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163 results for “TDS”+ Section 274clear

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Key Topics

Section 153A73Section 143(3)68Addition to Income63Section 10A40Section 92C35Section 13231Section 201(1)28Disallowance26Section 6824Deduction

JOINT COMMISSIONER OF INCOME TAX, BANGALORE vs. M/S STATE BANK OF MYSORE, H EAD OFFICE,, BANGALORE

In the result, the assessee's appeals for Assessment Years 2006-07 to 2008-09 are allowed and Revenue’s appeals for Assessment Years 2006-07 and 2008-09 are dismissed

ITA 1079/BANG/2014[2008-09]Status: DisposedITAT Bangalore11 Sept 2015AY 2008-09

Bench: Shri George George K & Shri Jason P. Boazi.T. A. Nos.1079 & 1080/Bang/2014 (Assessment Years : 2006-07 & 2008-09)

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri E.S. Nagendra Prasad, CIT (D.R)
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

274 rws 271 of the Act, proceeded to levy penalty under Section 271(1)(c) of the Act for the three assessment years 2006-07 to 2008-09 under consideration. 2.4 Aggrieved by the orders levying penalty under Section 271(1)(c) of the Act for Assessment Years 2006-07 to 2008-09, the assessee preferred appeals before

Showing 1–20 of 163 · Page 1 of 9

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24
Transfer Pricing23
Penalty21

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

ITA 2846/BANG/2017[2013-14]Status: DisposedITAT Bangalore07 Aug 2023AY 2013-14

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 133(6)Section 143(3)Section 144CSection 144C(5)Section 92C(3)

274 for which he drew our attention to the financial statement of Larsen & Toubro Infotech Limited placed at paper book page No.1081, which is absent in the case of present assessee. He also submitted that it has huge intangible assets and brand value in software at Rs.143,61,95,196 and it has intangible asset in the form of business

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

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

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

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

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

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

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

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

ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

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

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section

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

In the result, the appeal by the assessee is allowed

ITA 3234/BANG/2018[2015-16]Status: DisposedITAT Bangalore12 Jul 2021AY 2015-16

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri Muzaffar Hussain, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 144C(13)Section 271Section 274Section 9(1)(vi)

274 read with section 271 of the Act. 7 Relief 7.1 The Appellant prays that the AO be directed to grant all such relief arising from the preceding grounds as also all relief consequential thereto. INR Total tax effect 291,900,358 3. The assessee is a Singapore based company, a subsidiary of Autodesk US and the headquarters for Asia

SRI P A USMAN ,SULLIA vs. THE INCOME TAX OFFICER WARD-1 , PUTTUR

In the result, the assessee appeal in ITA No

ITA 888/BANG/2019[2014-15]Status: DisposedITAT Bangalore20 Sept 2019AY 2014-15

Bench: Shri A.K.Garodia & Shri Pavan Kumar Gadale, Judical Member Ita Nos.888 & 889(Bang)/2019 (Assessment Years : 2014-15) Shri P.A.Usman, D No.2-106-2, Chennavara House, Peruvaje Post, Bellare, Sullia-574 212 Pan No. Aappu4406R Appellant Vs The Income Tax Officer, Ward-1, Puttur Respondent Appellant By : Smt. Pratibha, Advocate Revenue By : Smt. R.Premi, Jcit

For Appellant: Smt. Pratibha, AdvocateFor Respondent: Smt. R.Premi, JCIT
Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 271(1)(c)Section 271BSection 44A

section 271(1)(c) of the Act carry different meaning. Therefore, it was imperative for the AO to strike off irrelevant limb so as to make the assessee aware as to what is the charge made against him and so that he can respond accordingly. Further, the Hon’ble High Court of Karnataka in the case of CIT vs. Manjunatha

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

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

ITA 1220/BANG/2014[2012-13]Status: DisposedITAT Bangalore21 Jun 2019AY 2012-13

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 2336/BANG/2016[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 2338/BANG/2016[2011-12]Status: DisposedITAT Bangalore21 Jun 2019AY 2011-12

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 1217/BANG/2014[2009-10]Status: DisposedITAT Bangalore21 Jun 2019AY 2009-10

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 1216/BANG/2014[2008-09]Status: DisposedITAT Bangalore21 Jun 2019AY 2008-09

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 1215/BANG/2014[2007-08]Status: DisposedITAT Bangalore21 Jun 2019AY 2007-08

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 1218/BANG/2014[2010-11]Status: DisposedITAT Bangalore21 Jun 2019AY 2010-11

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support

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

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

ITA 2328/BANG/2016[2007-08]Status: DisposedITAT Bangalore21 Jun 2019AY 2007-08

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

For Appellant: Shri K.R. Pradeep, CA
Section 201(1)Section 9(1)(vi)

TDS on Royalty is factually incorrect as evident from the discussion and the decision both by the Hon'ble ITAT and the Hon'ble High Court extracted in our written submission dt.22.11.2017. It is to be seen that it is a decision between the litigant parties which has the binding effect. The reliance placed by the department in support