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“foreign tax credit”

International TaxSection 90 / Rule 128Section 90 / Rule 128571 judgments

The decision most relied on for foreign tax credit is Chandra Kishore Jha v. Mahavir Prasad (8 SCC 266), cited in 163 judgments on BharatTax.

Leading authorities on foreign tax credit

Chandra Kishore Jha v. Mahavir Prasad
8 SCC 266 · 1999 · Supreme Court
163
citing judgments

If a statute or law prescribes that a thing must be done in a particular manner, then it must be done in that manner alone and in no other way. This principle mandates strict adherence to statutory procedures.

Wipro Ltd. v. DCIT
382 ITR 179 · 2016 · High Court
122
citing judgments

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.

Ms. Brinda Ramakrishna v. ITO
135 Taxmann.com 358 · 2022 · ITAT
109
citing judgments

The filing of Form 67 for claiming Foreign Tax Credit (FTC) is a directory requirement, not mandatory. Rule 128(9) does not provide for disallowance of FTC due to delay in filing this form. Double Taxation Avoidance Agreements (DTAAs) override domestic law.

CIT v. ACE Multitaxes Systems (P.) Ltd.
317 ITR 207 · 2009 · High Court
107
citing judgments

For claiming relief under Chapter VI-A deductions like Section 80IB or 80IA, the audit report in Form 10CCB is not mandatory to be filed with the return of income, but can be submitted before the assessment is completed.

Sambhaji and Others v. Gangabai and Others
17 SCC 117 · 2008 · Supreme Court
87
citing judgments

Procedural law serves as an aid to justice, not an obstruction, and should not ordinarily be construed as mandatory; it is subservient to substantive justice.

42 Hertz Software India (P.) Ltd. v. ACIT
139 Taxmann.com 448 · 2022 · ITAT
62
citing judgments

The claim for Foreign Tax Credit cannot be denied solely due to a delay in filing Form-67, as the requirement for filing Form-67 under Rule 128(9) is considered directory and not mandatory. The provisions of a Double Taxation Avoidance Agreement (DTAA) prevail over the Income-tax Act, 1961.

Duraiswamy Kumaraswamy v. PCIT
460 ITR 615 · 2024 · High Court
50
citing judgments

An assessee's claim for Foreign Tax Credit (FTC) cannot be rejected merely because Form 67 was filed after the due date under section 139(1), provided it is filed before the completion of assessment proceedings.

Sonakshi Sinha v. CIT
142 Taxmann.com 414 · 2022 · ITAT
37
citing judgments

The requirement to file Form 67 by the due date for claiming foreign tax credit is directory, not mandatory, if filed before the completion of assessment proceedings.

Judgments citing foreign tax credit

Edelweiss Financial Services Ltd, Mumbai vs. ACIT Cent Cir -1(2), Mumbai

The appeal is allowed

ITA 93/MUM/2022[2017-18]Status: DisposedITAT Mumbai23 Jun 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Ravikant Pathak, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 14A

payer in next year TDS deduced by the payer but not 54,59,764 deposited to the credit of Central Government Foreign Tax Credit 1,43,60,662 The Appellant submits that it has offered the related income from which TDS has been deducted in the year under consideration; hence ... confirmed the action of the learned Assessing Officer in not granting credit for ₹54,59,764/-. He also noted that assessee has claimed Foreign Tax Credit of ₹1,43,60,662/-. He noted that no details are available and therefore, no such tax credit can be granted. With respect

Edelweiss Financial Services Ltd, Mumbai vs. ACIT Central Cir-1(2), Mumbai

The appeal is allowed

ITA 92/MUM/2022[2016-17]Status: DisposedITAT Mumbai23 Jun 2022AY 2016-17

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Ravikant Pathak, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 14A

payer in next year TDS deduced by the payer but not 54,59,764 deposited to the credit of Central Government Foreign Tax Credit 1,43,60,662 The Appellant submits that it has offered the related income from which TDS has been deducted in the year under consideration; hence ... confirmed the action of the learned Assessing Officer in not granting credit for ₹54,59,764/-. He also noted that assessee has claimed Foreign Tax Credit of ₹1,43,60,662/-. He noted that no details are available and therefore, no such tax credit can be granted. With respect

Eldelweiss Securities Ltd, Mumbai vs. ACIT Circle 4(1) (1), Mumbai

The appeal is allowed

ITA 15/MUM/2022[2017-18]Status: DisposedITAT Mumbai23 Jun 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

For Appellant: Shri Ravikant Pathak, ARFor Respondent: Shri Amol Kirtane, CIT DR
Section 14A

payer in next year TDS deduced by the payer but not 54,59,764 deposited to the credit of Central Government Foreign Tax Credit 1,43,60,662 The Appellant submits that it has offered the related income from which TDS has been deducted in the year under consideration; hence ... confirmed the action of the learned Assessing Officer in not granting credit for ₹54,59,764/-. He also noted that assessee has claimed Foreign Tax Credit of ₹1,43,60,662/-. He noted that no details are available and therefore, no such tax credit can be granted. With respect

M/S Unisys India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

In the result, grounds 10 and 11 are allowed for statistical purposes

ITA 2096/BANG/2017[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Aliasger Rampurwala, CAFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153Section 153BSection 92C

same is not adjudicated. On the contrary, the learned AR submitted that if the Tribunal gives directions to the A.O. to compute the foreign tax credit that is due to the assessee as per law (ground 10) that would suffice. The surviving additional ground 12 reads as follows:- “Ground ... order passed by the learned CIT(Appeals), the learned CIT(Appeals) erred in rejecting the methodology adopted by the Appellant to compute the foreign tax credit and upholding the approach adopted by the learned Assessing Officer (AO) thereby allowing only partial claim with respect to the foreign tax credit claim

Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore vs. M/S. Unisys India Pvt Ltd, Bangalore

In the result, grounds 10 and 11 are allowed for statistical purposes

ITA 2025/BANG/2017[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Aliasger Rampurwala, CAFor Respondent: Dr.Manjunath Karkihalli, CIT-DR
Section 153Section 153BSection 92C

same is not adjudicated. On the contrary, the learned AR submitted that if the Tribunal gives directions to the A.O. to compute the foreign tax credit that is due to the assessee as per law (ground 10) that would suffice. The surviving additional ground 12 reads as follows:- “Ground ... order passed by the learned CIT(Appeals), the learned CIT(Appeals) erred in rejecting the methodology adopted by the Appellant to compute the foreign tax credit and upholding the approach adopted by the learned Assessing Officer (AO) thereby allowing only partial claim with respect to the foreign tax credit claim

Ibm India Private Limited, Bangalore vs. Joint Commissioner of Income Tax, Circle-3(1)(1), Bangalore

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

ITA 179/BANG/2022[2008-09]Status: DisposedITAT Bangalore15 Jun 2022AY 2008-09

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Ajay Rotti, A.RFor Respondent: Dr. Manjunath Karkihalli, D.R
Section 10ASection 143(3)Section 154Section 40

significantly higher tax demand. IT(TP)A No.179 /Bang/2022 IBM India Pvt. Ltd., Bangalore Page 9 of 11 6. Short grant of Foreign Tax Credit (`FTC') 6.1. The learned AO has erred in law and on facts in not granting foreign tax credit for the full amount of foreign taxes

M/S. Biocon Limited, Bengaluru vs. Commissioner of Income Tax, Ltu, Bengaluru

In the result, the appeal filed by the assessee is allowed on the legal issue raised in ground no

ITA 1858/BANG/2018[2010-11]Status: DisposedITAT Bangalore09 Jun 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2010-11 The Joint M/S. Biocon Ltd., Commissioner Of 20Th Km, Hosur Road, Income-Tax, Electronic City, Large Tax Payers Bangalore – 560 100. Unit [Ltu], Pan: Aaacb7461R Vs. Bangalore. Appellant Respondent : Shri Padam Chand Khincha, Assessee By Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 20-04-2022 Date Of Pronouncement : 09-06-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 28.03.2018 Passed By Ld.Cit(A)-3, Bangalore For A.Y. 2010-11 On Following Grounds Of Appeal: “The Grounds Mentioned Herein Below Are Independent & Without Prejudice To The Other Grounds Preferred By The Appellant. 1. That On Facts & Circumstances Of The ' Case & In Law, The Order Passed By The Learned Commissioner Of Income-Tax Appeals ["Cit(A)"] Dated March 28, 2018 Under Section 250 Of The Income-Tax Act, 1961 ("The Act") For Ay 2010-11 To The Extent Prejudicial To The Appellant, Is Bad In Law & Facts & Liable To Be Quashed. 2. Scope Of Re-Assessment Proceedings

For Respondent: Shri Padam Chand Khincha
Section 147Section 250Section 35

Ld.AO noticed that, the assessee deposited TDS of Rs.3,16,42,729/-, advance tax of Rs.20,10,00,000/-. The assessee claimed foreign tax credit of Rs.42,61,934/-. The Ld.AO completed the assessment u/s. 143(3) vide order dated 23.05.2014 computing gross total income

Sunkesulapati Sumanth, Bangalore vs. Income Tax Officer Ward 5(3)(2) and Assistant Director of CPC, Bangalore

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

ITA 6/BANG/2022[2017-18]Status: DisposedITAT Bangalore29 Apr 2022AY 2017-18

Bench: Shri Chandra Poojariassessment Year : 2017-18 Shri. Sunkesulapati Sumanth, Vs. Ito, 2B 502 Arya Hamsa Apartment, Ward – 5(3)(2) & Adit, Cpc, Bangalore South, Bannerghatta S.O, Bengaluru. Bengaluru – 560 083. Pan : Bypps 8390 R Appellant Respondent Assessee By : Shri. Balasubramanyam K V, Ar Revenue By : Shri. Ganesh R. Ghale, Standing Counsel Date Of Hearing : 11.04.2022 Date Of Pronouncement : 29.04.2022 O R D E R

For Appellant: Shri. Balasubramanyam K V, ARFor Respondent: Shri. Ganesh R. Ghale, Standing Counsel
Section 139(1)Section 143(1)Section 154Section 90

case. 3. the learned Assessing Officer has erred in law and on facts that requisite taxes paid are eligible for the Foreign Tax Credit as per Indo-American DTAA. That having regard to the facts and circumstances of the case, the 4. learned Assessing Officer has erred ... grounds of appeal are without prejudice to 7. each other. That the relief prayed to condone the delay in filing Form 67, allow Foreign Tax Credit of Rs. 3,29,045 and order of the Assessing Officer be quashed. set aside, annulled or modified 3. The facts of the issue

M/S. Invendis Technologies India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle - 3(1)(1), Bangalore

ITA 986/BANG/2019[2014-15]Status: DisposedITAT Bangalore27 Apr 2022AY 2014-15

Bench: Shri N V Vasudevan & Ms. Padmavathy Sassessment Year : 2014-15

For Appellant: Smt. Tanmayee Rajkumar AdvocateFor Respondent: Shri Priyadarshi Mishra Addl. CIT
Section 143(2)Section 250Section 90Section 91

Effective rate of tax on Ghana income – (K) = (J)/(I) 21.55% Effective Indian tax rate – (L) 18.50% Effective rate of tax on which foreign tax credit is 18.50% allowable – (M) = (lesser of) (K) or (L) Tax credit allowed / allowable – (N) = (M) * (I) 90,47,150 Tax credit disallowed ... explanation (iii) of section 91 of the Act. (ii) The net profit ratio method as adopted by the AO for computation of foreign tax credit has not been prescribed by section 90/91 of the Act. (iii) Wherever the legislature intended to provide a method of computation it has specifically provided

Tata Consultancy Services Ltd, Mumbai vs. ACIT Large Tax Payer Unit-1, Mumbai

797/Mum/2018

ITA 1769/MUM/2018[2013-14]Status: DisposedITAT Mumbai11 Apr 2022AY 2013-14
Section 143(3)Section 2Section 2(43)Section 37Section 40Section 90

A.Y.2012-13 are disposed of in the above mentioned terms. 5. The ground No.3 raised by the assessee is in respect of seeking foreign tax credit in respect of income pertaining to Section 10A/10AA eligible units in India. The ground No.8 raised by the Revenue for A.Y.2012-13 is also ... 30/10/2019 wherein it was held as under:- “26. In ground no.6, corresponding to ground no.7 of Revenue's appeal, the assessee has claimed foreign tax credit in respect of income pertaining to section 10A/10AA of the Act eligible units in India. 27. Brief facts are, in the course of assessment

Strides Pharma Science Ltd, Navi Mumbai vs. Dy CIT 15 (3)(2), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 7992/MUM/2019[2015-16]Status: DisposedITAT Mumbai06 Apr 2022AY 2015-16

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Nishit Gandhi a/w Ms. Akshita BhandariFor Respondent: Ms. Vatsalaa Jha (CIT)
Section 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 92C

assessee’s appeal is allowed. 36. The issue arising in ground no.7, raised in assessee’s appeal with regard to non–grant of foreign tax credited amounting to Rs.23,96,97,476, with respect to the dividend income earned. 37. The brief facts of the case pertaining to this issue ... emanating from the record are: During the course of assessment proceedings, the assessee claimed additional foreign tax credited amounting to Rs.23,96,97,476, under Article 25(4) of the Indo–Cyprus Double Taxation Avoidance Agreement (“DTAA”). Article–25(4) of Indo–Cyprus reads as under:– "(4) That tax payable

Tata Consultancy Services Ltd, Mumbai vs. Asst CIT Ltu-1, Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 1650/MUM/2016[2011-12]Status: DisposedITAT Mumbai06 Apr 2022AY 2011-12

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

For Appellant: Shri Porus Kaka, Sr. AdvocateFor Respondent: Ms. Vatsalaa Jha, CIT–DR
Section 115JSection 143(3)Section 144C(1)Section 144C(13)Section 144C(5)Section 2(43)Section 37Section 40Section 90Section 91

raised in assessee‟s appeal are allowed. 56. The issue arising in ground no.11 raised in assessee‟s appeal is regarding grant of foreign tax credit as per the provisions of section 90(1)(a) of the Act read with provisions of the applicable Double Taxation Avoidance Agreement („DTAA ... whichever is lower. In addition to above, during the course of proceedings before the DRP, the assessee raised an additional ground claiming that foreign tax credit should be allowed, as per respective tax treaties in respect of taxes paid overseas, on income eligible for deduction Tata Consultancy Services

M/S. Sasken Technologies Limited, Bangalore vs. Joint Commissioner of Income Tax, Special Range - 6, Bangalore

In the result, appeal of the assessee is partly allowed

ITA 2546/BANG/2019[2016-17]Status: DisposedITAT Bangalore18 Mar 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2016-17 M/S. Sasken Technologies Limited, Vs. Jcit, No.139/25, Ring Road, Domlur, Special Range – 6, Bengaluru-560071. Bengaluru. Pan : Aaecs 6424 R Appellant Respondent Appellant By : Shri. Padam Chand Khincha, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 09.03.2022 Date Of Pronouncement : 16.03.2022 O R D E R Per N.V. Vasudevanthis Is An Appeal By The Assessee Against The Order Dated 27.11.2019 Of Cit(A), Bengaluru -10, Relating To Assessment Year 2016-17. 2. Ground No.1 Raised By The Assessee Is General & Calls For No Specific Adjudication. Grounds Nos.2 & 3 Raised By The Assessee Is With Regard To The Issue Whether The Gain On Sale / Assignment Of Intellectual Property Rights (Ipr) Is Assessable To Tax At All & If So Assessable To Tax Whether It Has To Be Assessed To Tax Under The Head “Income From Business Or Profession” Or “Capital Gain”. Page 2 Of 31

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 1

Court in the case of Wipro Ltd., 382 ITR 179 (Karn.). “The Hon'ble Karnataka High Court has given following reason for allowing Foreign Tax credit in the case of Wipro Ltd (supra):- "56. Therefore, it follows that the income under Section 10A is chargeable to tax under Section

42 Hertz Software India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result appeal filed by assessee stands allowed for statistical purposes

ITA 29/BANG/2021[2017-18]Status: DisposedITAT Bangalore07 Mar 2022AY 2017-18

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2017-18 M/S. 42 Hertz Software India Pvt. Ltd., The Assistant 2231, One Bangalore Commissioner Of West, Income Tax, Dr. Rajkumar Road, Circle – 3 (1)(1), Bangalore North, Vs. Bangalore. Bangalore – 560 010. Pan: Aaacz7113J Appellant Respondent Assessee By : Shri Pvss Prasad, Ca : Shri Priyadarshini Mishra, Revenue By Addl. Cit (Dr) Date Of Hearing : 03-03-2022 Date Of Pronouncement : 07-03-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 18/03/2020 Passed By The Ld.Cit(A)-3, Bangalore, For Assessment Year 2017-18 On Following Grounds Of Appeal: Tax Effect Relating To Each Ground Of Grounds Of Appeal Appeal (See Note Below) The Appellate Order Of Ld Commissioner Of Income Tax Appeals Is 1. 43,46,900/- Bad & Erroneous Both On Facts & In Law On The Facts & In The Circumstances 2. 43,46,900/- Of The Case & In The Law, The Ld

For Appellant: Shri PVSS Prasad, CA
Section 139(1)Section 139(5)Section 90

Page 2 of 6 Commissioner of Income Tax (Appeals) has erred in sustaining the assessment order and in denying the Foreign Tax Credit (FTC) for default in filling Form 67 under Rule 128. He Ought to have consider that the minor technical lapse cannot disentitle the assesse for FTC which ... filed its return of income on 29/11/2017 declaring total income of Rs.1,36,89,850/-. 2.2 The Ld.AO noted that Assessee claimed Foreign Tax Credit(FTC) of Rs.43,46,900/- u/s.90/91 in respect of tax withheld by Japan. As per India-Japan DTAA. The Ld.AO called on assessee to file

Ibm India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, appeal by the assessee stands allowed as indicated hereinabove

ITA 289/BANG/2021[2015-16]Status: DisposedITAT Bangalore14 Feb 2022AY 2015-16

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiit(Tp)A No. 289/Bang/2021 Assessment Year : 2015-16 M/S. Ibm India Pvt. Ltd., The Deputy No. 12, Subramanya Commissioner Of Arcade, Income-Tax, Bannerghatta Road, Circle 3 (1)(1), Bangalore – 560 029. Vs. Bangalore. Pan: Aaaci4403L Appellant Respondent Assessee By : Shri Ajay Roti, Ca Revenue By : Shri Pradeep Kumar, Cit Dr Date Of Hearing : 12-01-2022 Date Of Pronouncement : 14-02-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Final Assessment Order Dated 30.04.2021 U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Passed By The National Faceless Assessment Centre, Delhi Relating To Assessment Year 2015-16 On Following Grounds Of Appeal: “The Grounds Stated Hereunder Are Independent Of & Without Prejudice To One Another. The Appellant Submits As Under: 1. Assessment Order Bad In Law 1.1. At The Outset, M/S Ibm India Private Limited (Hereinafter Referred To As 'The Appellant' Or 'The Company') Prays That The Order Dated April 30. 2021

For Appellant: Shri Ajay Roti, CAFor Respondent: Shri Pradeep Kumar, CIT DR
Section 10ASection 143(3)Section 144BSection 144C(13)

facts in not granting credit for the entire TDS of INR 554.53.87.685 claimed in the return of income. 14. Short grant of Foreign Tax Credit (`FTC') 14.1. The NeAC has erred in law and on facts in restricting the credit of FTC to INR 74,69,20,665 as against ... modified return of income. 14.2. Without prejudice to the above, the NeAC has erred in law and on facts in not granting foreign tax credit for the full amount of foreign taxes paid, disregarding that relief for tax holiday claim under section 10AA of the Act was fully denied

M/S. Tejas Networks Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Ltu, Circle-1, Bengaluru

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 582/BANG/2021[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

ought to have provided depreciation to the assessee, which is consequential to the assessment proceedings of AY 2010-11. 11. Non-grant of foreign tax credit 11.1. The learned AO erred in not granting eligible foreign tax credit to the assessee as claimed in the return of income amounting ... learned AO granted the foreign tax credit in the draft assessment order and has arbitrarily not allowed the same in the final assessment order. 12. Short credit of tax deducted at source 12.1. The learned AO erred in not considering the credit for Tax Deducted at Source ("TDS") amounting

M/S Tejats Networks Limited, Bangalore vs. Principal Commissioner of Income Tax Central, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1674/BANG/2018[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

ought to have provided depreciation to the assessee, which is consequential to the assessment proceedings of AY 2010-11. 11. Non-grant of foreign tax credit 11.1. The learned AO erred in not granting eligible foreign tax credit to the assessee as claimed in the return of income amounting ... learned AO granted the foreign tax credit in the draft assessment order and has arbitrarily not allowed the same in the final assessment order. 12. Short credit of tax deducted at source 12.1. The learned AO erred in not considering the credit for Tax Deducted at Source ("TDS") amounting

Tejas Networks Limited, Bangalore vs. DCIT, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 694/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

ought to have provided depreciation to the assessee, which is consequential to the assessment proceedings of AY 2010-11. 11. Non-grant of foreign tax credit 11.1. The learned AO erred in not granting eligible foreign tax credit to the assessee as claimed in the return of income amounting ... learned AO granted the foreign tax credit in the draft assessment order and has arbitrarily not allowed the same in the final assessment order. 12. Short credit of tax deducted at source 12.1. The learned AO erred in not considering the credit for Tax Deducted at Source ("TDS") amounting

DCIT, Bangalore vs. M/S Tejas Networks Limited, Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 621/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

ought to have provided depreciation to the assessee, which is consequential to the assessment proceedings of AY 2010-11. 11. Non-grant of foreign tax credit 11.1. The learned AO erred in not granting eligible foreign tax credit to the assessee as claimed in the return of income amounting ... learned AO granted the foreign tax credit in the draft assessment order and has arbitrarily not allowed the same in the final assessment order. 12. Short credit of tax deducted at source 12.1. The learned AO erred in not considering the credit for Tax Deducted at Source ("TDS") amounting

Tejas Networks Limited, Bangalore vs. Asst.C.I.T., Bangalore

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 468/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

ought to have provided depreciation to the assessee, which is consequential to the assessment proceedings of AY 2010-11. 11. Non-grant of foreign tax credit 11.1. The learned AO erred in not granting eligible foreign tax credit to the assessee as claimed in the return of income amounting ... learned AO granted the foreign tax credit in the draft assessment order and has arbitrarily not allowed the same in the final assessment order. 12. Short credit of tax deducted at source 12.1. The learned AO erred in not considering the credit for Tax Deducted at Source ("TDS") amounting