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.

How many judgments cite Wipro Ltd. v. DCIT?

122 judgments on BharatTax cite Wipro Ltd. v. DCIT (382 ITR 179), spanning 2016 to 2026.

Which sections of the Income Tax Act does Wipro Ltd. v. DCIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 90, Section 91, Section 10A, Section 234B, Section 10AA.

Wipro Ltd. v. DCIT (382 ITR 179)

Reliance Industries Limited, Mumbai vs. Dy Commissioner of Income Tax Circle-3(4), Mumbai

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

ITA 2318/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…

Reliance Industries Ltd., Mumbai vs. ACIT Circle 3(4), Mumbai

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

ITA 2317/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…

ACIT(Ltu-1), Mumbai vs. M/S. Tcs Ltd, Mumbai

ITA 5904/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10ASection 115JSection 14ASection 19Section 40Section 90(1)(a)

…1 ITA 5199/Mum/2019 ITA 5904/Mum/2019 M/s TCS Ltd IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE SHRI VIKAS AWASTHY (JUDICIAL MEMBER) AND Ms. PADMAVATHY S. (ACCOUNTANT MEMBER) I.T.A. No.5199/Mum/2019 (Assessment year: 2014-15) M/s Tata Consultancy Services vs Deputy Commissioner of Income-tax Limited, 9th Floor, Nirmal Building LTU-1, Mumbai, 29th Floor, Nariman Point, Mumbai-400 021 Centre One, World Trade Centre PAN : AAACR4849R Cuffe Parade, Mumbai-400 005 APPELLANT RESPONDENT I.T.A. No.5904/Mum/2019 (Assessment year: 2014-15) Assistant Commissioner of Income- vs M/s Tata Consultancy S…

Tata Consultancy Serrvices Limited, Mumbai vs. DCIT-1, Mumbai

ITA 5199/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Sept 2023AY 2014-15

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 10ASection 115JSection 14ASection 19Section 40Section 90(1)(a)

…1 ITA 5199/Mum/2019 ITA 5904/Mum/2019 M/s TCS Ltd IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “J”, MUMBAI BEFORE SHRI VIKAS AWASTHY (JUDICIAL MEMBER) AND Ms. PADMAVATHY S. (ACCOUNTANT MEMBER) I.T.A. No.5199/Mum/2019 (Assessment year: 2014-15) M/s Tata Consultancy Services vs Deputy Commissioner of Income-tax Limited, 9th Floor, Nirmal Building LTU-1, Mumbai, 29th Floor, Nariman Point, Mumbai-400 021 Centre One, World Trade Centre PAN : AAACR4849R Cuffe Parade, Mumbai-400 005 APPELLANT RESPONDENT I.T.A. No.5904/Mum/2019 (Assessment year: 2014-15) Assistant Commissioner of Income- vs M/s Tata Consultancy S…

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

…d considered the relevant material on record. At the outset, we note that an identical issue was also involved for the Assessment Year 2004-05 as well as for the Assessment Year 2007-08. The Hon'ble jurisdictional High Court in assessee's own case reported in 382 ITR 179 for the Assessment Year 2004-05 has upheld the decision of this Tribunal in favour of the assessee and against the revenue. We further note that this Tribunal in assessee's own case for the Assessment Year 2007-08 has again decided this issue in para 7.4 as under : “7.4 We have heard both parties and perused and carefully considered the material…

Gayatri Commercial Premises Co-Op Society Ltd, Mumbai vs. CPC/ITO.22(1)(4), Mumbai

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

ITA 114/MUM/2023[2019-20]Status: DisposedITAT Mumbai31 May 2023AY 2019-20

Bench: Shri Aby T. Varkey, Jm & Shri Amarjit Singh, Am आयकर अपील सं/ I.T.A. No.114/Mum/2023 (निर्धारण वर्ा / Assessment Years: 2019-20) Gayatri Commercial Premises बिधम/ Cpc/Ito, 22 (1)(4) Co-Op, Society Ltd. 3Rd Floor, Piramal Chambers Vs. Unit No. 102/103, Behind Lalbaugh Mumbai- 400034 Mittal Ind. Estate Andheri Kurla Andheri (East) Mumbai- 400059 स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaag5064D (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri. N.R. Agarwal Revenue By: Shri. Krishna Kumar, (Sr. Ar) सुनवाई की तारीख / Date Of Hearing: 15/03/2023 घोषणा की तारीख /Date Of Pronouncement: 31/05/2023 आदेश/Order Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The Ld. Cit(A)/Nfac Dated 13-12-2022 For Ay 2019-20 Confirming The Addition Of Rs. 93,20,286/-. 2. The Assessee Society Has Raised The Following Grounds Of Appeal Reads As Under: - “1. The Ld. Cit(A) Erred In Confirming The Addition Of Rs.93,20,286/- As A Business Income In Order Passed U/S 143(1) & 154 Of The Act By Cpc. 2. The Ld. Cit(A) Erred In Not Granting Deduction Under Mutuality Principal.” 3. The Regarding Ground No. 1, The Ld. Cit(A) Has Dismissed The Ground Of Appeal Of The Assessee By Observing As Under: - “The Ld. Cit(A) Has Rejected The Assessees’S The Ground Of Appeal By Observing At Para No. 7 Of The Impugned Order As Under:-

For Appellant: Shri. N.R. AgarwalFor Respondent: Shri. Krishna Kumar, (Sr. AR)

Section 143(1)

…y of law” and drew our attention to the following case laws:- a).Nirmala L. Mehta v/s A. Balsubramaniam CIT 269 ITR 1 (Bom) 4 A.Y. 2019-20 Gayatri Commercial Premises Co-Op Society Ltd. b).CIT v/s Archana R Dhanwatey 136 ITR 355 (Bom) c). Wipro Ltd v/s DCIT 382 ITR 179 (Karn) d).Smt Snehlata Jain v/s CIT 192 CTR 50 (J&K) e). TATA INDUSTRIES LTD vs. ITO dated 20th July, 2016,181 TTJ 0600 (Mumbai) Hon'ble bench has held in para 30 of the order as under:- 6. According to the Ld. AR, the assessee itself has offered disallowance in the return of income more than the exempt income earned and submitted that even if t…

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

…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 India [165 Taxmann.com 627]. 95 ITA NO.5655 & 569…

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

…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 India [165 Taxmann.com 627]. 95 ITA NO.5655 & 569…

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

…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 India [165 Taxmann.com 627]. 95 ITA NO.5655 & 569…

Cgi Information Systems and Management vs. The Income Tax Officer

Appeal is allowed

ITA/610/2016HC Karnataka23 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 10ASection 260Section 80H

…- 1 - ITA No. 610 of 2016 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF JANUARY, 2023 PRESENT THE HON'BLE MR JUSTICE P.S.DINESH KUMAR AND THE HON'BLE MR JUSTICE G BASAVARAJA INCOME TAX APPEAL NO. 610 OF 2016 BETWEEN: CGI INFORMATION SYSTEMS AND MANAGEMENT CONSULTANTS PRIVATE LIMITED ELECTRONIC CITY TOWER II, NO.95/1 AND 95/2, ELECTRONIC CITY PHASE I (WEST) BANGALORE-560 100 REPRESENTED HEREIN BY ITS DIRECTOR MS.BABALUSHA ESTHER ALEXANDER …APPELLANT (BY SRI. K.SURAYANARAYA, SR. ADV. FOR SMT. TANMAYEE RAJKUMAR, ADV.) AND: 1. THE INCOME TAX OFFICER WAR…

Cgi Information Systems vs. The Income Tax Officer

Appeal is allowed

ITA/611/2016HC Karnataka23 Jan 2023

Bench: P.S.DINESH KUMAR,G BASAVARAJA

Section 10ASection 260

…- 1 - ITA No. 611 of 2016 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 23RD DAY OF JANUARY, 2023 PRESENT THE HON'BLE MR JUSTICE P.S.DINESH KUMAR AND THE HON'BLE MR JUSTICE G BASAVARAJA INCOME TAX APPEAL NO. 611 OF 2016 BETWEEN: CGI INFORMATION SYSTEMS AND MANAGEMENT CONSULTANTS PRIVATE LIMITED ELECTRONIC CITY TOWER II, NO.95/1 AND 95/2, ELECTRONIC CITY PHASE I (WEST) BANGALORE-560 100 REPRESENTED HEREIN BY ITS DIRECTOR MS. BABALUSHA ESTHER ALEXANDER …APPELLANT (BY SRI. K.SURAYANARAYA, SR. ADV. FOR SMT. TANMAYEE RAJKUMAR, ADV.) AND: 1. THE INCOME TAX OFFICER…

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Limited, Bangalore

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 809/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R

Section 11Section 14ASection 194JSection 234BSection 40Section 80J

…. submitted that the above ground does not explicitly state the issue pertaining to which the Revenue has challenged the findings of the CIT(A). The learned CIT(A) had relied on the aforesaid decision of the Karnataka High Court in M/s Wipro Ltd v DCIT (2016) 382 ITR 179 (Kar) in deciding two distinct issues. The first issue being claim of deduction under section 10AA in respect of income from sale of scrap, incentives from airlines, interest from GLES deposits and interest from employee loans. The CIT(A) granted relief to the assessee on this issue by following the decision of the Karnataka High Court in Wipro’s…

M/S Infosys Ltd, Bangalor E vs. The Assistant Commissioner of Income Tax Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

ITA 735/BANG/2018[2013-14]Status: DisposedITAT Bangalore09 Jan 2023AY 2013-14

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Sri Sreenivas T. Bidari, D.R

Section 11Section 14ASection 194JSection 234BSection 40Section 80J

…. submitted that the above ground does not explicitly state the issue pertaining to which the Revenue has challenged the findings of the CIT(A). The learned CIT(A) had relied on the aforesaid decision of the Karnataka High Court in M/s Wipro Ltd v DCIT (2016) 382 ITR 179 (Kar) in deciding two distinct issues. The first issue being claim of deduction under section 10AA in respect of income from sale of scrap, incentives from airlines, interest from GLES deposits and interest from employee loans. The CIT(A) granted relief to the assessee on this issue by following the decision of the Karnataka High Court in Wipro’s…

Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore vs. M/S Infosys Ltd, Bangalore

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

ITA 1849/BANG/2017[2008-09]Status: DisposedITAT Bangalore30 Nov 2022AY 2008-09