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“software technology park”

DeductionsSection 10ASection 10A110 judgments

The decision most relied on for software technology park is ITO v. Sak Soft Ltd. (30 SOT 55), cited in 80 judgments on BharatTax.

Leading authorities on software technology park

ITO v. Sak Soft Ltd.
30 SOT 55 · 2009 · ITAT
80
citing judgments

When computing the deduction under Sections 10A or 10AA, if certain expenses (like those incurred in foreign currency or communication expenses) are excluded from 'export turnover' in the numerator, the same expenses must also be excluded from 'total turnover' in the denominator to ensure consistent calculation.

CIT v. WIPRO GE MEDICAL SYSTEM LTD.
358 ITR 518 · 2013 · High Court
19
citing judgments

To qualify for a Section 10A deduction, an undertaking must be independent of the assessee's existing undertakings, rather than merely an expansion of existing business.

PCIT v. Macquarie Global Services (P.) Ltd.
102 Taxmann.com 272 · 2019 · High Court
15
citing judgments

A deduction under Section 10AA cannot be withdrawn in a subsequent year if it was accepted in the first year of operations and the second year, by re-examining factors relevant to the initial year.

Shri Nagesh Chundur v. CIT
358 ITR 521 · 2013 · High Court
11
citing judgments

A new industrial undertaking qualifies for deduction under section 10A of the Income Tax Act even if it commenced production before seeking registration as a Software Technology Park (STP), provided it meets the requisite conditions.

Judgments citing software technology park

DCIT (E), New Delhi vs. M/S Software Technology Park of India, New Delhi

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 2516/DEL/2016[2011-12]Status: DisposedITAT Delhi10 Apr 2024AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2011-12 M/S. Software Technology Parks Vs. Dcit Of India, Circle-31(1) 9Th Floor, Ndcc-Ii Bldg. New Delhi. Opposite Jantar Mantar, New Delhi. Pan Aaats2468J (Appellant) (Respondent) Asstt. Year: 2011-12 Dcit (E) Vs. M/S. Software Technology Circle-2(1) Parks Of India, New Delhi. 9Th Floor, Ndcc-Ii Bldg. Jai Singh Marg, New Delhi-110 001 Pan Aaats2468J (Appellant) (Respondent)

For Appellant: Ms. Sangeeta Singh, CAFor Respondent: Shri Dharamvir Singh, CIT-DR
Section 11Section 12ASection 2(15)

BENCH “G”: NEW DELHI BEFORE SHRI G.S. PANNU, HON’BLE VICE PRESIDENT AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Asstt. Year: 2011-12 M/s. Software Technology Parks Vs. DCIT of India, Circle-31(1) 9th Floor, NDCC-II Bldg. New Delhi. Opposite Jantar Mantar, New Delhi. PAN AAATS2468J (Appellant) (Respondent) Asstt ... section 12A of the Act as a charitable society offering services to the nation as the arm of the Govt. of India under Software Technology Park of India (STPI) scheme. 3 & 11. For AY 2011-12, the assessee filed return on 30.09.2011 declaring income

M/S Software Technology Parks of India., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee is allowed and the appeal of the Revenue is dismissed

ITA 2415/DEL/2016[2011-12]Status: DisposedITAT Delhi10 Apr 2024AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Ms. Astha Chandraasstt. Year: 2011-12 M/S. Software Technology Parks Vs. Dcit Of India, Circle-31(1) 9Th Floor, Ndcc-Ii Bldg. New Delhi. Opposite Jantar Mantar, New Delhi. Pan Aaats2468J (Appellant) (Respondent) Asstt. Year: 2011-12 Dcit (E) Vs. M/S. Software Technology Circle-2(1) Parks Of India, New Delhi. 9Th Floor, Ndcc-Ii Bldg. Jai Singh Marg, New Delhi-110 001 Pan Aaats2468J (Appellant) (Respondent)

For Appellant: Ms. Sangeeta Singh, CAFor Respondent: Shri Dharamvir Singh, CIT-DR
Section 11Section 12ASection 2(15)

BENCH “G”: NEW DELHI BEFORE SHRI G.S. PANNU, HON’BLE VICE PRESIDENT AND MS. ASTHA CHANDRA, JUDICIAL MEMBER Asstt. Year: 2011-12 M/s. Software Technology Parks Vs. DCIT of India, Circle-31(1) 9th Floor, NDCC-II Bldg. New Delhi. Opposite Jantar Mantar, New Delhi. PAN AAATS2468J (Appellant) (Respondent) Asstt ... section 12A of the Act as a charitable society offering services to the nation as the arm of the Govt. of India under Software Technology Park of India (STPI) scheme. 3 & 11. For AY 2011-12, the assessee filed return on 30.09.2011 declaring income

DCIT 9(3), Mumbai vs. Wipro Technology Services .Ltd, Mumbai

In the result, the appeal of the learned Assessing Officer is dismissed

ITA 6974/MUM/2013[2008-09]Status: DisposedITAT Mumbai22 Mar 2024AY 2008-09

Bench: Shri Prashant Maharishi, Am & Ms. Kavitha Rajagopal, Jm Dy. Commissioner Of Income M/S Wipro Technology Tax, Circle 9(3) Services P. Ltd. 2Nd Floor, Room No. 229, 2Nd Floor, Interface Ii]Link Aaykar Bhavan, Vs. Road, Malad (W), M.K. Road, Mumbai-400 064 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaccc4700G Assessee By : Shri Sandeep Suilgol, Advocate Revenue By : Shri Dr. Kishor Dhule & Shri Manoj Kumar Singh, Drs’ Date Of Hearing: 26.03.2024 Date Of Pronouncement : 26.03.2024

For Appellant: Shri Sandeep Suilgol, AdvocateFor Respondent: Shri Dr. Kishor Dhule &
Section 10ASection 143(3)Section 144C

Technology, Software Solution and maintenance and technology, infrastructure support services to other City Group entities. The company has set up new units in Software Technology Parks of India in Mumbai and Chennai with effect from 17th February, 2005. The assessee has claimed deduction under Section ... claim of the above sum. The assessee during the course of assessment proceedings explained the fact that the units was set up in software technology park of India and profit derived by them are allowable for deduction under Section 10A of the Act. The assessee explains the Provision of Section

Larsen & Tourbro Infotech Ltd, Mumbai vs. Asst CIT 2(2)(1), Mumbai

In the result, appeal of the assessee for A

ITA 585/MUM/2017[2007-08]Status: DisposedITAT Mumbai30 Nov 2023AY 2007-08
Section 10Section 10ASection 115JSection 143(3)Section 147Section 148

confirming the AO's action of treating revenue generated from overseas branches as not export service from India and as not derived from Software Technology Park Units ("STPI units") located in India and on that basis holding that in any case the deduction under Section 10A needed to be recomputed

Larsen & Toubro Infotech Ltd., Mumbai vs. DCIT-2(2)(1), Mumbai

In the result, appeal of the assessee for A

ITA 2641/MUM/2016[2006-07]Status: DisposedITAT Mumbai30 Nov 2023AY 2006-07
Section 10Section 10ASection 115JSection 143(3)Section 147Section 148

confirming the AO's action of treating revenue generated from overseas branches as not export service from India and as not derived from Software Technology Park Units ("STPI units") located in India and on that basis holding that in any case the deduction under Section 10A needed to be recomputed

Sureprep (India) P.Ltd, Mumbai vs. ITO WD 8(3)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5855/MUM/2014[2011-12]Status: DisposedITAT Mumbai03 Nov 2023AY 2011-12

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.2243/मुं/2013 (िन.व.2009-10) आअसं.5523/मुं/2013 (िन.व.2010-11) आअसं.5855/मुं/2014 (िन.व.2011-12) M/S. Sureprep (India) Private Limited, 4Th Floor, Dhantak Plaza, Makwana Road, Marol, Andheri(E), Mumbai – 400 034. Pan: Aahcs-9039-H ...... अपीलाथ" /Appellant बनाम Vs. The Income Tax Officer, Ward 8(3)(2), 2Nd Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Dalpat Shah & Ms. Arti Shah "ितवादी "ारा/Respondent By : Ms. Samrudhi Dhananjay Hande & Shri P.D. Chougule सुनवाई क" ितिथ/ Date Of Hearing : 25/08/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 03/11/2023 आदेश आदेश/ Order आदेश आदेश Per Vikas Awasthy, Jm: These Three Appeals By The Assessee For Assessment Years 2009-10, 2010-11 & 2011-12 Are Taken Up Together For Adjudication As The Issues Involved In These Appeals Are Identical. The Appeal Of Assessee For Assessment Year 2009-10 Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-18, Mumbai [ In Short ‘The Cit(A)’ ], Dated 02/01/2013

For Appellant: Shri Dalpat Shah & Ms. Arti ShahFor Respondent: Ms. Samrudhi Dhananjay Hande &
Section 10ASection 10A(7)Section 143(3)Section 1O

5523/MUM/2013(A.Y. 2010-11) assessee is charging $50 per tax return from Sureprep LLC. The assessee is registered with Software Technology Park of India and accordingly the assessee had claimed deduction u/s. 10A of the Income Tax Act, 1961 [in short ‘the Act]. The assessee commenced its business on 01/03/2004 ... business from 01/03/2004 i.e. during the period relevant to the assessment year 2004-05, but the assessee set up eligible undertaking in Software Technology Park after issuance of Letter of Permission on 30/03/2005 and after execution of Agreement with STPI Director on 04/04/2005. Thus, the first year of assessee

Sureprep (India)P.Ltd, Mumbai vs. ITO 8(3)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 5523/MUM/2013[2010-11]Status: DisposedITAT Mumbai03 Nov 2023AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.2243/मुं/2013 (िन.व.2009-10) आअसं.5523/मुं/2013 (िन.व.2010-11) आअसं.5855/मुं/2014 (िन.व.2011-12) M/S. Sureprep (India) Private Limited, 4Th Floor, Dhantak Plaza, Makwana Road, Marol, Andheri(E), Mumbai – 400 034. Pan: Aahcs-9039-H ...... अपीलाथ" /Appellant बनाम Vs. The Income Tax Officer, Ward 8(3)(2), 2Nd Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Dalpat Shah & Ms. Arti Shah "ितवादी "ारा/Respondent By : Ms. Samrudhi Dhananjay Hande & Shri P.D. Chougule सुनवाई क" ितिथ/ Date Of Hearing : 25/08/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 03/11/2023 आदेश आदेश/ Order आदेश आदेश Per Vikas Awasthy, Jm: These Three Appeals By The Assessee For Assessment Years 2009-10, 2010-11 & 2011-12 Are Taken Up Together For Adjudication As The Issues Involved In These Appeals Are Identical. The Appeal Of Assessee For Assessment Year 2009-10 Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-18, Mumbai [ In Short ‘The Cit(A)’ ], Dated 02/01/2013

For Appellant: Shri Dalpat Shah & Ms. Arti ShahFor Respondent: Ms. Samrudhi Dhananjay Hande &
Section 10ASection 10A(7)Section 143(3)Section 1O

5523/MUM/2013(A.Y. 2010-11) assessee is charging $50 per tax return from Sureprep LLC. The assessee is registered with Software Technology Park of India and accordingly the assessee had claimed deduction u/s. 10A of the Income Tax Act, 1961 [in short ‘the Act]. The assessee commenced its business on 01/03/2004 ... business from 01/03/2004 i.e. during the period relevant to the assessment year 2004-05, but the assessee set up eligible undertaking in Software Technology Park after issuance of Letter of Permission on 30/03/2005 and after execution of Agreement with STPI Director on 04/04/2005. Thus, the first year of assessee

Sureprep (India) P.Ltd, Mumbai vs. ITO RG 8(3)(2), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 2243/MUM/2013[2009-10]Status: DisposedITAT Mumbai03 Nov 2023AY 2009-10

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.2243/मुं/2013 (िन.व.2009-10) आअसं.5523/मुं/2013 (िन.व.2010-11) आअसं.5855/मुं/2014 (िन.व.2011-12) M/S. Sureprep (India) Private Limited, 4Th Floor, Dhantak Plaza, Makwana Road, Marol, Andheri(E), Mumbai – 400 034. Pan: Aahcs-9039-H ...... अपीलाथ" /Appellant बनाम Vs. The Income Tax Officer, Ward 8(3)(2), 2Nd Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020. ..... "ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri Dalpat Shah & Ms. Arti Shah "ितवादी "ारा/Respondent By : Ms. Samrudhi Dhananjay Hande & Shri P.D. Chougule सुनवाई क" ितिथ/ Date Of Hearing : 25/08/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 03/11/2023 आदेश आदेश/ Order आदेश आदेश Per Vikas Awasthy, Jm: These Three Appeals By The Assessee For Assessment Years 2009-10, 2010-11 & 2011-12 Are Taken Up Together For Adjudication As The Issues Involved In These Appeals Are Identical. The Appeal Of Assessee For Assessment Year 2009-10 Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-18, Mumbai [ In Short ‘The Cit(A)’ ], Dated 02/01/2013

For Appellant: Shri Dalpat Shah & Ms. Arti ShahFor Respondent: Ms. Samrudhi Dhananjay Hande &
Section 10ASection 10A(7)Section 143(3)Section 1O

5523/MUM/2013(A.Y. 2010-11) assessee is charging $50 per tax return from Sureprep LLC. The assessee is registered with Software Technology Park of India and accordingly the assessee had claimed deduction u/s. 10A of the Income Tax Act, 1961 [in short ‘the Act]. The assessee commenced its business on 01/03/2004 ... business from 01/03/2004 i.e. during the period relevant to the assessment year 2004-05, but the assessee set up eligible undertaking in Software Technology Park after issuance of Letter of Permission on 30/03/2005 and after execution of Agreement with STPI Director on 04/04/2005. Thus, the first year of assessee

Sureprep (India) P.Ltd, Mumbai vs. DCIT RG 8(3), Mumbai

In the result, appeal of assessee is allowed

ITA 8818/MUM/2011[2007-08]Status: DisposedITAT Mumbai31 Oct 2023AY 2007-08
Section 10ASection 143(3)Section 263Section 32(2)

providing outsourcing services, more particularly preparation of US Tax Return and development of software in connection therewith. The 2 assessee is registered with Software Technology Park of India. The assessee claimed deduction u/s. 10A of the Act amounting to Rs.25,04,380/ on profit and gains of eligible undertaking

M/S. Zensar Technologies Ltd, Mumbai vs. The DCIT -2(3), Mumbai

In the result, ground No.5 and the additional ground of appeal are allowed

ITA 2907/MUM/2008[2002-2003]Status: DisposedITAT Mumbai28 Aug 2023AY 2002-2003

Bench: Shri Vikas Awasthy & Shrigagan Goyalआअसं.2907/मुं/2008 ("न.व.2002-03) Zensar Technologies Ltd. Magnet House, 2Nd Floor, Narottam Morarjee Marg, Ballard Estate, Mumbai 400 038. Pan: Aaacf-0742-K ...... अपीलाथ"/Appellant बनाम Vs. Dy. Commissioner Of Income Tax, Circle 2(31), Mumbai Mumbai. ..... ""तवाद"/Respondent अपीलाथ" "वारा/ Appellant By Shri Nitesh Joshi, Advocate : ""तवाद" "वारा/Respondent By : S/Shri Jasdeep Singh, Cit-Dr & Pratap Narayan Sharma, Sr. Ar सुनवाई क" "त"थ/ Date Of Hearing : 02/06/2023 घोषणा क" "त"थ/ Date Of Pronouncement : 28/08/2023 आदेश/Order

For Respondent: S/Shri Jasdeep Singh, CIT-DR &
Section 10ASection 115JSection 234DSection 80HSection 94(7)

profits which are eligible for deduction under section 80HHE the export turnover and the total turnover should include the turnover of the following software technology parks. Rs.(in lakhs) i) SEEPZ 46.2 ii) Noida 18.08 iii) Ashoka Plaza 429.09 5. (a) The CIT(A) erred in holding that the amount ... Export Oriented Units (EOU), the profits from which are eligible for deduction u/s. 10A of the Act. The said units are located at Software Technology Parks at SEEPZ, Noida and Ashok Plaza. As per section 80HHE(3) of the Act, profits derived from business referred to in section 80HHE

Career Point Limited, Kota, Rajasthan vs. Principal Commissioner of Income Tax, Udaipur, Rajasthan

In the result, the appeal of the assessee is allowed

ITA 242/JPR/2023[2018-19]Status: DisposedITAT Jaipur22 Aug 2023AY 2018-19

Bench: HON’BLE SHRI SANDEEP GOSAIN, JM & HON’BLE SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Vijay Goyal, CA &For Respondent: Shri Ajey Malik (CIT)
Section 143(2)Section 143(3)Section 14ASection 263

said circular. The said circular emphasizes that lease rent received by the assessee from letting out the building alongwith other amenities in a Software Technology Park would be chargeable to tax under the head ‘’Income from House Property’’. Therefore, in this way, every case of ‘’letting out buildings alongwith other ... amenities’’ would automatically fall in the income from business and it will not be merely restricted to Software Technology Park only as has been wrongly understood by ld. PCIT. It is important to mention here that the AO after detailed enquiries and verification on completed the assessment

Software Technology Parks of India, New Delhi vs. ACIT, CPC TDS, New Delhi

In the result, the appeal of the assessee is allowed

ITA 1118/DEL/2022[2018-19]Status: DisposedITAT Delhi31 Jul 2023AY 2018-19

Bench: Sh. C. M. Gargdr. B. R. R. Kumar

For Appellant: Sh. Atul Ninawat, AdvFor Respondent: Sh. Anuj Garg, Sr. DR
Section 154Section 200ASection 201Section 220(2)Section 250

DELHI Before Sh. C. M. Garg, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 1118/Del/2022 : Asstt. Year: 2018-19 Software Technology Parks of India, Vs ACIT, 1st Floor, Plate B, Office Block-1, East CPC, TDS, Didwai Nagar, New Delhi-110023 Ghaziabad, U.P.-201010 (APPELLANT) (RESPONDENT ... facts and circumstances of the case by passing the order u/s 250 of the Act, in violation of the principles of 2 Software Technology Parks of India natural justice by completely disregarding the adjournment request of the Appellant. 4. The Ld. AO as well as Ld. CIT(A) has erred

Accenture Solutions P Ltd (Asol), Mumbai vs. Addl/Jt/ Dy/CIT/Asstt/ITO, National Faceless Assessment Centre, Delhi & the Dy CIT, Circle-14(1)(1), Mumbai

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

ITA 1255/MUM/2021[2016-17]Status: DisposedITAT Mumbai13 Jul 2023AY 2016-17

Bench: Shri Amit Shukla & Shri Amarjit Singhaccenture Solutions Vs. Additional/Joint/Deputy/ Private Limited (‘Asol’) Assistant Commissioner Plant 3, Godrej & Boyce Of Income Tax/Income- Complex, Phirojshah Tax Officer, National Nagar, Vikhroli West, Facelless Assessment Off L.B.S Marg, Centre, Delhi Mumbai – 400079 The Dcit, Circle 14(1)(1) स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaach3235M Appellant .. Respondent Appellant By : Nishant Thakkar/ Hiten Chande/ Ms. Jasmin Amalsadvala Respondent By : Azhar Zain Vayal Parambath Date Of Hearing 22.05.2023 Date Of Pronouncement 13.07.2023 आदेश / O R D E R Per Amarjit Singh (Am): This Appeal Filed By The Assesse Is Directed Against The Order Passed By The Ao (National Assessment Centre) Mumbai- 2, Dated 18.03.2021 For A.Y. 2016-17 As Per The Direction Of The Drp Issued U/S 144C (5) Of The Act. The Assessee Has Raised The Following Grounds Before Us: “On The Facts & Circumstances Of The Case & In Law, The Learned Ao Transfer Pricing Officer (Tpo), Based On The Directions Of The Hon'Ble Drp Has: General Ground 1. Erred In Assessing The Total Income Of The Appellant At Rs.2888,33,73,016 Against A Total Income Of Rs.2179,39,30,620 As Reported By The Appellant In Its Revised Return Of Income & Determining A Demand Of Rs.2186,98,55,847 Payable By The Appellant.

For Appellant: Nishant Thakkar/ Hiten Chande/For Respondent: Azhar Zain Vayal Parambath
Section 144CSection 92CSection 92C(3)

providing I.T software development, BPO and consulting services. During the course of assessment the assesse operated out of several units located in the Software Technology Park of India (STPI) and Special Economic Zone (SEZ) and claimed a deduction u/s 10AA of the Act in respect of the profits earned from

Larsen & Toubro Infotech Ltd, Mumbai vs. Addl CIT RG 2(2), Mumbai

ITA 1924/MUM/2014[2009-10]Status: DisposedITAT Mumbai31 May 2023AY 2009-10
For Appellant: Shri Percy J PardiwallaFor Respondent: Dr. Yogesh Kamat, CIT DR
Section 10ASection 143(2)Section 143(3)Section 144C(13)Section 144C(5)Section 92C

onsite software development services rendered by the appellant to its customers do not form part of exports of the Undertaking comprised in the Software Technology Park Units (“STPI Units”) and on that basis holding that in any case the deduction under Section 10A needed to be recomputed and reduced

Tcs E- Serve Ltd ( Earlier Known As E- Serve International Ltd), Mumbai vs. DCIT RG 9(1), Mumbai

Accordingly, ITA number 7448/M/2010 for assessment year 2005 – 06 filed by the learned assessing officer is dismissed

ITA 2540/MUM/2011[2005-06]Status: DisposedITAT Mumbai18 Apr 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No.151/Mm/2012 (Arising In Ita No. 2380/Mum/2011 For A.Y. 2005-06) Tata Consultancy Services The Additional Commissioner Limited Of Income-Tax (Upon Merger Of Tcs E-Serve 9(1) Limited With Tata Consultancy Aaykar Bhavan, Services Limited) Vs. 9Th Floor, Nirmal Building, M. Karve Road, Nariman Point, Mumbai-400 020 Mumbai-400 020 (Appellant/Cross Objector) (Respondent) Pan No. Aaacc4480F

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 10Section 14Section 143

year 2000 as an independent unit and the unit were located in entirely separate identifiable custom bond areas. It has a separate software technology Park registration for each premises. The claim of the assessee is that these are independent units located in entirely separate identifiable custom bond area, they have

ACIT 9(3), Mumbai vs. Tcs E-Serve Ltd, Mumbai

Accordingly, ITA number 7448/M/2010 for assessment year 2005 – 06 filed by the learned assessing officer is dismissed

ITA 2380/MUM/2011[2005-06]Status: DisposedITAT Mumbai18 Apr 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No.151/Mm/2012 (Arising In Ita No. 2380/Mum/2011 For A.Y. 2005-06) Tata Consultancy Services The Additional Commissioner Limited Of Income-Tax (Upon Merger Of Tcs E-Serve 9(1) Limited With Tata Consultancy Aaykar Bhavan, Services Limited) Vs. 9Th Floor, Nirmal Building, M. Karve Road, Nariman Point, Mumbai-400 020 Mumbai-400 020 (Appellant/Cross Objector) (Respondent) Pan No. Aaacc4480F

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 10Section 14Section 143

year 2000 as an independent unit and the unit were located in entirely separate identifiable custom bond areas. It has a separate software technology Park registration for each premises. The claim of the assessee is that these are independent units located in entirely separate identifiable custom bond area, they have

ACIT 9(3), Mumbai vs. Tcs E-Serve Ltd, Mumbai

Accordingly, ITA number 7448/M/2010 for assessment year 2005 – 06 filed by the learned assessing officer is dismissed

ITA 7448/MUM/2010[2005-06]Status: DisposedITAT Mumbai18 Apr 2023AY 2005-06

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No.151/Mm/2012 (Arising In Ita No. 2380/Mum/2011 For A.Y. 2005-06) Tata Consultancy Services The Additional Commissioner Limited Of Income-Tax (Upon Merger Of Tcs E-Serve 9(1) Limited With Tata Consultancy Aaykar Bhavan, Services Limited) Vs. 9Th Floor, Nirmal Building, M. Karve Road, Nariman Point, Mumbai-400 020 Mumbai-400 020 (Appellant/Cross Objector) (Respondent) Pan No. Aaacc4480F

For Appellant: Shri Niraj Sheth, ARFor Respondent: Shri Manoj Kumar, CIT DR
Section 10Section 14Section 143

year 2000 as an independent unit and the unit were located in entirely separate identifiable custom bond areas. It has a separate software technology Park registration for each premises. The claim of the assessee is that these are independent units located in entirely separate identifiable custom bond area, they have

ACIT, Circle-31(1), New Delhi vs. Lotus Herbals Color Cosmetics, New Delhi

ITA 4191/DEL/2017[ 2013-14]Status: HeardITAT Delhi07 Feb 2023

Bench: Shri Shamim Yahya & Shri Anubhav Sharma[Assessment Year: 2013-14]

Section 80I

Export Processing Zone or Integrated Infrastructure Development Centre or Industrial CO No.63/Del/2021 Growth Centre or Industrial Estate or Industrial Park or Software Technology Park or Industrial Area or Theme Park, as notified by the Board in accordance with the scheme framed and notified by the Central Government in this regard ... April, 2012, in any Export Processing Zone or Integrated Infrastructure Development Centre or Industrial Growth Centre or Industrial Estate or Industrial Park or Software Technology Park or Industrial Area or Theme Park, as notified by the Board in accordance with the scheme framed and notified by the Central Government

Mwh India Pvt. Ltd., Mumbai vs. I.T.O. 9(2)(3), Mumbai

In the result, the appeal of the assesse is allowed

ITA 3143/MUM/2019[2007-08]Status: DisposedITAT Mumbai29 Dec 2022AY 2007-08

Bench: Shri Vikas Awasthy & Shri Amarjit Singhmwh India Private Ltd. Vs. Income Tax Officer, 168, Udyog Bhavan, Circle-9(2)(3), Sonawala Road, Room No. 147B, Goregaon (East) Aaykar Bhavan, M.K. Mumbai-400 063 Road, Churchgate, Mumbai – 400 020 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaca4613L Appellant .. Respondent Appellant By : Niraj Sheth Respondent By : Mahita Nair

For Appellant: Niraj ShethFor Respondent: Mahita Nair
Section 10ASection 10BSection 143(2)Section 143(3)Section 234Section 234B

assessment year 2007-08 it was first time realized that Pune Unit was only 100% export oriented undertaking registered with the Software Technology Park (STP), therefore, Pune Unit was eligible for deduction u/s 10A of the Income Tax Act, and not u/s 10B of the Income ... record. Without reiterating the facts as elaborated above the assesse claimed that Pune unit was registered as 100% export oriented undertaking with the Software Technology Park at Pune (STP) and was eligible for a deduction u/s 10A of the Act. Earlier the assesse had claimed deduction

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

In the result, the appeal filed by the assessee stands partly allowed

ITA 209/BANG/2021[2016-17]Status: DisposedITAT Bangalore30 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 209/Bang/2021 Assessment Year : 2016-17 M/S. Applied Materials India Pvt. Ltd., Unit -5, 3Rd Floor, The Deputy Explorer Building, Commissioner Of International Tech Income Tax, Park, Circle – 1(1)(1), Whitefield Road, Vs. Bangalore. Bangalore – 560 001. Pan: Aaeca2635C Appellant Respondent : Shri T. Suryanarayana, Assessee By Advocate : Dr. Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 30-11-2022 Date Of Pronouncement : 30-11-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 31/03/2021 Passed By The National E-Assessment Centre, Delhi For A.Y. 2016-17 On Following Grounds Of Appeal:

For Respondent: Shri T. Suryanarayana
Section 143(1)Section 143(2)Section 195Section 40Section 92C

technical product support and design services to its Holding Company. The Company is registered as a 100% export oriented unit ("EOU") with the Software Technology Park of India and was eligible for a tax holiday up to 31st March, 2011.The assessee filed its ITR for the AY 2016-17 electronically