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export oriented unit

DeductionsSection 10BSection 10B105 judgments

GALLAGHER SERVICE CENTER LLP (FORMERLY KNOWN AS GALLAGHER OPERATIONS SUPPORT SERVICES P LTD),PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, NFAC,, DELHI

In the result, the Ground Number 6 is Partly Allowed for Statistical purpose

ITA 679/PUN/2022[2018-19]Status: DisposedITAT Pune24 Mar 2025AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.679/Pun/2022 िनधा"रण वष" / Assessment Year : 2018-19 Gallagher Services Center V Additional/Joint Llp, S Commissioner Of Income 401, Delta 2, Gigaspace It Tax. Park, Vimannagar, Pune – 411014. Pan: Aaqfg7417F Appellant/ Assessee Respondent /Revenue Assessee By Shri M.P.Lohia – Ar Revenue By Shri Prakash L Pathade – Cit(Dr) Date Of Hearing 23/01/2025 Date Of Pronouncement 24/03/2025 आदेश/ Order Per Dr.Dipak P.Ripote, Am : This Is An Appeal Filed By The Assessee Against The Assessment Order Of Passed Under Section 143(3) R.W.S 144C(3) Read With Section 144B Of The Income Tax Act, 1961; Dated 15.07.2022 For A.Y.2018-19. The Assessee Has Raised The Following Grounds Of Appeal : “Based On The Facts & Circumstances Of The Case, The Appellant Respectfully Craves Leave To Prefer An Appeal Under Section 253(1)(D)

Section 143(3)Section 144Section 144BSection 253(1)(d)

service provider engaged in providing back-office support in insurance domain exclusively to its group companies. During the impugned year, the assessee has Export Oriented Units (EOU) in Pune, Bengaluru, Shimoga and Kolhapur which are registered with the Software Technology Parks in India(STPI). The Return of Income filed

EXCELRA KNOWLEDGE SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE-8(1), HYDERABAD

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

ITA 202/HYD/2023[2020-21]Status: DisposedITAT Hyderabad23 Jan 2025AY 2020-21

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.202/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2020-21) Excelra Knowledge Vs. Dy. Cit Solutions (P) Ltd, Circle 8(1) Hyderabad Hyderabad Pan:Aafcg5715Q (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 25/11/2024 घोषणा की तारीख/Pronouncement: 23/01/2025 आदेश/Order Per Vijay Pal Raothis Appeal Filed By The Assessee Is Directed Against The Order Dated10/02/2023 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.2020-21. 2. The Assessee Has Raised The Following Grounds:

For Appellant: Shri H. Srinivasulu, AdvocateFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 10ASection 143(1)Section 438Section 43B

Account. He has further contended that since the deposits with banks were made out of the export proceeds and assessee is a 100% export oriented unit located in SEZ have to receive its sale proceeds in convertible foreign exchange. Therefore, the entire turnover is from exports which is eligible ... deduction u/s 10AA in respect of all the incomes earned by it. The quantum of deduction to be the income of the export oriented unit. He has also referred to the decision of the Hon'ble Delhi High Court in the case of CIT vs. Vasishta Chay Vyapar

ASST. COMMISSIONER OF INCOME TAX, VIJAYAWADA vs. FYSOLATE TECHNOLOGIES, VIJAYAWADA

In the result, appeal of the Revenue is dismissed

ITA 182/VIZ/2023[2017-18]Status: DisposedITAT Visakhapatnam15 Jul 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No.182/Viz/2023 (िनधा"रण वष" / Assessment Year : 2017-18) Assistant Commissioner Of Vs. Fysolate Technologies, Income Tax, Vijayawada. Vijawayada. Pan: Aacff5633L (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Assessee By : Sri Mithilesh Sannareddy ""याथ" क" ओर से / Revenue By : Dr. Satyasai Rath, Cit-Dr सुनवाई क" तारीख / Date Of Hearing : 16/04/2024 घोषणा क" तारीख/Date Of : 15/07/2024 Pronouncement O R D E R

For Appellant: Sri Mithilesh SannareddyFor Respondent: Dr. Satyasai Rath, CIT-DR
Section 10ASection 143(2)Section 143(3)Section 92C

than 10% when compared to the export activities carried out by the assessee which is more than 75% as the assessee is an export oriented unit. S. Comparable Name Turnover (In Export Export Export No INR) Income (In income Filter INR) (%) (75%) 1. Nagarjuna Herbal Concentrates ... considered view that the fresh comparables selected by the TPO do not have export performance and whereas the assessee is a 100% export oriented unit and hence these comparables are fit to be compared with that of the AE M/s. Laila Nutra as a Tested Party. It is also found

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