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“Section 10(50)”

Section References (mined)Section 10Section 10(50)11 judgments

The decision most relied on for Section 10(50) is Shri Manjeet Singh HUF v. UOI & Others in CWP No. 15506 of 2013; Shri Puneet Singh vs. CIT (110 Taxmann.com 116), cited in 83 judgments on BharatTax.

Leading authorities on Section 10(50)

Shri Manjeet Singh HUF v. UOI & Others in CWP No. 15506 of 2013; Shri Puneet Singh vs. CIT
110 Taxmann.com 116 · 2019 · Reported
83
citing judgments

Interest received on compensation or enhanced compensation from compulsory acquisition of land is taxable under the head 'Income from other sources' in the year of receipt, as per the amended provisions, with a 50% deduction available under section 57(iv).

CIT v. Shri Arbuda Mills Ltd.
231 ITR 50 · 1998 · Supreme Court
61
citing judgments

The Commissioner's revisional powers under Section 263, as clarified by Explanation (c) of Section 263(1) (retrospectively inserted by the Finance Act, 1989), extend to and are deemed always to have extended to matters that were not considered and decided in an appeal. This means the CIT can revise an order even if it was appealed, provided the specific issue under revision was not part of the appeal proceedings.

ITO v. Frigsales (India) Ltd.
4 SOT 376 · 2005 · ITAT
38
citing judgments

Capital gains arising on a depreciable asset, which are exempt under Section 50, are to be excluded from the calculation of deemed profits under Section 115JA, as the exemption is preserved by Section 115JA(4).

CIT v. R.B. Rungta & Co.
50 ITR 233 · 1963 · High Court
15
citing judgments

An expenditure not allowed as a specific deduction can still be considered an allowable business loss under the general principles of income computation, even if a specific condition for that deduction was not met.

Mrs. Thulasidass Prabavathi v. Income-tax Officer
174 Taxmann.com 508 · 2025 · High Court
12
citing judgments

Reopening of assessment beyond three years but not more than 10 years is permissible under section 149(1)(a) if the income escapement amounts to or is likely to amount to ₹50 lacs or more.

193 (Kolkata-Trib.), Century Enka Ltd. v. DCIT
57 Taxmann.com 95 · 2015 · ITAT
10
citing judgments

An assessee is entitled to claim the remaining 50% of depreciation in a subsequent year if the asset was put to use for less than 180 days in the year of addition, and the first 50% was not claimed. Capital investment subsidies received for setting up a project in a backward area are considered capital subsidies and do not require reduction from the cost of assets under Explanation 10 to Section 43(1).

Judgments citing Section 10(50)

Acronis Asia Pte Ltd, Mumbai vs. Deputy Commissioner of Income Tax (International Taxation )Range-1(1)(1), Mumbai

In the result, the appeal filed by the assessee is

ITA 2035/MUM/2025[2022-23]Status: DisposedITAT Mumbai30 Dec 2025AY 2022-23
Section 10(50)Section 143(3)Section 144C(13)

treating the same as consideration received from e-commerce supply or services. Consequent thereto, the assessee claimed exemption of the said income under section 10(50) of the Act. 7. In the return of income, the assessee characterized the receipts as business income not chargeable to tax in India ... without prejudice, it was contended that once Equalization Levy had been paid, the income stood excluded from the total income by virtue of section 10(50) of the Act. 8. The case of the assessee was selected for scrutiny and notices under sections 143(2) and 142(1) were issued

Jeppesen Gmbh, Germany vs. ACIT, Internation Taxation, Circle-3(1)(1), Mumbai, Maharashtra

In the result, the appeal of the assessee is partly allowed

ITA 1337/MUM/2025[2022-23]Status: DisposedITAT Mumbai29 Dec 2025AY 2022-23

Bench: Us Read As Under:

Section 10(50)Section 143(3)Section 144C(13)Section 9(1)(vi)

cent on a portion of receipts. It was also noticed by the Assessing Officer that the assessee had claimed exempt income under section 10(50) of ₹42,44,84,655, whereas in the return of income the exempt income reflected in the schedule was shown

Zscaler, Inc., United States of America vs. DCIT, International Tax, Circle 3(1)(1), New Delhi

The appeals are allowed

ITA 928/DEL/2025[2022-23]Status: DisposedITAT Delhi18 Jun 2025AY 2022-23

Bench: Shri Anubhav Sharma & Shri Manish Agarwal, Ccountant Member Assessment Year: 2021-22 Assessment Year : 2022-23 Zscaler Inc., Vs Dcit, 120, Holger Way San Jose, International Tax Circle 3(1)(1), California, Usa, Delhi. Usa 95134. Pan: Aaacz4350P (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate; Shri Kishore Kunal, Advocate; Ms Ankita Prakash, Advocate; & Shri Govind Gupta, Advocate Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 18.06.2025 Order Per Anubhav Sharma, Jm: These Appeals Are Preferred By The Assessee Against The Final Assessment Orders Dated 31.10.2023 & 22.01.2025 Passed By The Dy. Commissioner Of Income-Tax, International Tax Circle 3(1)(1), Delhi (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Ms Ekta Jain, CIT-DR
Section 142(1)Section 143(2)Section 143(3)

show cause also stated that it has paid equalisation levy on the total receipts and hence the receipts should be exempt under section 10(50) of the Income Tax Act. However, that was not sustained by the ld. AO for following reasons; “Firstly, the assessee the assessee deliberately ... India. Hence, these receipts don't fall under the chapter of equalisation levy and hence are not eligible for exemption under section 10(50) of the Act.” The objections filed by the assessee were dismissed by the Dispute 7. Resolution Panel (DRP), for which the assessee is in appeal

Zscaler, Inc., United States vs. Deputy Commissioner of Income Tax, International Tax, Circle 3(1)(1), Delhi

The appeals are allowed

ITA 3376/DEL/2023[2021-22]Status: DisposedITAT Delhi18 Jun 2025AY 2021-22

Bench: Shri Anubhav Sharma & Shri Manish Agarwal, Ccountant Member Assessment Year: 2021-22 Assessment Year : 2022-23 Zscaler Inc., Vs Dcit, 120, Holger Way San Jose, International Tax Circle 3(1)(1), California, Usa, Delhi. Usa 95134. Pan: Aaacz4350P (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate; Shri Kishore Kunal, Advocate; Ms Ankita Prakash, Advocate; & Shri Govind Gupta, Advocate Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 18.06.2025 Order Per Anubhav Sharma, Jm: These Appeals Are Preferred By The Assessee Against The Final Assessment Orders Dated 31.10.2023 & 22.01.2025 Passed By The Dy. Commissioner Of Income-Tax, International Tax Circle 3(1)(1), Delhi (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Ms Ekta Jain, CIT-DR
Section 142(1)Section 143(2)Section 143(3)

show cause also stated that it has paid equalisation levy on the total receipts and hence the receipts should be exempt under section 10(50) of the Income Tax Act. However, that was not sustained by the ld. AO for following reasons; “Firstly, the assessee the assessee deliberately ... India. Hence, these receipts don't fall under the chapter of equalisation levy and hence are not eligible for exemption under section 10(50) of the Act.” The objections filed by the assessee were dismissed by the Dispute 7. Resolution Panel (DRP), for which the assessee is in appeal

Icici Bank Ltd, Mumbai vs. Addl CIT RG 3 (1), Mumbai

ITA 4249/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “H”, MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI OMKARESHWAR CHIDARA

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

ITA 4159/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “H”, MUMBAI BEFORE SMT. BEENA PILLAI, JUDICIAL MEMBER AND SHRI OMKARESHWAR CHIDARA

Shri Vijay Singh, Gurgaon vs. ITO, Gurgaon

The appeals are allowed

ITA 928/DEL/2017[2013-14]Status: DisposedITAT Delhi01 Apr 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal, Ccountant Member Assessment Year: 2021-22 Assessment Year : 2022-23 Zscaler Inc., Vs Dcit, 120, Holger Way San Jose, International Tax Circle 3(1)(1), California, Usa, Delhi. Usa 95134. Pan: Aaacz4350P (Appellant) (Respondent) Assessee By : Shri Ajay Vohra, Sr. Advocate; Shri Kishore Kunal, Advocate; Ms Ankita Prakash, Advocate; & Shri Govind Gupta, Advocate Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 18.06.2025 Order Per Anubhav Sharma, Jm: These Appeals Are Preferred By The Assessee Against The Final Assessment Orders Dated 31.10.2023 & 22.01.2025 Passed By The Dy. Commissioner Of Income-Tax, International Tax Circle 3(1)(1), Delhi (Hereinafter Referred To As The Ld. Ao) U/S 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961

For Appellant: Shri Ajay Vohra, Sr. AdvocateFor Respondent: Ms Ekta Jain, CIT-DR
Section 142(1)Section 143(2)Section 143(3)

show cause also stated that it has paid equalisation levy on the total receipts and hence the receipts should be exempt under section 10(50) of the Income Tax Act. However, that was not sustained by the ld. AO for following reasons; “Firstly, the assessee the assessee deliberately ... India. Hence, these receipts don't fall under the chapter of equalisation levy and hence are not eligible for exemption under section 10(50) of the Act.” The objections filed by the assessee were dismissed by the Dispute 7. Resolution Panel (DRP), for which the assessee is in appeal

Deputy Commissioner of Income Tax (International Taxation), Circle 1(1), Bengalore vs. Google Ireland Limited, Dublin

In the result, the appeal of the revenue is dismissed

ITA 1272/BANG/2024[2008-09]Status: DisposedITAT Bangalore21 Oct 2024AY 2008-09

Bench: SHRI LAXMI PRASAD SAHU (Accountant Member), SHRI KESAV DUBEY (Judicial Member)

For Appellant: Ms. Priya Tandon, Ms. Nandita Phal & Shri AnmolFor Respondent: Shri Sridhar E., CIT(DR)(ITAT), Bengaluru
Section 10(50)Section 148Section 195Section 201Section 9Section 9(1)(vi)Section 90Section 90A

taxable under the then existing provisions, without IT(IT)A No.1272/Bang/2024 Page 2 of 6 considering that the amendment to made to Section 10(50) of the Income Tax Act, 1961 in Finance Act, 2020 that exemption under section 10(50) will not apply for royalty or fees for technical

Hireright Limited, United Kingdom vs. Assistant Commissioner of Income Tax, Circle 2(1)(1), International Taxation, New Delhi

In the result, the appeal of the assessee is allowed

ITA 3880/DEL/2023[2021-22]Status: DisposedITAT Delhi27 Jun 2024AY 2021-22

Bench: Dr. B. R. R. Kumar, Sh. Anubhav Sharma

For Appellant: Sh. Kishore Kunal, Adv. &For Respondent: Sh. Vizay B. Vasanta, CIT-DR
Section 10(50)Section 143(3)Section 144CSection 234A

royalty or FTS. 3. That on the facts and circumstances and in law, the Ld. AO erred in denying exemption under Section 10(50) of the Act without appreciating the factual matrix of the case. 4. That on the facts and circumstances of the case and in law, without prejudice

Automation Anywhere Inc., Usa vs. DCIT Circle Intl. Taxation 1(1)(1), New Delhi

ITA 3418/DEL/2023[2021-22]Status: DisposedITAT Delhi19 Feb 2024AY 2021-22

Bench: Shri Shamim Yahya & Sh. Anubhav Sharmaautomation Anywhere Inc., Vs. Dcit 633, River Oaks Parkway, Circle San Jose, Ca 95134, Usa Intl. Taxation 1(1)(1), Pan No.Aamca9481A Civic Centre, Minto Road, New Delhi. (Appellant) (Respondent)

Section 10(50)Section 143(3)Section 144CSection 156

platform in AY 2021-22. Therefore, such income of the Appellant cannot be included in the total income as per the provision of Section 10(50) of the Act. G) SEVENTH GROUND OF APPEAL 10. The Ld. AO, both in facts and in law, in adding income of Rs.33

Hireright Llc, Usa vs. Deputy Commissioner of Income Tax, International Taxation, Gurgaon

ITA 3413/DEL/2023[Hireright LLC ]Status: DisposedITAT Delhi19 Jan 2024

Bench: Shri Saktijit Dey & Dr. B. R. R. Kumar

For Appellant: Sh. Kishore Kunal, AdvFor Respondent: Sh. P. Praveen Siddharth, CIT-DR
Section 10(50)Section 115ASection 2(24)Section 234ASection 234BSection 5Section 9

That on the facts and circumstances of the case and in law, the Ld. AO has erred in denying exemption under Section 10(50) of the Act without appreciating the factual matrix of the case. 3 That on the facts and circumstances of the case