TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

TDS was not done thereon, the payments are liable for disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source from out of the payments made to non-residents. Under Section 195 of the Act, an obligation is cast on a person making payment

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

TDS was not done thereon, the payments are liable for disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source from out of the payments made to non-residents. Under Section 195 of the Act, an obligation is cast on a person making payment

TECNOTREE CONVERGENCE LT D,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

TDS was not done thereon, the payments are liable for disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source from out of the payments made to non-residents. Under Section 195 of the Act, an obligation is cast on a person making payment

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

10A of the Income Tax Act, 1961 (in short ‘the Act’) and ‘book profits’ under section 115JB of the Act amounting to Rs.4,98,44,075/-. The assessee subsequently filed a revised return on 19.01.2009 to claim credit for TDS

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

10A of the Income Tax Act, 1961 (in short ‘the Act’) and ‘book profits’ under section 115JB of the Act amounting to Rs.4,98,44,075/-. The assessee subsequently filed a revised return on 19.01.2009 to claim credit for TDS

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

10A of the Income Tax Act, 1961 (in short ‘the Act’) and ‘book profits’ under section 115JB of the Act amounting to Rs.4,98,44,075/-. The assessee subsequently filed a revised return on 19.01.2009 to claim credit for TDS

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

10A(4) of the Act. (3) No agreement with states : 64. Whether the assessee is entitled to the aforesaid benefit when India has no agreement with the States where tax is levied on the income of the assessee. IT(TP)A Nos.99/Bang/2014, 398/Bang/2015, 222/Bang/2016, 492/Bang/2017, 2851/Bang/2-17, 3115/Bang/2018, 151/Bang/2014, 467/Bang/2015 & 609/Bang/2016 M/s. Wipro Limited, Bangalore Page 46 of 202 65. Section

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

10A(4) of the Act. (3) No agreement with states : 64. Whether the assessee is entitled to the aforesaid benefit when India has no agreement with the States where tax is levied on the income of the assessee. IT(TP)A Nos.99/Bang/2014, 398/Bang/2015, 222/Bang/2016, 492/Bang/2017, 2851/Bang/2-17, 3115/Bang/2018, 151/Bang/2014, 467/Bang/2015 & 609/Bang/2016 M/s. Wipro Limited, Bangalore Page 46 of 202 65. Section

DCIT, BANGALORE vs. M/S HEWLETT PACKARD GLOBALSOFT PVT. LTD.,, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

10A and was closed in the year 2007-08. It is submitted that STPI unit I & II is located in Bangalore. Whereas STPI Unit V & VI are located in Chennai. Further admittedly STPI Unit I & II performed ITeS services whereas STPI Unit V & VI are into SWD services. “Hon'ble Supreme Court in the case of Textile Machinery Corporation

HEWLETT-PACKARD GLOBALSOFT PRIVATE LIMTIED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

10A and was closed in the year 2007-08. It is submitted that STPI unit I & II is located in Bangalore. Whereas STPI Unit V & VI are located in Chennai. Further admittedly STPI Unit I & II performed ITeS services whereas STPI Unit V & VI are into SWD services. “Hon'ble Supreme Court in the case of Textile Machinery Corporation

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, Revenue’s appeal for Assessment Year 2006-07 is partly allowed for statistical purposes

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

TDS and therefore not liable for disallowance under Section 40(a)(i) of the Act. Consequently, Ground No.3 of Revenue’s appeal is dismissed. 23 IT(TP)A Nos.799 & 942/Bang/2015 Infosys Limited 21. Ground No.4 - Computation of deduction u/s. 10A

INFOSYS LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

DY.C.I.T., BANGALORE vs. M/S INFOSYS LIMITED, BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

ASST.C.I.T., BANGALORE vs. M/S INFOSYS LTD.,, BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

INFOSYS LTD ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

M/S INFOSYS LTD ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

M/S INFOSYS LTD ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

INFOSYS LTD,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE vs. M/S INFOSYS LTD , BANGALORE

In the result, the appeals filed by the assessee and revenue stands partly allowed as indicated hereinabove

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

section 10A Ld.AO to verify the 1 to 3 and 10AA as per the decision of FTC paid and to the Jurisdictional High Court allow the claim Page 7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro