Wipro Ltd. v. DCIT

382 ITR 179High Court2016#866 most cited

What is Wipro Ltd. v. DCIT authority for?

Foreign Tax Credit (FTC) is allowable even if no tax is paid in India on the corresponding income due to deductions under sections 10A or 10AA, or losses in other units. The scope of income eligible for deduction under Section 10AA includes interest on deposits and realized gains on forward contracts.

122

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2026.

Also referred to as

Wipro Ltd. v. DCIT · 382 ITR 179 · 62 Taxmann.com 26 · Foreign Tax Credit · FTC · Section 90 · Section 91 · DTAA · Section 10A · Section 10AA · non-taxable income · deduction eligibility

Also reported as

62 Taxmann.com 26

Sections most often in play

Section 143(3)Section 90Section 91Section 10ASection 234BSection 10AASection 115JBSection 244A

Issues it is cited on

free trade zonestpi unitsection 80ia(8)foreign tax creditsection 28(i)section 90(1)section 10aasection 91section 10acomputer softwaresection 80hhsection 80h

Judgments citing Wipro Ltd. v. DCIT

HCL TECHNOLOGIES LTD.,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5465/DEL/2011[2007-08]Status: DisposedITAT Delhi15 Apr 2026AY 2007-08

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

…31.05.2016 and submitted that AO ought to have allowed Foreign Tax Credit of Rs.17,42,40,152 (including enhanced claim to the extent of Rs.15,20,58,506) in pursuance to law clarified by the Hon’ble Karnataka High Court in the case of Wipro Ltd vs DCIT: [2015] 382 ITR 179 (Kar). The assessee also filed additional evidences in terms of Rule 29 of the IT(AT) Rules, 1962 on 09.06.2016. 13.1 This claim was raised for the first time by the assessee by way of an objection before the DRP to the effect that foreign tax credit should be allowed to the assessee as permissible under Section 90 of the Income Tax Act, 1961 as…

HCL TECHNOLOGIES LTD,NEW DELHI vs. ACIT, NEW DELHI

The appeal is allowed as indicated above

ITA 5624/DEL/2010[2006-07]Status: DisposedITAT Delhi15 Apr 2026AY 2006-07

Bench: Shri Vikas Awasthy & Shri Brajesh Kumar Singh

Section 10ASection 143Section 144Section 144C(13)

…31.05.2016 and submitted that AO ought to have allowed Foreign Tax Credit of Rs.17,42,40,152 (including enhanced claim to the extent of Rs.15,20,58,506) in pursuance to law clarified by the Hon’ble Karnataka High Court in the case of Wipro Ltd vs DCIT: [2015] 382 ITR 179 (Kar). The assessee also filed additional evidences in terms of Rule 29 of the IT(AT) Rules, 1962 on 09.06.2016. 13.1 This claim was raised for the first time by the assessee by way of an objection before the DRP to the effect that foreign tax credit should be allowed to the assessee as permissible under Section 90 of the Income Tax Act, 1961 as…

DCIT CIRCLE 4(2), NEW DELHI vs. CANON INDIA PVT. LTD., NEW DELHI

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

…the AO. 41. At the time of hearing, it was agreed that the issue with regard to claiming FTC is no longer res integra and has been settled by the Hon'ble Karnataka High Court in the case of Wipro Ltd. v. Dy. CIT[2015] 62 taxmann.com 26/[2016] 236 Taxman 209/382 ITR 179 (Karn.).***** 42. The fact that the Assessee suffered loss in Non-SEZ unit and therefore the claim for FTC cannot be allowed cannot be accepted as taxability is not the criteria to deny FTC. Thus ground No. 8 is allowed." b) M/s Uniparts India Ltd. Vs. CIT (2018-TII-274-ITAT-DEL-INTL): In this case, a consolidated order was passed by Hon'ble Delh…

CANON INDIA PVT. LTD,GURUGRAM vs. NEAC, DELHI

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

…the AO. 41. At the time of hearing, it was agreed that the issue with regard to claiming FTC is no longer res integra and has been settled by the Hon'ble Karnataka High Court in the case of Wipro Ltd. v. Dy. CIT[2015] 62 taxmann.com 26/[2016] 236 Taxman 209/382 ITR 179 (Karn.).***** 42. The fact that the Assessee suffered loss in Non-SEZ unit and therefore the claim for FTC cannot be allowed cannot be accepted as taxability is not the criteria to deny FTC. Thus ground No. 8 is allowed." b) M/s Uniparts India Ltd. Vs. CIT (2018-TII-274-ITAT-DEL-INTL): In this case, a consolidated order was passed by Hon'ble Delh…

SAUMITRA KUMAR, LUCKNOW,UTTAR PRADESH vs. DCIT CIRCLE 12, PUNE, MAHARASHTRA

In the result, the appeal filed by the assessee is allowed

ITA 1520/PUN/2025[2021-22]Status: DisposedITAT Pune14 Aug 2025AY 2021-22

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1520/Pun/2025 िनधा"रण वष" / Assessment Year : 2021-22 Saumitra Kumar, Vs. Dcit, Circle-12, Pune. Hig 111, Sector E, Aliganj, Lucknow- 226024. Pan : Bcmpk7370J Appellant Respondent Assessee By : Shri Naman Maloo (Virtual) Revenue By : Shri Amit Bobde Date Of Hearing : 23.07.2025 Date Of Pronouncement 14.08.2025 : आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 23.04.2025 Passed By Ld. Addl./Jcit(A), Indore [‘Ld. Cit(A)’] For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. In The Facts & Circumstances Of The Case, Ld. Cit(A) Has Erred In, Confirming The Action Of Ld. Ao(Cpc) In Disallowing The Credit Of Taxes Paid Outside India While Processing The Return Of Income (Foreign Tax Credit, "Ftc") Under Section 143(1) Of The Income Tax Act, 1961. Such Rejection Is Beyond The Purview Of Section 143(1). The Action Of The Ld. Cit(A) Is Illegal & Arbitrary & Against The Facts Of The Case. Relief May Please

For Appellant: Shri Naman Maloo (Virtual)For Respondent: Shri Amit Bobde
Section 139Section 139(1)Section 143(1)Section 90Section 91

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY BHAMORE, JUDICIAL MEMBER आयकर अपील सं. / ITA No.1520/PUN/2025 िनधा"रण वष" / Assessment Year : 2021-22 Saumitra Kumar, Vs. DCIT, Circle-12, Pune. HIG 111, Sector E, Aliganj, Lucknow- 226024. PAN : BCMPK7370J Appellant Respondent Assessee by : Shri Naman Maloo (Virtual) Revenue by : Shri Amit Bobde Date of hearing : 23.07.2025 Date of pronouncement 14.08.2025 : आदेश / ORDER PER VINAY BHAMORE, JM: This appeal filed by the assessee is directed against the order dated 23.04.2025 passed by Ld. Addl./JCIT(A)…

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

…mann.com 182, DCIT v Motorola India Electronics P Ltd [2014] 46 taxmann.com 167, Green Agro Pack (P) Ltd v CIT in ITA No 3112/2005 dated 13.4.2010, Green Agro Pack (P) Ltd v CIT in ITA No 230/2008 dated 26.8.2014 as well as Wipro Ltd v DCIT [2016] reported in 382 ITR 179 allowed the deduction under section 10AA in respect of interest on deposits with Banks, interest on security deposits, realized gain on forward contracts and license fees comprising of rental income. 10.3 Further, the deduction under section 10AA of the Act was also allowed by the CIT(A)/NFAC in respect of other business income comprising of hos…

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

…rd Global Soft Ltd [2017] 87 taxmann.com 182, DCIT v Motorola India Electronics P Ltd [2014] 46 taxmann.com 167, Green Agro Pack P Ltd v CIT ITA No 3112/2005 dated 13.4.2010, Green Agro Pack P Ltd v CIT ITA No 230/2008 dated 26.8.2014, Wipro Ltd v DCIT [2016] 382 ITR 179 and allowed the deduction under section 10AA in respect of interest on deposits with Banks, interest on security deposits and realized gain on forward contracts. The Revenue has not challenged the above reliefs allowed by the CIT(A)/NFAC before this Tribunal. ITA Nos.1531 & 1532/Bang/2024 Infosys Limited Page 6 of 16 5.7 In respect of interest…

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

…rd Global Soft Ltd [2017] 87 taxmann.com 182, DCIT v Motorola India Electronics P Ltd [2014] 46 taxmann.com 167, Green Agro Pack P Ltd v CIT ITA No 3112/2005 dated 13.4.2010, Green Agro Pack P Ltd v CIT ITA No 230/2008 dated 26.8.2014, Wipro Ltd v DCIT [2016] 382 ITR 179 and allowed the deduction under section 10AA in respect of interest on deposits with Banks, interest on security deposits and realized gain on forward contracts. The Revenue has not challenged the above reliefs allowed by the CIT(A)/NFAC before this Tribunal. ITA Nos.1531 & 1532/Bang/2024 Infosys Limited Page 6 of 16 5.7 In respect of interest…

PRINCIPAL COMMISSIONER OF INCOME TAX-7 vs. M/S TECNO TREE CONVERGENCE LTD.,

ITA/204/2022HC Karnataka20 Feb 2025

Bench: KRISHNA S DIXIT,G BASAVARAJA

Section 10A(3)Section 195Section 260Section 40

…- 1 - NC: 2025:KHC:7603-DB ITA No. 204 of 2022 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 20TH DAY OF FEBRUARY, 2025 PRESENT THE HON'BLE MR JUSTICE KRISHNA S DIXIT AND THE HON'BLE MR JUSTICE G BASAVARAJA INCOME TAX APPEAL NO.204 OF 2022 BETWEEN: 1. PRINCIPAL COMMISSIONER OF INCOME TAX-7 BMTC COMPLEX, KORAMANGALA, BENGALURU. 2. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -7(1)(1), BMTC COMPLEX, KORAMANGALA, BENGALURU. …APPELLANTS (BY SRI. E.I. SANMATHI, ADVOCATE) AND: M/S TECNO TREE CONVERGENCE LTD., 394-PHASE – IV, UDYOG VIHAR, GURGAON - 122 001.…

L & T TECHNOLOGIES SERVICES LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI

In the result, the additional grounds of the assessee are allowed for statistical purposes

ITA 4255/MUM/2023[2015-16]Status: DisposedITAT Mumbai06 Feb 2025AY 2015-16

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeel&T Technologies Services Ltd Vs Assistant Commissioner Of Income L&T House, N.M. Marg, Tax, Circle 2(2)(1), Mumbai Room No.545, 5Th Floor, Aayakar Mumbai Pan: Aaccl4310P Bhavan, Maharshi Karve Road, Mumbai-400 020 Appellant Respondent

For Appellant: Shri Nitesh JoshiFor Respondent: Dr. K.R. Subhash (CIT- DR)
Section 10ASection 143(3)Section 170Section 2Section 250Section 37Section 90

…x credit has not been allowed under section 90/91 of the Act. g. For further foreign tax in respect of the income pertaining to SEZ units eligible for deductions U/s 10A/10AA, please refer the Karnataka High Court order in case of Wipro Limited v. DCIT (2016) 382 ITR 179 (see paragrapfer34 to 66 at pages 13 to 23 of Legal paper book "Part B") and the Mumbai Bench of the Tribunal in the case of Tata Consultancy Services Ltd. v. Asst. CIT by its Order dated 30.10.2019 in ITA No. 5713/Mum/2016 (see paragraphs 39 at pages 79 to 81 of Legal paper book "Part B") have held that, considering the phraseology used in the D…

SWASTHA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

ITA 328/CTK/2023[2007-08]Status: HeardITAT Cuttack06 Jun 2024AY 2007-08

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

For Appellant: None (Adjn petition)For Respondent: Shri S.C.Mohanty, Sr
Section 11Section 12ASection 147

…purposes of profit, and which is wholly or substantially financed by the Government; or” 8. The assessee falls under all these conditions. It would be worthwhile to refer to the decision of the Hon’ble Karnataka High court in the case of Wipro Ltd., VS DCIT, 382 ITR 179 (Karnataka) at page 221 para 72, wherein, the Hon’ble High Court has gone on to hold that once the return is filed and the Income Tax Officer commences the assessment proceedings, the Assessing Officer is not the taxpayer’s opponent, in the strictly procedural sense of the term. It would also be worthwhile in such context to mention that in today…

SWASTHYA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

ITA 327/CTK/2023[2006-07]Status: HeardITAT Cuttack06 Jun 2024AY 2006-07

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

For Appellant: None (Adjn petition)For Respondent: Shri S.C.Mohanty, Sr
Section 11Section 12ASection 147

…purposes of profit, and which is wholly or substantially financed by the Government; or” 8. The assessee falls under all these conditions. It would be worthwhile to refer to the decision of the Hon’ble Karnataka High court in the case of Wipro Ltd., VS DCIT, 382 ITR 179 (Karnataka) at page 221 para 72, wherein, the Hon’ble High Court has gone on to hold that once the return is filed and the Income Tax Officer commences the assessment proceedings, the Assessing Officer is not the taxpayer’s opponent, in the strictly procedural sense of the term. It would also be worthwhile in such context to mention that in today…

SWASTHYA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

ITA 326/CTK/2023[2005-06]Status: HeardITAT Cuttack06 Jun 2024AY 2005-06

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

For Appellant: None (Adjn petition)For Respondent: Shri S.C.Mohanty, Sr
Section 11Section 12ASection 147

…purposes of profit, and which is wholly or substantially financed by the Government; or” 8. The assessee falls under all these conditions. It would be worthwhile to refer to the decision of the Hon’ble Karnataka High court in the case of Wipro Ltd., VS DCIT, 382 ITR 179 (Karnataka) at page 221 para 72, wherein, the Hon’ble High Court has gone on to hold that once the return is filed and the Income Tax Officer commences the assessment proceedings, the Assessing Officer is not the taxpayer’s opponent, in the strictly procedural sense of the term. It would also be worthwhile in such context to mention that in today…

SWASTHYA BIKASH SAMITI, SCB MEDICAL COLLEGE,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

ITA 325/CTK/2023[2004-05]Status: HeardITAT Cuttack06 Jun 2024AY 2004-05

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

For Appellant: None (Adjn petition)For Respondent: Shri S.C.Mohanty, Sr
Section 11Section 12ASection 147

…purposes of profit, and which is wholly or substantially financed by the Government; or” 8. The assessee falls under all these conditions. It would be worthwhile to refer to the decision of the Hon’ble Karnataka High court in the case of Wipro Ltd., VS DCIT, 382 ITR 179 (Karnataka) at page 221 para 72, wherein, the Hon’ble High Court has gone on to hold that once the return is filed and the Income Tax Officer commences the assessment proceedings, the Assessing Officer is not the taxpayer’s opponent, in the strictly procedural sense of the term. It would also be worthwhile in such context to mention that in today…

SWASTHYA BIKASH SAMITI SCB MIDICAL COLLEGE HOSPITAL,CUTTACK vs. ITO(EXEMPTION), CUTTACK

In the result appeal of the assessee allowed

ITA 324/CTK/2023[2003-04]Status: HeardITAT Cuttack06 Jun 2024AY 2003-04

Bench: Before Shri George Mathan, Judicial & Manish Agarwal Manish Agarwalita Nos.324 To 328/Ctk/20 /Ctk/2023 Assessment Years : 2003-04 To 2007 04 To 2007-08 Swasthya Swasthya Bikash Bikash Samity, Samity, Vs. Ito (Exemption), Ito (Exemption), Scb Cb Medical Medical College College Aayakar Bhavan, Cuttack Aayakar Bhavan, Cuttack Hospital,Mangalabag, Hospital,Mangalabag, Cuttack Pan/Gir No Pan/Gir No.Aaeas 5600 H (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : None (Adjn Petition) : None (Adjn Petition) Revenue By : Shri S.C.Mohanty, Sr : Shri S.C.Mohanty, Sr Dr Date Of Hearing : 06/0 06/2024 Date Of Pronouncement : 06/0 /06/2024 O R D E R Per Bench

For Appellant: None (Adjn petition)For Respondent: Shri S.C.Mohanty, Sr
Section 11Section 12ASection 147

…purposes of profit, and which is wholly or substantially financed by the Government; or” 8. The assessee falls under all these conditions. It would be worthwhile to refer to the decision of the Hon’ble Karnataka High court in the case of Wipro Ltd., VS DCIT, 382 ITR 179 (Karnataka) at page 221 para 72, wherein, the Hon’ble High Court has gone on to hold that once the return is filed and the Income Tax Officer commences the assessment proceedings, the Assessing Officer is not the taxpayer’s opponent, in the strictly procedural sense of the term. It would also be worthwhile in such context to mention that in today…

A.T. KEARNEY LIMITED ,GURGAON vs. ACIT, CIRCLE INT. TAX 1(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 498/DEL/2022[2017-18]Status: DisposedITAT Delhi11 Mar 2024AY 2017-18

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)

…Tax Credit [FTC]. 12. The contention of the assessee is that the Assessing Officer has not allowed complete credit of foreign taxes paid by the assessee by completely disregarding the decision of the Hon'ble Karnataka High Court in the case of Wipro Limited 62 Taxmann.com 26. 11 13. Though the ld. DR vehemently stated that due to divergent views, this quarrel has been referred to the Special Bench of the Tribunal. But we find that the Hon'ble Jurisdiction High Court of Delhi in the case of HCL Comnet Systems And Services Ltd ITA 546/2022 order dated 23.11.2023 has decided the issue in favour of the assessee. Th…

A.T KEARNEY LTD -INDIA,GURUGRAM vs. ACIT, CIRCLE INTERNATIONAL TAXATION 1(1)(1), NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 2257/DEL/2022[2018-19]Status: DisposedITAT Delhi11 Mar 2024AY 2018-19

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT-DR
Section 143(3)

…Tax Credit [FTC]. 12. The contention of the assessee is that the Assessing Officer has not allowed complete credit of foreign taxes paid by the assessee by completely disregarding the decision of the Hon'ble Karnataka High Court in the case of Wipro Limited 62 Taxmann.com 26. 11 13. Though the ld. DR vehemently stated that due to divergent views, this quarrel has been referred to the Special Bench of the Tribunal. But we find that the Hon'ble Jurisdiction High Court of Delhi in the case of HCL Comnet Systems And Services Ltd ITA 546/2022 order dated 23.11.2023 has decided the issue in favour of the assessee. Th…

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

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

ITA 1152/BANG/2023[2018-19]Status: DisposedITAT Bangalore28 Feb 2024AY 2018-19

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri Subramanian .S, JCIT DR
Section 10ASection 10A(9)Section 250

…No. 7299/Mum/2017 dated 10.11.2020 ITAT Mumbai b) Zandu Pharmaceuticals Works Ltd. vs. CIT reported in (2013) 31 taxmann.com 191 (Bombay) c) CIT vs. Hindustan Lever Ltd. reported in (2014) 42 taxmann.com 132 (Madras) d) Wipro Ltd. vs. DCIT reported in (2016) 382 ITR 179 (Karnataka) e) CIT vs. Wipro Ltd. in ITA No. 507 of 2002 dated 25.08.2010- Karnataka High Court f) CIT vs. Gokaldas Images Pvt. Ltd. reported in (2020) TaxCorp DT 83685 (Karnataka) 6. The Ld.DR relied on the orders of the lower authorities. Page 5 of 39 7. Considering the rival submissions, we note that allocation of common expenses has been de…

DCIT- 3(4) , MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

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

ITA 2588/MUM/2022[2018-19]Status: DisposedITAT Mumbai18 Oct 2023AY 2018-19

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

…THE INCOME TAX APPELLATE TRIBUNAL “J” Bench, Mumbai Before Shri B.R. Baskaran (AM) & Shri Pavan Kumar Gadale (JM) I.T.A. No. 2587 & 2588/Mum/2022 (Assessment Year : 2017-18 & 2018-19) DCIT-3(4) M/s. Reliance Industries Ltd. 29th floor, Centre-1 Vs. 3rd Floor, Maker Chambers World Trade Centre IV, 222, Nariman Point Cuffe Parade Mumbai-400 021. Mumbai-400 005. (Appellant) (Respondent) I.T.A. No. 2318 & 2317/Mum/2022 (Assessment Year : 2017-18 & 2018-19) & C.O. No. 137/Mum/2022 (Arising out of ITA No.2588/M/2022) (Assessment Year : 2018-19) M/s. Reliance Industries Ltd. DCIT-3(4) 3rd Floor, Maker Chambers Vs. 2…

DCIT-3(4), MUMBAI vs. M/S RELIANCE INDUSTRIES LIMITED, MUMBAI

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

ITA 2587/MUM/2022[2017-18]Status: DisposedITAT Mumbai18 Oct 2023AY 2017-18

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

Section 14ASection 250(6)Section 32Section 35

…THE INCOME TAX APPELLATE TRIBUNAL “J” Bench, Mumbai Before Shri B.R. Baskaran (AM) & Shri Pavan Kumar Gadale (JM) I.T.A. No. 2587 & 2588/Mum/2022 (Assessment Year : 2017-18 & 2018-19) DCIT-3(4) M/s. Reliance Industries Ltd. 29th floor, Centre-1 Vs. 3rd Floor, Maker Chambers World Trade Centre IV, 222, Nariman Point Cuffe Parade Mumbai-400 021. Mumbai-400 005. (Appellant) (Respondent) I.T.A. No. 2318 & 2317/Mum/2022 (Assessment Year : 2017-18 & 2018-19) & C.O. No. 137/Mum/2022 (Arising out of ITA No.2588/M/2022) (Assessment Year : 2018-19) M/s. Reliance Industries Ltd. DCIT-3(4) 3rd Floor, Maker Chambers Vs. 2…

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