019[2015-16]Status: DisposedITAT Bangalore10 Aug 2022AY 2015-16

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 14ASection 234BSection 244ASection 32

…IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND Ms. PADMAVATHY S, ACCOUNTANT MEMBER IT(TP)A Nos.139 & 2560/Bang/2019 Assessment years : 2014-15 & 2015-16 Onmobile Global Ltd., Vs. The Asstt./Deputy Tower # 1, 94/1C & 94/2, Commissioner of Income Tax, Veerasandra Village, Attibele Hobli, Circle 5(1)(2), Anekal Taluk, Electronics City, Bengaluru. Phase 1, Bengaluru – 560 100. PAN: AAACO 3900E ASSESSEE RESPONDENT Assessee by : Shri T. Suryanarayana, Advocate Respondent by : Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru. Date of hearing : 27.07.20…

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