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

Disallowance out of assessee’s claim of deduction - Rs.14,13,53,193/- u/s section 10A of the Act (iii) Disallowance

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

Disallowance out of assessee’s claim of deduction - Rs.14,13,53,193/- u/s section 10A of the Act (iii) Disallowance

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

Disallowance out of assessee’s claim of deduction - Rs.14,13,53,193/- u/s section 10A of the Act (iii) Disallowance

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

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

section 10A. 5.1 The learned Assistant Commissioner of Income tax, Circle 11(5), Bangalore has erred in disallowing provision for warranty

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

disallowance made under section 10AA of the Act ignoring that since no new master service agreement was made, the benefit of claim u/s 10AA from the old SEZ cannot be allowed. 5. The CIT(A) erred in remitting the matter to assessing officer on issue relating to section 80G of the Act ignoring that in instant case assessee

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

section 10A in respect of the disallowance made under section 14A. 10.1 The learned Commissioner of Income tax (Appeals)-I, Bangalore

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

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

disallowances and after allowing deduction of Rs.6,17,15,259/- under section 10A of the Act, as claimed in the return

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

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

disallowances and after allowing deduction of Rs.6,17,15,259/- under section 10A of the Act, as claimed in the return

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

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

disallowances and after allowing deduction of Rs.6,17,15,259/- under section 10A of the Act, as claimed in the return

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

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

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\N\N\Nita No. 881/Bang/2023\N Assessment Year: 2019-20\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nvs.\N\Ndy. Commissioner Of Income Tax\Ncircle - 3(1)(1)\Nbmtc Building, 80 Feet Road\Nkoramangala, Bangalore – 560095\Nkarnataka\N\Nrespondent\N\Nita No. 245/Bang/2024\N Assessment Year: 2019-20\N\Njt. Commissioner Of Income Tax (Osd)\Ncircle - 3(1)(1)\Nroom No. 241, 2Nd Floor\Nbmtc Building, 80 Feet Road\N6Th Block, Koramangala\Nbangalore - 560095\Nkarnataka\N\Nvs.\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nrespondent\N\Nassessee By\Ndepartment By\N\Nsri Padam Chand Khincha – Ca\Nsmt. Srinandini Das – Cit - Dr\N\Ndate Of Hearing\Ndate Of Pronouncement:\N\N09.05.2025\N06.08.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Cross Appeals Are Filed Against The Order Of Ld. Commissioner Of\Nincome Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short \"Ld.\Ncit(A)/Nfac] Vide Din & Order No. Itba/Nfac/S/250/2023-24/1056786183(1) Dated 05.10.2023 Passed U/S.250 Of The Income Tax\Nact, 1961 (In Short “The Act\") For The A.Y.2019-20.\N\Npage 2 Of 34\N\N2. The Assessee Has Raised The Following Grounds Of Appeal: - \N\N\"1.\N\Ngeneral Ground\N\N1.

disallowance made under section\n10AA of the Act ignoring that since no new master service agreement was\nmade, the benefit of claim u/s 10AA from the old SEZ cannot be allowed.\n\n5.\nThe CIT(A) erred in remitting the matter to assessing officer on issue\nrelating to section 80G of the Act ignoring that in instant case assessee

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, Revenue’s appeal for Assessment Year 2006-07 is partly allowed for statistical purposes

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

section 10A.” 5 IT(TP)A Nos.799 & 942/Bang/2015 Infosys Limited 5. Ground No.1.1 being general in nature, no adjudication is called for thereon. 6. Ground Nos.2.1 to 2.4 - Disallowance

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

disallowance of depreciation on software under section 40(a)(ia) of the Act, on account of non-deduction of TDS is not sustainable. • Directed the Ld.AO to verify the claim of TDS having deducted on professional fees paid and to allow the claim of assessee accordingly. • DRP accepted the contention of assessee that in computing deduction under section 10A

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

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

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

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

HEWLETT-PACKARD GLOBALSOFT PRIVATE LIMTIED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

disallowance of 12.50 percent of the relief computed under section 10A and section 10B of the Act. 6.3 Aggrieved by the order

DCIT, BANGALORE vs. M/S HEWLETT PACKARD GLOBALSOFT PVT. LTD.,, BANGALORE

In the result, the appeal filed by the assessee stands partly allowed for statistical purposes and the appeal of the revenue stands dismissed

disallowance of 12.50 percent of the relief computed under section 10A and section 10B of the Act. 6.3 Aggrieved by the order

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

disallowance made in the assessment order was denying exemption claimed u/s. 10A of the act on the ground that, the export turnover brought into India does not amount to 75 percent of the total turnover of the STP unit. It was submitted by the assessee that, it treated export credits of the bank account maintained

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

section 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