M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LIMITED ,BANGALORE vs. THE ASSISSTANT COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION CIRCLE-2(1), BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. WIPRO LTD,, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

M/S WIPRO LTD,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX, BANGALORE

In the result, all 6 appeals filed by the revenue are dismissed

Bench: Shri A.K. Garodia & Shri Laliet Kumar

TDS was not relevant. Accordingly, the Ld.CIT(A) erred in allowing part relief on levy of surcharge and education cess stating that surcharge and education cess should be levied only in the cases where the non-resident vendors are residents of countries with which the DTAA allows withholding rate of more than 11.33%. ITA Nos.1215 to 1220/ Bang/2014

DEPUTY COMMISSIONER OF INCOME TAX, C-1(1)(1), BANGALORE vs. AD2PRO MEDIA SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, appeals filed by the Revenue are dismissed

TDS on this payment and as a consequence,\nthe demand raised by the AO u/s 201(1) & 201(1A) of the Act cannot\nsurvive and the same is deleted.\n16. In the result, all the 14 appeals filed by the assessee are allowed.\"\n11.\nWe notice that against the above order of the Tribunal, the Revenue had\nfiled appeal under

M/S. SUBEX LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX (OSD), CIRLCE- 12(3), BANGALORE

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

260A of the I.T.Act. The Hon’ble High Court vide judgment dated 21.12.2020 in ITA No.180/2017, restored the matter to the ITAT. The Hon’ble High Court directed the Tribunal to consider afresh, the claim of the assessee u/s 40(a)(i) of the I.T.Act. The relevant finding of the Hon’ble High Court reads as follow:- “10. Thus, from

M/S SUBEX TECHNOLOGIES LIMITED,BANGALORE vs. JCIT, BANGALORE

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

260A of the I.T.Act. The Hon’ble High Court vide judgment dated 21.12.2020 in ITA No.180/2017, restored the matter to the ITAT. The Hon’ble High Court directed the Tribunal to consider afresh, the claim of the assessee u/s 40(a)(i) of the I.T.Act. The relevant finding of the Hon’ble High Court reads as follow:- “10. Thus, from