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“STPI unit”

DeductionsSection 10ASection 10A75 judgments

ACIT, CIRCLE-1(1)(1), BENGALURU vs. ACUITY KNOWLEDGE CENTRE(INDIA) PVT LTD, BENGALURU

In the result, the appeal of the Revenue is hereby dismissed

ITA 2334/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Dec 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year: 2014-15

For Appellant: Ms. Mansa Ananthan, Advocate &For Respondent: Dr. Divya K.J, CIT-DR
Section 250Section 37Section 43B

assessment proceeding asked the assessee to explain the basis of allocation of common and non-identifiable expenses among its different units, namely the STPI unit, SEZ unit and non-eligible unit. On verification of the details, it was observed that several common expenses such as corporate overheads, top management remuneration ... Before the learned CIT(A), the assessee submitted that it is engaged in providing services through three separate units, namely the STPI unit, SEZ Unit-I and SEZ Unit-II. The assessee explained that it follows a cost-plus mark-up model, under which revenue of each unit is computed

ACUITY KNOWLEDGE CENTRE (INDIA) PRIVATE LIMITED,BENGALURU vs. THE DEPUTY COMMISSION OF INCOME TAX, CIRCLE1(1)(1), BENGALURU , BENGALURU

In the result, the appeal of the Revenue is hereby dismissed

ITA 2153/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Dec 2025AY 2014-15

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year: 2014-15

For Appellant: Ms. Mansa Ananthan, Advocate &For Respondent: Dr. Divya K.J, CIT-DR
Section 250Section 37Section 43B

assessment proceeding asked the assessee to explain the basis of allocation of common and non-identifiable expenses among its different units, namely the STPI unit, SEZ unit and non-eligible unit. On verification of the details, it was observed that several common expenses such as corporate overheads, top management remuneration ... Before the learned CIT(A), the assessee submitted that it is engaged in providing services through three separate units, namely the STPI unit, SEZ Unit-I and SEZ Unit-II. The assessee explained that it follows a cost-plus mark-up model, under which revenue of each unit is computed

DCIT, BANGALORE vs. M/S THOMSON REUTERS INDIA SERVICES PVT. LTD.,, BANGALORE

In the result, appeal filed by revenue in IT(TP)

ITA 843/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

learned Panel erred in denying deduction under section 10A of the Act in respect of UB Plaza Software Technology Parks of India (‘STPI’) Unit. b) That the learned AO failed to appreciate that no new undertaking was formed and the Company was continuing the business of the existing undertaking already ... case, the learned AO and the learned Panel erred in denying deduction under section 10A of the Act in respect of Titanium STPI Unit. b) That the learned AO and the learned Panel failed to appreciate that Titanium unit is a newly established undertaking and has received STPI approval

M/S THOMSON REUTERS INTERNATIONAL SERVICES PRIVATE LIMITED,MUMBAI vs. DCIT, BANGALORE

ITA 542/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11
Section 10ASection 10A(2)Section 143(3)

nthe learned Panel erred in denying deduction under section 10A of the Act\nin respect of UB Plaza Software Technology Parks of India (‘STPI) Unit.\nb) That the learned AO failed to appreciate that no new undertaking was\nformed and the Company was continuing the business of the existing\nundertaking ... case, the learned AO and\nthe learned Panel erred in denying deduction under section 10A of the Act\nin respect of Titanium STPI Unit.\nb) That the learned AO and the learned Panel failed to appreciate that\nTitanium unit is a newly established undertaking and has received STPI\napproval

DCIT, BANGALORE vs. M/S THOMSON CORPORATION (INTERNATIONAL) PVT. LTD.,, BANGALORE

ITA 234/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11
Section 10ASection 10A(2)Section 143(3)Section 7A

nthe learned Panel erred in denying deduction under section 10A of the Act\nin respect of UB Plaza Software Technology Parks of India (‘STPI) Unit.\nb) That the learned AO failed to appreciate that no new undertaking was\nformed and the Company was continuing the business of the existing\nundertaking ... case, the learned AO and\nthe learned Panel erred in denying deduction under section 10A of the Act\nin respect of Titanium STPI Unit.\nb) That the learned AO and the learned Panel failed to appreciate that\nTitanium unit is a newly established undertaking and has received STPI\napproval

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-19, NEW DELHI vs. KOYA AND COMPANY CONSTRUCTION LIMITED, HYDERABAD

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

ITA 2177/DEL/2023[2017-18]Status: DisposedITAT Delhi26 Nov 2025AY 2017-18

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareekdcit, Vs. M/S. Koya & Company Construction Ltd. Central Circle 19, 12-2-831/38/1, 72 Migh, New Delhi. Mehdipatnam, Hyderabad – 500 028 (Telangana). (Pan :Aacck3240R) (Appellant) (Respondent) Assessee By : Shri K.C. Devdas, Ar Revenue By : Shri Shankar Gupta, Sr. Dr Date Of Hearing : 13.10.2025 Date Of Order : 26.11.2025 Order Per S. Rifaur Rahman:

For Appellant: Shri K.C. Devdas, ARFor Respondent: Shri Shankar Gupta, Sr. DR
Section 139(1)Section 142(1)Section 143(2)Section 92CSection 92D

coming to the facts of the present case where the assessee had shown profits from its Engineering Design & Development Services which was an STPI unit and had shown the net pro.fit range of 72.98%, and the international transaction of the assessee with its Associated Enterprises had been accepted

DCIT CIRCLE 4(2), NEW DELHI vs. CANON INDIA PVT. LTD., NEW DELHI

In the result, to sum up and conclude:

ITA 1038/DEL/2023[2005-06]Status: DisposedITAT Delhi10 Nov 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

deduction u/s 10A of the Income tax Act, 1961 [hereinafter referred to as 'The Act' for short] was claimed against income earned by its STPI unit of RS 3,05,13,171/- Subsequently, the AO framed the assessment u/s 143(3) of the Act on 31.03.2006 at NIL income after ... 04/DEL/2025 ITA No. 1038/DEL/2023 [A.Y. 2005-06] Canon India Pvt Ltd Sl. Particulars Amount (Rs.) No A PGBP Income from Non STPI Unit (4,83,42,879) B1 Gross PGBP Income from STPI Unit 3,39,03,523 B2 Less: Income Exempt

CANON INDIA PVT. LTD,GURUGRAM vs. NEAC, DELHI

In the result, to sum up and conclude:

ITA 585/DEL/2021[2003-04]Status: DisposedITAT Delhi10 Nov 2025AY 2003-04

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Himanshu Sinha, AdvFor Respondent: Shri Vijay B. Basanta, CIT-DR
Section 10ASection 143(3)Section 254Section 92C

deduction u/s 10A of the Income tax Act, 1961 [hereinafter referred to as 'The Act' for short] was claimed against income earned by its STPI unit of RS 3,05,13,171/- Subsequently, the AO framed the assessment u/s 143(3) of the Act on 31.03.2006 at NIL income after ... 04/DEL/2025 ITA No. 1038/DEL/2023 [A.Y. 2005-06] Canon India Pvt Ltd Sl. Particulars Amount (Rs.) No A PGBP Income from Non STPI Unit (4,83,42,879) B1 Gross PGBP Income from STPI Unit 3,39,03,523 B2 Less: Income Exempt

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 2112/MUM/2025[2013-14]Status: DisposedITAT Mumbai22 Sept 2025AY 2013-14

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Sukhsagar Syal, AdvocateFor Respondent: Shri Umashankar Prasad, CIT DR
Section 10ASection 143(3)Section 147Section 35(1)(ii)

fact that the appellant is in the business of developing software used for electronic exchanges and it has two units: one STPI unit and another SEZ unit. The appellant company has various subsidiary companies in various countries such as Dubai, UK, Singapore, and Mauritius. During the assessment proceedings the appellant

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 2111/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Sept 2025AY 2012-13

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Sukhsagar Syal, AdvocateFor Respondent: Shri Umashankar Prasad, CIT DR
Section 10ASection 143(3)Section 147Section 35(1)(ii)

fact that the appellant is in the business of developing software used for electronic exchanges and it has two units: one STPI unit and another SEZ unit. The appellant company has various subsidiary companies in various countries such as Dubai, UK, Singapore, and Mauritius. During the assessment proceedings the appellant

DCIT(CC)-8(3), MUMBAI vs. 63 MOONS TECHNOLOGIES LIMITED, MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 2110/MUM/2025[2011-12]Status: DisposedITAT Mumbai22 Sept 2025AY 2011-12

Bench: Shri Sandeep Gosain & Shri Girish Agrawal

For Appellant: Shri Sukhsagar Syal, AdvocateFor Respondent: Shri Umashankar Prasad, CIT DR
Section 10ASection 143(3)Section 147Section 35(1)(ii)

fact that the appellant is in the business of developing software used for electronic exchanges and it has two units: one STPI unit and another SEZ unit. The appellant company has various subsidiary companies in various countries such as Dubai, UK, Singapore, and Mauritius. During the assessment proceedings the appellant

NIELSEN (INDIA) P.LTD,MUMBAI vs. DCIT RG 6(1), MUMBAI

The appeal is dismissed as withdrawn

ITA 3581/MUM/2015[2009-10]Status: DisposedITAT Mumbai31 Jul 2025AY 2009-10

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3581/Mum/2015 (नििाारण वर्ा / Assessment Year: 2009-10) M/S. Nielsen (India) V/S. Deputy Private Limited बिाम Commissioner Of (Formerly Known As Income Tax Range– Acnielsen Org-Marg 6(1), Mumbai Private Limited) Aaykar Bhavan, Mumbai 6Th Floor, Block C, Godrej It 400020 Park, 02, Godrej Business District, Lbs Marg, Phirojshanagar, Vikhroli (W), Mumbai 400079 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacm9279L Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Paras S. Savla राजस्व की ओर से /Revenue By: Ms. Neena Jeph, Cit Dr

For Appellant: Shri Paras S. SavlaFor Respondent: Ms. Neena Jeph, CIT DR
Section 250Section 43B

ought to have appreciated that transfer pricing is an anti-avoidance provision and in the present case both EUREKA and RRC divisions are registered STPI units and there is no intention of appellant to shift the profits. P a g e | 3 ITA NO. 3581/Mum/2015 AY 2009-10 M/s. Nielsen

AB INBEV GCC SERVICES INDIA PRIVATE LIMITED,BANGALORE, KARNATAKA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1) , BANGALORE

In the result, appeal is allowed for statistical purposes

ITA 1635/BANG/2024[2020-21]Status: DisposedITAT Bangalore13 May 2025AY 2020-21

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.1635/Bang/2024 Assessment Year :2020-21

For Appellant: Shri. Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bangalore
Section 143(3)Section 144BSection 153Section 92B

engaged in providing IT enabled back-office support services to its group entities as a captive service provider. The tax payer, through its STPI Unit viz., GAC is engaged in providing analytical support services to its group entities. Analytical support services involve using data that is generated from the business

DY. COMMISSIONER OF INCOME TAX, MUMBAI vs. M/S INFRASOFT TECHNOLOGIES LTD., MUMBAI

In the result, appeal of the Revenue is dismissed

ITA 5769/MUM/2024[2006-07]Status: DisposedITAT Mumbai31 Dec 2024AY 2006-07

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2006-07

For Appellant: Shri Tarang Mehta, ARFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10ASection 143Section 143(3)Section 254

demonstrated with various details contained in financial records such as invoices, remittances, existence of domestic unit, etc. Assessee had also shown approval of STPI Unit dated 28.03.2000 which stated that there is specific reference to the Unit located at the new premise. Assessee had also demonstrated the investment made ... fixed assets separately maintained for STPI Unit. Thus, on careful consideration of the order of the Ld. CIT(A), Co-ordinate Bench did not find any infirmity in the same and held that conditions laid down for claiming deduction under section 10A were fulfilled by the assessee. Accordingly, order

DCIT CENTRAL CIRCLE 5 4, MUMBAI , MUMBAI vs. L AND T VALDEL ENGINEERING LIMITED, BANGALURU

In the result, all appeals filed by the assessee stands allowed and appeals filed by the revenue stands dismissed for all assessment years under consideration

ITA 4767/MUM/2023[2011-12]Status: DisposedITAT Mumbai30 Oct 2024AY 2011-12

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

unit is set up. It was further held that even from perusal of assets, the assessee has purchased few computers for the use of STPI unit and the assessee has not purchased any land for the use of STPI unit. The Assessing Officer therefore, concluded that the assessee has only

DCIT CENTRAL CIRCLE 5(4), MUMBAI vs. L AND T VALDEL ENGINEERING LIMITED, BANGALURU

In the result, all appeals filed by the assessee stands allowed and appeals filed by the revenue stands dismissed for all assessment years under consideration

ITA 4715/MUM/2023[2013-14]Status: DisposedITAT Mumbai30 Oct 2024AY 2013-14

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

unit is set up. It was further held that even from perusal of assets, the assessee has purchased few computers for the use of STPI unit and the assessee has not purchased any land for the use of STPI unit. The Assessing Officer therefore, concluded that the assessee has only

DCIT CC -5 (4), MUMBAI, MUMBAI vs. L AND T VALDEL ENGINEERING LIMITED, MUMBAI

In the result, all appeals filed by the assessee stands allowed and appeals filed by the revenue stands dismissed for all assessment years under consideration

ITA 4684/MUM/2023[2015-16]Status: DisposedITAT Mumbai30 Oct 2024AY 2015-16

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

unit is set up. It was further held that even from perusal of assets, the assessee has purchased few computers for the use of STPI unit and the assessee has not purchased any land for the use of STPI unit. The Assessing Officer therefore, concluded that the assessee has only

DCIT CENTRAL CIRCLE 5 4 MUMBAI, MUMBAI vs. L AND T VALDEL ENGINEERING LIMITED, BANGALURU

In the result, all appeals filed by the assessee stands allowed and appeals filed by the revenue stands dismissed for all assessment years under consideration

ITA 4683/MUM/2023[2014-15]Status: DisposedITAT Mumbai30 Oct 2024AY 2014-15

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

unit is set up. It was further held that even from perusal of assets, the assessee has purchased few computers for the use of STPI unit and the assessee has not purchased any land for the use of STPI unit. The Assessing Officer therefore, concluded that the assessee has only

DCIT CENTRAL CIRCLE 5 4, MUMBAI, MUMBAI vs. L AND T VALDEL ENGINEERING LIMITED, KARNATAKA

In the result, all appeals filed by the assessee stands allowed and appeals filed by the revenue stands dismissed for all assessment years under consideration

ITA 4682/MUM/2023[2012-13]Status: DisposedITAT Mumbai30 Oct 2024AY 2012-13

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

unit is set up. It was further held that even from perusal of assets, the assessee has purchased few computers for the use of STPI unit and the assessee has not purchased any land for the use of STPI unit. The Assessing Officer therefore, concluded that the assessee has only

LARSEN & TOUBRO LIMITED (SUCCESSOR TO M/S L & T VA;DE; ENGINEERING LIMITED ),MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 5(4) MUMBAI (EARLIER AO DCITM CIRCLE 11(5) BANGALORE, MUMBAI

In the result, all appeals filed by the assessee stands allowed and appeals filed by the revenue stands dismissed for all assessment years under consideration

ITA 4555/MUM/2023[2015-16]Status: DisposedITAT Mumbai30 Oct 2024AY 2015-16

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

unit is set up. It was further held that even from perusal of assets, the assessee has purchased few computers for the use of STPI unit and the assessee has not purchased any land for the use of STPI unit. The Assessing Officer therefore, concluded that the assessee has only

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