Verizon Communications Singapore Pte Ltd. v. ITO

361 ITR 575High Court2014#630 most cited

What is Verizon Communications Singapore Pte Ltd. v. ITO authority for?

Payments for the use of equipment or copyrighted articles constitute royalty income under section 9(1)(vi) of the Income-tax Act, necessitating TDS deduction under section 195 and attracting disallowance under section 40(a)(i) for non-compliance.

156

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2013 to 2025.

Also referred to as

Verizon Communications Singapore · 361 ITR 575 · Madras High Court · Section 9(1)(vi) · royalty income · use of equipment · copyrighted article · TDS liability · Section 195 · Section 40(a)(i) disallowance · international taxation

Sections most often in play

Section 143(3)Section 195Section 9(1)(vi)Section 144C(13)Section 1957Section 201Section 201(1A)Section 14(a)/(b) of the Copyright Act

Issues it is cited on

section 9(l)(vi)section 9(l)use of equipmentsection 14(a)section 90(2)copyrighted articlesection 9(1)(vi)retrospective amendmentsection 52section 91clarificatory amendmentsection 9(1)

Judgments citing Verizon Communications Singapore Pte Ltd. v. ITO

Deputy Commissioner of Income-Tax, Bangalore vs. M/S. Wipro Ltd, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2337/BANG/2016[2010-11]Status: DisposedITAT Bangalore21 Jun 2019AY 2010-11

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

Deputy Commissioner of Income-Tax, Bangalore vs. M/S. Wipro Ltd, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2336/BANG/2016[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

Deputy Commissioner of Income-Tax, Bangalore vs. M/S. Wipro Ltd, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2335/BANG/2016[2008-09]Status: DisposedITAT Bangalore21 Jun 2019AY 2008-09

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

Deputy Commissioner of Income-Tax, Bangalore vs. M/S. Wipro Ltd, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 2328/BANG/2016[2007-08]Status: DisposedITAT Bangalore21 Jun 2019AY 2007-08

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

M/S Wipro Ltd, Bangalore vs. Additional Commissioner of Income Tax, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1220/BANG/2014[2012-13]Status: DisposedITAT Bangalore21 Jun 2019AY 2012-13

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

M/S Wipro Ltd, Bangalore vs. Additional Commissioner of Income Tax, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1219/BANG/2014[2011-12]Status: DisposedITAT Bangalore21 Jun 2019AY 2011-12

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

M/S Wipro Ltd, Bangalore vs. Additional Commissioner of Income Tax, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1218/BANG/2014[2010-11]Status: DisposedITAT Bangalore21 Jun 2019AY 2010-11

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

M/S Wipro Ltd, Bangalore vs. Additional Commissioner of Income Tax, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1217/BANG/2014[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

M/S Wipro Ltd, Bangalore vs. Additional Commissioner of Income Tax, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1216/BANG/2014[2008-09]Status: DisposedITAT Bangalore21 Jun 2019AY 2008-09

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

M/S Wipro Ltd, Bangalore vs. Additional Commissioner of Income Tax, Bangalore

In the result, all 6 appeals filed by the revenue are dismissed

ITA 1215/BANG/2014[2007-08]Status: DisposedITAT Bangalore21 Jun 2019AY 2007-08

Bench: Shri A.K. Garodia & Shri Laliet Kumar

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

…held to be deductible …………….. “ The same has been reaffirmed by the Hon'ble Karnataka High Court in assessee's own case in ITA 879/2008 dt.25.03.2015 (mentioned supra). The decisions relied on by the Ld.DR in Verizon Communications Singapore PTE Ltd vs ITO - 361 ITR 575 MAD FTC (department paper book pages 52 to 91), CIT vs CGI Information Systems & Management Consultants (P) Ltd (226 Taxman 319 - department paper book pages 126 to 138) and Citrix Systems Asia Pacific Pvt Ltd in Re 343 ITR 1 AAR are all cases of third parties and not applicable under the impugned case for the reasons mentioned supra. The decisio…

Raskspace Us Inc, Mumbai vs. DCIT (It) 4(1)(1), Mumbai

In the result, these appeals of the assessee are allowed as indicated above

ITA 3507/MUM/2017[2014-15]Status: DisposedITAT Mumbai29 May 2019AY 2014-15

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: S/Shri PJ PardiwalaFor Respondent: S/Shri Kumar Sanjay, CIT DR &
Section 143(3)Section 144C(5)Section 9Section 9(1)(vi)

…roperty under agreement, the customer gets economic and possessory interest in such property to such extent and hence it would fall under meaning of Royalty even without the amendment as held by Madras High court in case of Verizon Communication Singapore Pte 361 ITR 575 (Mad). The High court further observed in the context of DTAA with Singapore that the definition of 'royalty' under tax treaty and the Act are in pan - materia. The provisions of Royalty under DTAA with USA are similarly worded as that of Singapore and hence the observations of Rackspace, US Inc ITAs No. 1634/Mum/2016, 3507 & 1075/Mum/2017 High c…

Rackspace, Us Inc., Mumbai vs. DCIT (It) 4(1)(1), Mumbai

In the result, these appeals of the assessee are allowed as indicated above

ITA 1075/MUM/2017[2013-14]Status: DisposedITAT Mumbai29 May 2019AY 2013-14

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: S/Shri PJ PardiwalaFor Respondent: S/Shri Kumar Sanjay, CIT DR &
Section 143(3)Section 144C(5)Section 9Section 9(1)(vi)

…roperty under agreement, the customer gets economic and possessory interest in such property to such extent and hence it would fall under meaning of Royalty even without the amendment as held by Madras High court in case of Verizon Communication Singapore Pte 361 ITR 575 (Mad). The High court further observed in the context of DTAA with Singapore that the definition of 'royalty' under tax treaty and the Act are in pan - materia. The provisions of Royalty under DTAA with USA are similarly worded as that of Singapore and hence the observations of Rackspace, US Inc ITAs No. 1634/Mum/2016, 3507 & 1075/Mum/2017 High c…

Rackspace, Us Inc, Mumbai vs. DCIT (It) 4(1)(1), Mumbai

In the result, these appeals of the assessee are allowed as indicated above

ITA 1634/MUM/2016[2012-13]Status: DisposedITAT Mumbai29 May 2019AY 2012-13

Bench: Sri Mahavir Singh, Jm & Sri Rajesh Kumar, Am

For Appellant: S/Shri PJ PardiwalaFor Respondent: S/Shri Kumar Sanjay, CIT DR &
Section 143(3)Section 144C(5)Section 9Section 9(1)(vi)

…roperty under agreement, the customer gets economic and possessory interest in such property to such extent and hence it would fall under meaning of Royalty even without the amendment as held by Madras High court in case of Verizon Communication Singapore Pte 361 ITR 575 (Mad). The High court further observed in the context of DTAA with Singapore that the definition of 'royalty' under tax treaty and the Act are in pan - materia. The provisions of Royalty under DTAA with USA are similarly worded as that of Singapore and hence the observations of Rackspace, US Inc ITAs No. 1634/Mum/2016, 3507 & 1075/Mum/2017 High c…

John Deere Eqipment P. Ltd., Pune vs. Deputy Director of Income-Tax

In the result, all the appeals of assessee are allowed

ITA 908/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

…re leased lines established between Pune office of assessee and US entity office. He pointed out that both the authorities below had relied on the ratio laid down by the Hon’ble High Court of Madras in Verizon Communications Singapore Pte. Ltd. Vs. ITO (2014) 361 ITR 575 (Mad), which goes by amended definition in the Act, but do not apply to DTAA. He then referred to the ratio laid down by Pune Bench of Tribunal in M/s. T-3 Energy Services India Pvt. Ltd. Vs. JCIT in ITA No.826/PUN/2015, relating to assessment year 2010-11, order dated 02.02.2018 and pointed out that the Tribunal has held that such payments were…

John Deere Eqipment P. Ltd., Pune vs. Deputy Director of Income-Tax

In the result, all the appeals of assessee are allowed

ITA 907/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

…re leased lines established between Pune office of assessee and US entity office. He pointed out that both the authorities below had relied on the ratio laid down by the Hon’ble High Court of Madras in Verizon Communications Singapore Pte. Ltd. Vs. ITO (2014) 361 ITR 575 (Mad), which goes by amended definition in the Act, but do not apply to DTAA. He then referred to the ratio laid down by Pune Bench of Tribunal in M/s. T-3 Energy Services India Pvt. Ltd. Vs. JCIT in ITA No.826/PUN/2015, relating to assessment year 2010-11, order dated 02.02.2018 and pointed out that the Tribunal has held that such payments were…

John Deere India Pvt. Ltd., Pune vs. Deputy Director of Income-Tax

In the result, all the appeals of assessee are allowed

ITA 906/PUN/2015[2008-09]Status: DisposedITAT Pune23 Jan 2019AY 2008-09

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

…re leased lines established between Pune office of assessee and US entity office. He pointed out that both the authorities below had relied on the ratio laid down by the Hon’ble High Court of Madras in Verizon Communications Singapore Pte. Ltd. Vs. ITO (2014) 361 ITR 575 (Mad), which goes by amended definition in the Act, but do not apply to DTAA. He then referred to the ratio laid down by Pune Bench of Tribunal in M/s. T-3 Energy Services India Pvt. Ltd. Vs. JCIT in ITA No.826/PUN/2015, relating to assessment year 2010-11, order dated 02.02.2018 and pointed out that the Tribunal has held that such payments were…

John Deere India Pvt. Ltd., Pune vs. Deputy Director of Income-Tax

In the result, all the appeals of assessee are allowed

ITA 905/PUN/2015[2007-08]Status: DisposedITAT Pune23 Jan 2019AY 2007-08

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

For Appellant: Shri Nikhil PathakFor Respondent: S/Shri Ajay Modi, Pankaj Garg and Sudhendu Das
Section 195Section 201Section 201(1)Section 9(1)(vi)

…re leased lines established between Pune office of assessee and US entity office. He pointed out that both the authorities below had relied on the ratio laid down by the Hon’ble High Court of Madras in Verizon Communications Singapore Pte. Ltd. Vs. ITO (2014) 361 ITR 575 (Mad), which goes by amended definition in the Act, but do not apply to DTAA. He then referred to the ratio laid down by Pune Bench of Tribunal in M/s. T-3 Energy Services India Pvt. Ltd. Vs. JCIT in ITA No.826/PUN/2015, relating to assessment year 2010-11, order dated 02.02.2018 and pointed out that the Tribunal has held that such payments were…

Viacom 18 Media P.Ltd, Mumbai vs. Asst DIT (It) 4(3)(1), Mumbai

In the result, all the appeals filed by the assessee stands dismissed

ITA 667/MUM/2016[2015-16]Status: DisposedITAT Mumbai09 Jul 2018AY 2015-16

Bench: Shri Shamim Yahya, Am & Shri Ravish Sood, Jm

For Respondent: Shri M. V. Rajguru
Section 195Section 248

…said decision of the Tribunal in assessee’s own case and held as under: 7.2 We note that in coming to the aforesaid decision, this Tribunal has referred the decision of Hon’ble Madras High Court in the case of Verizon Communications Singapore Private Limited 361 ITR 575. In the said decision of the Tribunal the decision of the Hon’ble Delhi High Court in the case of a Asia Satellite Communications was also considered. Thus we note that there is a decision of ITAT in assessee’s own case in which ratio from the Hon’ble Madras High Court has been followed. Now the learned Counsel of the assessee is urging us that t…

Shell Information Technology International Bv, Mumbai vs. Asst. Commissioner of Income Tax(International Taxation)-4(2)(1), Mumbai

In the result, appeal filed by the assessee for assessment year 2011-12 is partly allowed

ITA 2058/MUM/2016[2011-12]Status: DisposedITAT Mumbai28 May 2018AY 2011-12

Bench: Shri Rajendra, Am & Shri Ram Lal Negi, Jm आिकर अपील सं./Ita No. 2058/Mum/2016 (धििाारण वर्ा / Assessment Year: 2011-12) M/S Shell Information Technology Vs. The Assistant Commissioner Of International Bv, Income Tax (International C/O B S R & Co. Llp, Taxation)-4(2)(1), 1St Floor, Lodha Excelus, Scindia House, Ballard Estate, Apollo Mills Compound, N.M. Road, Mumbai - 400038 N.M. Joshi Marg, Mahalaxmi, Mumbai - 400011 स्थािी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaics9091A (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) राजस्व की ओर से / Assessee By : Shri Madhuragrawal (Ar) यनर्ावररती की ओर से /Revenue By : Shri Samuel Darse (Cit Dr) सुनर्ाई की तारीख / Date Of Hearing : 27/02/2018 घोषणा की तारीख/Date Of Pronouncement: 28/05/2018

For Appellant: Shri MadhurAgrawal (AR)For Respondent: Shri Samuel Darse (CIT DR)
Section 143(3)Section 144C(13)Section 2(24)Section 234ASection 234BSection 271(1)(c)Section 9(1)(vi)

…d as to why the said judgment of Madras High Court cannot be applied in such cases after observing as under:- "31. In a judgment by the Madras High Court in Verizon Communications Singapore Pte Ltd. V. The Income Tax Officer, International Taxation 1, /2014] 361 ITR 575 (Mad), the Court held the Explanations to be applicable to not only the domestic definition but also carried them to influence the meaning of royalty under Article 12. Notably, in both cases, the clarificatory nature of the amendment was not questioned, but was instead applied squarely to assessment years predating the amendment. The crucial diff…

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)

…आयकर अपीऱीय अधिकरण पुणे न्यायपीठ “बी” पुणे में IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE सुश्री सुषमा चावऱा, न्याययक सदस्य एवं श्री अयिऱ चतुवेदी, ऱेखा सदस्य के समक्ष BEFORE MS. SUSHMA CHOWLA, JM AND 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 अऩीऱाथी की ओर से / Appellant by : S/Shri Dhanesh Bafna and Arpitha Chouda…