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

capital loss under section 94(7) of the Act ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 3 of 45 2.2 On appeal, the CIT(A)-15, Delhi, disposed off the same; vide order dated 23.03.2017, allowing the assessee partial relief. 3. Both Revenue and the assessee, being aggrieved by the order of CIT(A)-15, Bangalore

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

capital loss under section 94(7) of the Act ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 3 of 45 2.2 On appeal, the CIT(A)-15, Delhi, disposed off the same; vide order dated 23.03.2017, allowing the assessee partial relief. 3. Both Revenue and the assessee, being aggrieved by the order of CIT(A)-15, Bangalore

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

capital loss under section 94(7) of the Act ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 3 of 45 2.2 On appeal, the CIT(A)-15, Delhi, disposed off the same; vide order dated 23.03.2017, allowing the assessee partial relief. 3. Both Revenue and the assessee, being aggrieved by the order of CIT(A)-15, Bangalore

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

Section 92CC with the caption “Advance Pricing Agreement” provides through sub-section (1): `The Board, with the approval of the Central Government, may enter into an advance pricing agreement with any person, determining the arm's length price … in relation to an international transaction …’. Sub-section (2) gives the manner of determination of the ALP referred to in sub-section

IBM GLOBAL SERVICES INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-11(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2000-2001

10A. (1) Subject to the provisions of this section, any profits and gains derived by an section, a deduction of such profits and gains assessee from an industrial undertaking to as are derived by an undertaking from the which this section applies shall not be export of articles or things or computer included in the total income of the assessee

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

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

10A and 10AA. 5.4 Before this Tribunal, the Ld.AR submitted as under: During the FY 2008-09, the assessee was considering acquisition of Axon Group PLC, an IT services company listed in London having expertise in SAP consultancy. Infosys had proposed a bid price of 600 pence for every Axon share. As per the agreement, it Page

DCIT, BANGALORE vs. M/S IBM INDIA (P) LIMITED, BANGALORE

In the result, the appeals filed by the assessee for AY 2010-11 and 2011-12 are treated as partly allowed

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A Nos.773 & 2041/Bang/2016 Assessment Years :2010-11 & 2011-12

gains derived by an undertaking from export of computer software that has been manufactured from eligible STPI/SEZ units. 2. For transmission of data from eligible STPI/SEZ units to outside India contradictory submission has been made by the assessee to different authorities. 3. The scheme of STPI notified by Government of India has been violated thoroughly by IBM India

M/S. IBM INDIA PRIVATE LIMITED,BANGALORE vs. ASST. COMMISSIONER OF INCOME TAX, BANGALORE

In the result, the appeals filed by the assessee for AY 2010-11 and 2011-12 are treated as partly allowed

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A Nos.773 & 2041/Bang/2016 Assessment Years :2010-11 & 2011-12

gains derived by an undertaking from export of computer software that has been manufactured from eligible STPI/SEZ units. 2. For transmission of data from eligible STPI/SEZ units to outside India contradictory submission has been made by the assessee to different authorities. 3. The scheme of STPI notified by Government of India has been violated thoroughly by IBM India

M/S.IBM INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the appeals filed by the assessee for AY 2010-11 and 2011-12 are treated as partly allowed

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A Nos.773 & 2041/Bang/2016 Assessment Years :2010-11 & 2011-12

gains derived by an undertaking from export of computer software that has been manufactured from eligible STPI/SEZ units. 2. For transmission of data from eligible STPI/SEZ units to outside India contradictory submission has been made by the assessee to different authorities. 3. The scheme of STPI notified by Government of India has been violated thoroughly by IBM India

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