Tin Box Co. v. CIT

170 TTJ 432Income Tax Appellate Tribunal2015#2726 most cited

What is Tin Box Co. v. CIT authority for?

The case establishes the scope of 'software development services' for Section 10B exemption, distinguishing validation and testing from core development. It also underscores that the Assessing Officer must provide sufficient opportunity of being heard, which cannot be cured at the appellate stage.

43

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2024 to 2025.

Also referred to as

TIBCO Software India Pvt. Ltd. · 170 TTJ 432 · Section 10B exemption · software development services · validation and testing · opportunity of being heard · natural justice · Assessing Officer · foreign bank accounts · undisclosed foreign income · Section 10B(1)(e) · Section 10B(3)

Sections most often in play

Section 10(B)(3)Section 10B(1)(e)Section 10B(3)

Issues it is cited on

undisclosed foreign income and assetssection 149(1)(c)section 4(2)section 201(3)section 158basection 150unexplained jewellerysection 70beyond four yearssection 18section 149(1)(b)statement under section 132(4)

Judgments citing Tin Box Co. v. CIT

ACIT, CIRCLE- 9(1), NEW DELHI vs. FIS GLOBAL BUSINESS SOLUTIONS INDIA PVT. LTD., NEW DELHI

In the result, the appeal of the Revenue and CO of the assessee are partly allowed as above for statistical purposes

ITA 372/DEL/2018[2009-10]Status: DisposedITAT Delhi25 Aug 2025AY 2009-10

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishra

…banking and financial institutions. Reliance was placed on the decisions in the cases of Steria (India) Ltd. [2021] 123 taxmann.com 264 (Del. Trib.), Netlink Software Pvt. Ltd. [2020] 113 taxmann.com 591 (Del. Trib.) and TIBCO Software India Pvt. Ltd. [2015] 170 TTJ 432 (Pune Trib.). 17 CO No.64/Del/2018 25. We have heard both parties and have perused the material available on the record. After careful consideration of material on the record and facts in entirety, we find force in the argument of the Ld. CIT-DR. The issue here is whether the validation and testing of software is equivalent to the software develo…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 50/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 49/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 48/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 47/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 46/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 45/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 44/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 43/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 42/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. SMT. MANJULABEN BIPINCHANDRA PATEL, BARODA

ITA 41/AHD/2020[2000-01]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2000-01

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 40/AHD/2020[2016-17]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2016-17

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 39/AHD/2020[2009-10]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2009-10

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 38/AHD/2020[2008-09]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2008-09

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 37/AHD/2020[2007-08]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2007-08

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 36/AHD/2020[2006-07]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2006-07

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 35/AHD/2020[2005-06]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2005-06

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 34/AHD/2020[2004-05]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2004-05

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 33/AHD/2020[2002-03]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2002-03

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

THE DY.CIT. CENTRAL CIRCLE-1, BARODA vs. MANJULABEN B. PATEL LEGAL HEIR OF SHRI BIPINBHAI PRABHUDAS PATEL, BARODA

ITA 32/AHD/2020[2001-02]Status: DisposedITAT Ahmedabad10 Sept 2024AY 2001-02

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinha

Section 132

…nt opportunity of being heard has to be granted before the AO and that the factum of opportunity of being granted before the appellate forum is of no consequence: i. Tin Box Co. vs. CIT, [2001] 249 ITR 216 (SC) ii. TIBCO Software India P. Ltd. Vs. DCIT [2015] 170 TTJ 432 (Pune) 23. Per Contra, Dr. Darsi Suman Ratnam, Ld. CIT.DR submitted that the AO had provided numerous opportunities to the assessee to explain the transactions in foreign bank accounts. However, the assessee never provided the required details and was in perpetual denial mode. The documents were made available to the assessee as and when request…

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