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17 results for “TDS”+ Section 139Aclear

Sorted by relevance

Bangalore17Jaipur12Delhi5Kolkata2Chennai2Visakhapatnam1Hyderabad1Mumbai1Pune1Jabalpur1

Key Topics

Section 206A77Section 80J20Section 201(1)18Deduction14Section 15413Section 195A12Section 19510Section 2019Double Taxation/DTAA9TDS

M/S WIPRO LTD. vs. ITO,

In the result, the appeals of the assessee are allowed and S

ITA 1544/BANG/2013[2010-11]Status: DisposedITAT Bangalore12 Feb 2016AY 2010-11

Bench: Shri Abraham P George & Shri Vijaypal Rao

For Appellant: Shri B.K. Manjunatha, C.AFor Respondent: Shri Rajashekar, Addl. CIT (D.R)
Section 139ASection 156Section 200ASection 206ASection 90(2)Section 90A(2)

section 139A. On the facts and circumstances of the case and law applicable and considering the fact that there was no requirement under law for the non-resident deductees to obtain PAN, the higher rate of TDS

8
Section 200A6
Addition to Income5

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

ITA 652/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19
Section 143(3)Section 80J

section 139A(1) of the Act, PAN is required only when\nan individual has income above the basic exemption limit. As per the\nCBDT circular on salary TDS

DY DIT vs. M/S INFOSYS BPO LTD.,,

In the result, all the appeals of the revenue and the cross

ITA 1143/BANG/2013[2011-12]Status: DisposedITAT Bangalore29 Jun 2015AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Jason P Boaz

For Respondent: Dr. P.K.Srihari, Addl.CIT
Section 115ASection 200A(1)Section 200A(1)(b)Section 206ASection 246A

section 139A. On the facts and circumstances of the case and law applicable and considering the fact that there was no requirement under law for the non-resident deductees to obtain PAN, the higher rate of TDS

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX , CIRCLE-2(1)(1), BANGALORE

In the result appeal of the assessee is hereby allowed

ITA 653/BANG/2025[2020-21]Status: DisposedITAT Bangalore18 Dec 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 143(3)Section 80J

section 139A(1) of the Act, PAN is required only when an individual has income above the basic exemption limit. As per the CBDT circular on salary TDS

DUSTERS TOTAL SOLUTIONS SERVICES PRIVATE LIMITED ,BANGALORE vs. DCIT, CIRCLE-2(1)(2), BANGALORE

In the result appeal of the assessee is hereby allowed

ITA 980/BANG/2025[2018-19]Status: DisposedITAT Bangalore18 Dec 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Smt. Kavita Jha, AdvocateFor Respondent: Shri Shivanand H Kalakeri, CIT (DR)
Section 143(3)Section 80J

section 139A(1) of the Act, PAN is required only when an individual has income above the basic exemption limit. As per the CBDT circular on salary TDS

DY.COMMISSIONER OF INCOME TAX, BANGALORE vs. HONEYWELL TECHNOLOGY SOLUTIONS LTD, BANGALORE

In the result, the appeal by the revenue is dismissed

ITA 563/BANG/2017[2012-13]Status: DisposedITAT Bangalore05 Aug 2020AY 2012-13

Bench: Shri N.V. Vasudevanand Shri B.R. Baskaran, Accoutant Member It(It)A Nos.562 To 564/Bang/2017 Assessment Years : 2011-12 To 2013-14

For Appellant: ShriFor Respondent: Smt. Shreya Loyalka, A.R
Section 201(1)Section 206A

TDS should be made by the assessee is 10% in accordance with the Treaty for Avoidance of Double Taxation between India and Germany (DTAA) and not at the higher rate of tax @ 20% by invoking the provisions of section 206AA of the Act. This submission was accepted by the CIT(A) and on the basis of the decision

DY.COMMISSIONER OF INCOME TAX, BANGALORE vs. HONEYWELL TECHNOLOGY SOLUTIONS LTD, BANGALORE

In the result, the appeal by the revenue is dismissed

ITA 562/BANG/2017[2011-12]Status: DisposedITAT Bangalore05 Aug 2020AY 2011-12

Bench: Shri N.V. Vasudevanand Shri B.R. Baskaran, Accoutant Member It(It)A Nos.562 To 564/Bang/2017 Assessment Years : 2011-12 To 2013-14

For Appellant: ShriFor Respondent: Smt. Shreya Loyalka, A.R
Section 201(1)Section 206A

TDS should be made by the assessee is 10% in accordance with the Treaty for Avoidance of Double Taxation between India and Germany (DTAA) and not at the higher rate of tax @ 20% by invoking the provisions of section 206AA of the Act. This submission was accepted by the CIT(A) and on the basis of the decision

DY.COMMISSIONER OF INCOME TAX, BANGALORE vs. HONEYWELL TECHNOLOGY SOLUTIONS LTD, BANGALORE

In the result, the appeal by the revenue is dismissed

ITA 564/BANG/2017[2013-14]Status: DisposedITAT Bangalore05 Aug 2020AY 2013-14

Bench: Shri N.V. Vasudevanand Shri B.R. Baskaran, Accoutant Member It(It)A Nos.562 To 564/Bang/2017 Assessment Years : 2011-12 To 2013-14

For Appellant: ShriFor Respondent: Smt. Shreya Loyalka, A.R
Section 201(1)Section 206A

TDS should be made by the assessee is 10% in accordance with the Treaty for Avoidance of Double Taxation between India and Germany (DTAA) and not at the higher rate of tax @ 20% by invoking the provisions of section 206AA of the Act. This submission was accepted by the CIT(A) and on the basis of the decision

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE vs. M/S HONEYWELL TECHNOLOGIES SOLUTIONS LAB PVT LTD , BANGALORE

In the result, the appeal by the revenue is dismissed

ITA 1418/BANG/2018[2014-15]Status: DisposedITAT Bangalore05 Aug 2020AY 2014-15

Bench: Shri N.V. Vasudevanand Shri B.R. Baskaran, Accoutant Member It(It)A Nos.562 To 564/Bang/2017 Assessment Years : 2011-12 To 2013-14

For Appellant: ShriFor Respondent: Smt. Shreya Loyalka, A.R
Section 201(1)Section 206A

TDS should be made by the assessee is 10% in accordance with the Treaty for Avoidance of Double Taxation between India and Germany (DTAA) and not at the higher rate of tax @ 20% by invoking the provisions of section 206AA of the Act. This submission was accepted by the CIT(A) and on the basis of the decision

CGI INFORMATION SYSTEMS AND MANAGEMENT CONSULTANTS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessee are allowed

ITA 737/BANG/2020[2013-14]Status: DisposedITAT Bangalore05 Apr 2021AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri. Chavali Narayan, CAFor Respondent: Shri. Ramesh Kumar, Addl. CIT(DR)(ITAT), Bengaluru
Section 154Section 201Section 201(1)Section 206ASection 90

139A(8)(d) of the Income-tax Act. We cannot agree with this contention ITA Nos.735 to 737/Bang/2020 Page 4 of 11 of the assessee. The provisions of sec. 206AA clearly overrides the other provisions of the Act. Therefore, a non resident whose income is chargeable to tax in India has to obtain PAN No. and provide the same

DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE- 1(1), BANGALORE vs. M/S. BHARAT FRITZ WARNER LIMITED, BANGALORE

In the result, the appeal by the revenue is dismissed

ITA 1360/BANG/2019[2011-12]Status: DisposedITAT Bangalore26 Jun 2020AY 2011-12

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

For Appellant: Shri Priyadarshi Mishra, Jt.CIT(DR)(ITAT), BengaluruFor Respondent: Shri S. Ramasubramanian, CA
Section 201(1)Section 206ASection 90(2)

TDS should be made by the assessee is 10% in accordance with the Treaty for Avoidance of Double Taxation between India and Germany (DTAA) and not at the higher rate of tax @ 20% by invoking the provisions of section 206AA of the Act. This submission was accepted by the CIT(A) and on the basis of the decision

DEPUTY COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), CIRCLE - 1(1), BANGALORE vs. M/S. EDGEVERVE SYSTEMS LIMITED, BANGALORE

In the result, the appeals are dismissed

ITA 13/BANG/2020[2018-19]Status: DisposedITAT Bangalore10 Sept 2020AY 2018-19

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. Sudheendra, AdvocateFor Respondent: Smt.R.Premi, JCIT , DR(ITAT)
Section 195Section 206ASection 248

TDS at the higher of the rates mentioned below: " At the rate specified in the relevant provision of the Act; IT(IT)A No.12 to 14/Bang/2020 M/S.Edgeverve Systems Ltd. " At the rate or rates in force, i.e., the rate prescribed in the Finance Act.; " At the rate of 20% 3. The AO rejected the plea of the Assessee that

DEPUTY COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), CIRCLE- 1(1), BANGALORE vs. M/S. EDGEVERVE SYSTEMS LIMITED, BANGALORE

In the result, the appeals are dismissed

ITA 12/BANG/2020[2017-18]Status: DisposedITAT Bangalore10 Sept 2020AY 2017-18

Bench: Shri N. V. Vasudevan & Shri Chandra Poojari

For Appellant: Shri. Sudheendra, AdvocateFor Respondent: Smt.R.Premi, JCIT , DR(ITAT)
Section 195Section 206ASection 248

TDS at the higher of the rates mentioned below: " At the rate specified in the relevant provision of the Act; IT(IT)A No.12 to 14/Bang/2020 M/S.Edgeverve Systems Ltd. " At the rate or rates in force, i.e., the rate prescribed in the Finance Act.; " At the rate of 20% 3. The AO rejected the plea of the Assessee that

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE vs. M/S MPHASIS LIMITED, BANGALORE

In the result, the appeals as well as the cross objections are dismissed

ITA 1691/BANG/2018[2010-11]Status: DisposedITAT Bangalore27 Nov 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri A. K. Garodia

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. K.V.Arvind, Advocate, Standing Counsel
Section 154Section 192Section 195Section 195ASection 201Section 201(1)

TDS u/s 192 is above taxable limit, the deductor will calculate the average rate of income-tax based on rates in force as provided in sec 192. If the tax so calculated is below 20%, deduction of tax will be made at the rate of 20% and in case the average rate exceeds 20%, tax is to deducted

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE vs. M/S MPHASIS LIMITED , BANGALORE

In the result, the appeals as well as the cross objections are dismissed

ITA 1693/BANG/2018[2012-13]Status: DisposedITAT Bangalore27 Nov 2019AY 2012-13

Bench: Shri N. V. Vasudevan & Shri A. K. Garodia

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. K.V.Arvind, Advocate, Standing Counsel
Section 154Section 192Section 195Section 195ASection 201Section 201(1)

TDS u/s 192 is above taxable limit, the deductor will calculate the average rate of income-tax based on rates in force as provided in sec 192. If the tax so calculated is below 20%, deduction of tax will be made at the rate of 20% and in case the average rate exceeds 20%, tax is to deducted

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE vs. M/S MPHASIS LIMITED , BANGALORE

In the result, the appeals as well as the cross objections are dismissed

ITA 1690/BANG/2018[2009-10]Status: DisposedITAT Bangalore27 Nov 2019AY 2009-10

Bench: Shri N. V. Vasudevan & Shri A. K. Garodia

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. K.V.Arvind, Advocate, Standing Counsel
Section 154Section 192Section 195Section 195ASection 201Section 201(1)

TDS u/s 192 is above taxable limit, the deductor will calculate the average rate of income-tax based on rates in force as provided in sec 192. If the tax so calculated is below 20%, deduction of tax will be made at the rate of 20% and in case the average rate exceeds 20%, tax is to deducted

DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE vs. M/S MPHASIS LIMITED , BANGALORE

In the result, the appeals as well as the cross objections are dismissed

ITA 1692/BANG/2018[2011-12]Status: DisposedITAT Bangalore27 Nov 2019AY 2011-12

Bench: Shri N. V. Vasudevan & Shri A. K. Garodia

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. K.V.Arvind, Advocate, Standing Counsel
Section 154Section 192Section 195Section 195ASection 201Section 201(1)

TDS u/s 192 is above taxable limit, the deductor will calculate the average rate of income-tax based on rates in force as provided in sec 192. If the tax so calculated is below 20%, deduction of tax will be made at the rate of 20% and in case the average rate exceeds 20%, tax is to deducted