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130 results for “TDS”+ Section 234Dclear

Sorted by relevance

Mumbai302Delhi217Bangalore130Kolkata33Hyderabad29Chennai27Ahmedabad26Raipur19Chandigarh13Jaipur8Pune7Surat3Dehradun2Karnataka2Rajkot2Visakhapatnam1Amritsar1Cochin1Indore1Jabalpur1Jodhpur1

Key Topics

Section 10A76Deduction57Addition to Income52Section 143(3)50Disallowance49Transfer Pricing40Section 92C38Section 15436Section 4035Section 234B

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

In the result, Revenue’s appeal for A

ITA 102/BANG/2013[2005-06]Status: DisposedITAT Bangalore10 Nov 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri H.N. Khincha, C.AFor Respondent: Shri R. N. Parbat, CIT-III (D.R)
Section 143(3)Section 195Section 40Section 92ASection 92C

234D.” 5. Ground No.1 being general in nature, no adjudication is called for thereon. 6. Ground No.2 - Disallowance of Subscription charges paid to Forrester Research Inc., USA. 6.1 This ground is raised by the assessee in respect of the disallowance under Section 40(a)(i) of the Act of subscription charges amounting to 7 IT(TP)A Nos.102 & 233/Bang/2013 Infosys

Showing 1–20 of 130 · Page 1 of 7

34
TDS32
Section 153A24

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

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

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

section 234B and 234D. Prayer 61. In view of the above and other grounds to be adduced at the time of hearing, the appellant prays that the DRP directions and the final assessment order passed by the learned AO be quashed or in the alternative, the aforesaid grounds and the relief prayed for there under be allowed. The appellant submits

M/S PLAYSIMPLE GAMES PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - 5(1)(2), BANGALORE

In the result, the appeal is allowed for statistical purposes

ITA 1125/BANG/2019[2016/17]Status: DisposedITAT Bangalore09 Mar 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Shri Deepak Kumar Jain, CAFor Respondent: Shri Priyadarshi Mishra, Addl.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 195Section 234BSection 234DSection 40Section 9(1)(vi)

section Page 5 of 9 234D is computed at Rs. 24,76,287/- and Rs. 11,297/- respectively. As a consequence, a sum of Rs. 1,00,82,021/- is determined as payable by the appellant. 7. Before the CIT(Appeals), the Appellant also submitted that the impugned payments do not constitute royalty or fees for technical services and supported

M/S ORION MALL MANAGEMENT COMPANY LIMITED ,BANGALORE vs. INCOME TAX OFFICER WARD-5(1)(2), BANGALORE

In the result appeal filed by assessee stands partly allowed

ITA 677/BANG/2018[2014-15]Status: DisposedITAT Bangalore14 Sept 2020AY 2014-15

Bench: Shri A.K Garodia & Smt. Beena Pillaiassessment Year : 2014-15

For Appellant: Shri B.R Sudheendra, C.AFor Respondent: Shri S Sundar Rajan, Addl. CIT(DR)
Section 143(2)Section 234BSection 234D

TDS credit should be fully allowed as claimed in the return of income. Levy of Interest under section 234B and 234D

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE vs. M/S SASKEN COMMUNICATION TECHNOLOGIES LTD , BANGALORE

In the result, the appeal of the assessee is partly allowed in the terms indicated above

ITA 882/BANG/2018[2005-06]Status: DisposedITAT Bangalore20 Dec 2019AY 2005-06

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

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Smt. Neera Malhotra, CIT DR
Section 41(1)

234D. Prayer 10. In view of the above and other grounds to be adduced at the time of hearing, the appellant prays that the order passed by the learned assessing officer under section 143(3) be quashed or in the alternative the additions/disallowances/variation to income returned and tax payable as sustained by the Id. CIT(A) be deleted

TEJAS NETWORKS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 694/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 621/BANG/2016[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

M/S TEJATS NETWORKS LIMITED ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX CENTRAL , BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1674/BANG/2018[2011-12]Status: DisposedITAT Bangalore09 Feb 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

DCIT, BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 1119/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

M/S. TEJAS NETWORKS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, LTU, CIRCLE-1, BENGALURU

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 582/BANG/2021[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

ASST.C.I.T., BANGALORE vs. M/S TEJAS NETWORKS LIMITED, BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 296/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

TEJAS NETWORKS LIMITED,BANGALORE vs. ASST.C.I.T., BANGALORE

In the result, the appeals filed by the revenue in IT(TP)A No

ITA 468/BANG/2015[2010-11]Status: DisposedITAT Bangalore09 Feb 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.It(Tp)A Nos.296/Bang/2015 Assessment Year: 2010-11 M/S. Tejas Networks Ltd. Plot No.25, 5Th Floor Jp Software Park Acit, Circle-1, Ltu Vs. Electronic City, Phase I Bangalore Bangalore 560 100

For Appellant: Shri Jairam Raipura, D.RFor Respondent: Shri Annamalli & Shri Narendra Sharma, A.Rs
Section 154

TDS amounting to Rs. 19,50,789. 13. Interest under section 244A 13.1. The learned AO erred in granting incorrect interest under section 244A of the Act. The grant of interest under section 244A of the Act is consequential in nature. 14. Interest under section 234D

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

ITA 1448/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

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

ITA 1447/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

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

ITA 1520/BANG/2017[2011-12]Status: DisposedITAT Bangalore03 Jul 2019AY 2011-12

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

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

ITA 1519/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

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

PRAVESH KOTHARI L/H OF SOHANRAJ KHIMRAJ KOTHARI ,HUBLI vs. JOINT COMMISSIONER OF INCOME TAX RANGE-3, HUBLI

In the result appeal filed by assessee stands dismissed

ITA 201/BANG/2017[2011-12]Status: DisposedITAT Bangalore31 Jul 2019AY 2011-12

Bench: Shri B.R.Baskaran & Smt.Beena Pillai, Judical Member

For Appellant: Shri B.R.Sudheendra, AdvocateFor Respondent: Shri R.N.Siddappaji, Addl.CIT
Section 142Section 194JSection 234ASection 234BSection 234DSection 234aSection 40

234D be deleted. (VI) The appellant prays accordingly. Brief facts of the case are as under: 2. Assessee filed its return of income on 03/10/11 declaring total income of Rs.21,79,790/-. The case was selected for scrutiny and notice under section 142 (2) along with notice under section 142 (1) and questionnaire was issued to assessee. As the case

SRI. SINGONAHALLI CHIKKAREVANNA GANGADHARAIAH,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(2)(1), BENGALURU

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

ITA 785/BANG/2018[2014-15]Status: DisposedITAT Bangalore24 Feb 2020AY 2014-15

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri. Narendra Sharma, AdvocateFor Respondent: Ms.Neera Malhotra, CIT-DR
Section 194CSection 194C(3)Section 201Section 28Section 30Section 40

TDS provisions can be disallowed under section 40(a)(ia) of the Act if at all it is to be disallowed, not the entire expenditure claimed by the appellant, on the facts and circumstances of the case. The learned authorities failed to appreciate that considering the draconian provisions of section 40(a)(ia) of the Act, the legislature reduced

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1)(1), BANGALORE vs. M/S ALTISOURCE BUSINESS SOLUTIONS INDIA PVT LTD , BANGALORE

In the result, the appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands dismissed

ITA 164/BANG/2018[2012-13]Status: DisposedITAT Bangalore29 Jun 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 162/Bang/2018 Assessment Year : 2012-13 M/S. Altisource Business Solutions Pvt. Ltd., Pritech Park, 3Rd & 5Th Floors Of Wing A & The Deputy 4Th Floor Of Wing B, Commissioner Of Block No. 12, Pritech Park, Income Tax, Survey No. 51-64/4, Circle – 1 (1)(2), Bellandur Village, Bangalore. Vs. Sarjapur Marathahalli Outer Ring Road, Bangalore – 560 103. Pan: Aaaco9467A Appellant Respondent & It(Tp)A No. 164/Bang/2018 Assessment Year : 2012-13 (By Revenue) : Shri K.R. Vasudevan, Assessee By Advocate : Smt. Susan Dolores George Revenue By Cit (Osd) Date Of Hearing : 30-05-2022 Date Of Pronouncement : 29-06-2022 Order Per Beena Pillaipresent Cross Appeals Filed By The Assessee & The Revenue Against Order Dated 31.08.2017 Passed By The Ld.Cit(A)-1, Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal:

Section 92C(3)(a)

TDS obligation on software was hit by the doctrine of 'impossibility of performance' as upheld by several judicial precedents 12.6 Notwithstanding and without prejudice to the above, the learned AO/CIT(A) erred in not granting deduction under section 10AA on the enhanced income after considering the above disallowance. 12.7 Learned CIT(A) has erred in holding that issue is covered

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INFOSYS BPO LTD, BANGALORE

In the result appeal filed by assessee stands partly allowed

ITA 1333/BANG/2014[2007-08]Status: DisposedITAT Bangalore27 Sept 2019AY 2007-08

Bench: Shri J. Sudhakar Reddy & Smt.Beena Pillai

For Appellant: Shri P.C. Khincha, CAFor Respondent: Miss. Neera Malhotra, CIT, DR
Section 10ASection 14ASection 40

234D be (viii) deleted. 2. Brief facts of the case are as under: Assessee filed its return of income on 30/10/07 declaring income of Rs.4,85,37,120/-. Return was processed under section 143(1) of the Act, and subsequently statutory notice under section 143 (2) along with questionnaire was issued to assessee. In response to statutory notices, representative