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297 results for “depreciation”+ Section 10A(3)clear

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Key Topics

Section 10A264Deduction71Addition to Income54Transfer Pricing51Section 143(3)38Disallowance37Comparables/TP31Depreciation30Section 4028

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

ITA 725/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Jul 2020AY 2013-14

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

For Appellant: Shri Percy Pardiwala, Sr. Advocate along with Ajay Roti, C.AFor Respondent: Shri K.V Arvind, Advocate
Section 10ASection 143Section 143(3)Section 144C(1)Section 92C

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

Showing 1–20 of 297 · Page 1 of 15

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Section 115J23
Set Off of Losses23
Section 14721

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

ITA 3464/BANG/2004[2000-2001]Status: DisposedITAT Bangalore31 Jul 2024AY 2000-2001

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

For Appellant: Shri Sharath Rao, CAFor Respondent: Shri D.K. Mishra, CIT-DR
Section 10ASection 10A(2)Section 10A(2)(ia)Section 142(1)Section 143(2)Section 143(3)

depreciation for each of the relevant other free trade zone which the Central assessment year. Government may, by notification in the (7) The provisions of sub-section (8) and sub- Official Gazette, specify for the purposes of section (10) of section 80-IA shall, so far as this section; may be, apply in relation to the undertaking [(ii) relevant assessment

M/S. BIRLASOFT LIMITED (FORMERLY KNOWN AS KPIT CUMMINS INFOSYSTEMS LTD.,),PUNE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-11(5), BANGALORE

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

ITA 739/BANG/2010[2005-06]Status: DisposedITAT Bangalore14 May 2024AY 2005-06

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2005-06 M/S. Birlasoft Ltd. (Formerly Known As Kpit Technologies Ltd.) The Assistant # 35 & 36, Rajiv Commissioner Gandhi Infotech Park, Of Income Tax, Phase – 1, Midc Circle – 11(5), Hinjawadi, Bangalore. Vs. Pune – 411 057. Pan: Aaack7308N Appellant Respondent

For Appellant: Shri Padam Chand Khincha, CAFor Respondent: Shri D.K. Mishra, CIT –DR
Section 10ASection 10BSection 143(3)

depreciation allowance was reduced from business income computed after claiming deduction under section 10A. 2.2 The Ld.AO issued notice u/s. 143(2) on 25.09.2006. The assessment has been completed and the order u/s. 143(3

MAKINO INDIA PVT. LTD.,,BANGALORE vs. ACIT,

In the result, the assessee's appeal for Assessment Year 2004-05 is treated as partly allowed for statistical purposes

ITA 1016/BANG/2014[2004-05]Status: DisposedITAT Bangalore04 Nov 2015AY 2004-05

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

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Kaleemulla Khan, JCIT (D.R)
Section 10ASection 115JSection 143(1)Section 143(3)Section 147Section 148

3) of the Act vide order dt.28.12.2006 determining the loss under normal provisions of the Act at Rs.1,11,08,860 in view of the following additions / disallowances :- (i) Addition towards PF and ESI : Rs.1,48,634. (ii) Towards excess depreciation : Rs.3,37,292. (iii) Excess deduction under Section 10A

DCIT, BANGALORE vs. M/S MAKINO INDIA PRIVATE LIMITED, BANGALORE

In the result, the assessee's appeal for Assessment Year 2004-05 is treated as partly allowed for statistical purposes

ITA 935/BANG/2014[2004-05]Status: DisposedITAT Bangalore04 Nov 2015AY 2004-05

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

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Kaleemulla Khan, JCIT (D.R)
Section 10ASection 115JSection 143(1)Section 143(3)Section 147Section 148

3) of the Act vide order dt.28.12.2006 determining the loss under normal provisions of the Act at Rs.1,11,08,860 in view of the following additions / disallowances :- (i) Addition towards PF and ESI : Rs.1,48,634. (ii) Towards excess depreciation : Rs.3,37,292. (iii) Excess deduction under Section 10A

INFOSYS LTD.,,BANGALORE vs. DCIT, BANGALORE

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

ITA 449/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Nov 2022AY 2010-11

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1530/BANG/2017[2007-08]Status: DisposedITAT Bangalore30 Nov 2022AY 2007-08

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 613/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1532/BANG/2017[2009-10]Status: DisposedITAT Bangalore30 Nov 2022AY 2009-10

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1557/BANG/2017[2007-08]Status: DisposedITAT Bangalore30 Nov 2022AY 2007-08

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 532/BANG/2016[2011-12]Status: DisposedITAT Bangalore30 Nov 2022AY 2011-12

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1849/BANG/2017[2008-09]Status: DisposedITAT Bangalore30 Nov 2022AY 2008-09

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1848/BANG/2017[2009-10]Status: DisposedITAT Bangalore30 Nov 2022AY 2009-10

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 509/BANG/2015[2010-11]Status: DisposedITAT Bangalore30 Nov 2022AY 2010-11

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1531/BANG/2017[2008-09]Status: DisposedITAT Bangalore30 Nov 2022AY 2008-09

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

Section 10ASection 40

section Ground nos. 14-21 40(a)(ia) / 40(a)(i) in respect of Paras 9 – 9.1 2007-08 7 to 10 software expenses paid to The issue is 2008-09 9 to 12 residents and non residents remanded to the 2009-10 9 to 12 Ld.AO to consider 2010-11 7 to 9 in accordance with

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

ITA 1228/BANG/2016[2010-11]Status: DisposedITAT Bangalore18 Jul 2022AY 2010-11

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

For Appellant: Shri Ajay Rotti, C.A (A.R)For Respondent: Shri Dilip, Advocate, Standing
Section 10ASection 143(3)

10A of the act, if otherwise the conditions laid down in the said section are fulfilled by an assessee. Besides the above, the CA has given a detailed explanation as to how profitability of various STP units have been arrived at. The AO has also referred to the fact that audited financial statements of statutory auditors was relied upon

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

ITA 773/BANG/2016[2010-11]Status: DisposedITAT Bangalore18 Jul 2022AY 2010-11

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

For Appellant: Shri Ajay Rotti, C.A (A.R)For Respondent: Shri Dilip, Advocate, Standing
Section 10ASection 143(3)

10A of the act, if otherwise the conditions laid down in the said section are fulfilled by an assessee. Besides the above, the CA has given a detailed explanation as to how profitability of various STP units have been arrived at. The AO has also referred to the fact that audited financial statements of statutory auditors was relied upon

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

ITA 2041/BANG/2016[2011-12]Status: DisposedITAT Bangalore18 Jul 2022AY 2011-12

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

For Appellant: Shri Ajay Rotti, C.A (A.R)For Respondent: Shri Dilip, Advocate, Standing
Section 10ASection 143(3)

10A of the act, if otherwise the conditions laid down in the said section are fulfilled by an assessee. Besides the above, the CA has given a detailed explanation as to how profitability of various STP units have been arrived at. The AO has also referred to the fact that audited financial statements of statutory auditors was relied upon

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

ITA 454/BANG/2019[2010-11]Status: DisposedITAT Bangalore21 Aug 2019AY 2010-11

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

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao
Section 10ASection 115JSection 143(1)Section 143(3)

depreciation of the Non-STPI Units shall not be adjusted against the profits of the STPI Unit for the purposes of computation of the deduction under section 10A of the Act to be allowed to the assessee. We hold and direct accordingly. Consequently, ground Nos. 2 to 5 of the assessee’s appeal are allowed. 6. Ground No.6 : Deduction under

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

ITA 453/BANG/2019[2009-10]Status: DisposedITAT Bangalore21 Aug 2019AY 2009-10

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

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao
Section 10ASection 115JSection 143(1)Section 143(3)

depreciation of the Non-STPI Units shall not be adjusted against the profits of the STPI Unit for the purposes of computation of the deduction under section 10A of the Act to be allowed to the assessee. We hold and direct accordingly. Consequently, ground Nos. 2 to 5 of the assessee’s appeal are allowed. 6. Ground No.6 : Deduction under