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

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

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

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

capital expenditure incurred by the assessee. In reply, the learned counsel pointed out that the expenditure by way of technical know- how was capitalized and it was not claimed as revenue expenditure. Therefore, there was also no reason to disallow depreciation on such capitalized amount as the aforesaid provision does not deal with deduction of depreciation. Having considered arguments from

DCIT, 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

capital expenditure incurred by the assessee. In reply, the learned counsel pointed out that the expenditure by way of technical know- how was capitalized and it was not claimed as revenue expenditure. Therefore, there was also no reason to disallow depreciation on such capitalized amount as the aforesaid provision does not deal with deduction of depreciation. Having considered arguments from

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

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

7 IT(TP)A Nos. 449, 509/Bang/2015, 613 & 532/Bang/2016 & ITA Nos. 1530 to 1532, 1557, 1848 & 1849/Bang/2017 in the case of Wipro Ltd v u/s. 90 of the Act. 2011-12 25 & 26 DCIT[2016] 382 ITR 179 Relied on Hon’ble 2011-12 23 & 24 (Karnataka) Karnataka High Foreign tax credit and Court in case of incremental deduction state

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

7. Insurance claim received 8. Incentive received 9. Interest on deposits with Banks 10. Interest on security deposits 11. Interest on loan to subsidiaries 12. Interest on debenture 13. Interest on government securities 14. Interest on tax refunds 15. Interest on non-convertible debentures (NCDs) 16. Net realization on exchange gain on forward contracts During the assessment proceedings, the deduction

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

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

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

7. section 10B of the Act was substituted by Finance Act, 2000 w.e.f. 1-4-2001. section 10B as it stands is not a provision in the nature of an exemption but provides for a deduction of such profit and gains as are derived by 100% export oriented undertaking from the export of articles or things or computer software

DCIT, BANGALORE vs. SOBHA RENAISSANCE INFORMATION TECHNOLOGY PVT. LTD.,, BANGALORE

In the result, the appeal of Revenue is partly allowed for statistical

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

7 9.72 Learned Authorised Representative has relied on the Hon'ble Delhi ITAT decision in case of TCIL Bellsouth Ltd., since reported in (2004) 89 TTJ 851, to contend that even revenue expenditure incurred for development of software package amounts to expenditure on scientific research, eligible for deduction under Section 35(1)(iv). Detailed discussion has been made in paras