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

5. On facts and circumstances of the case, the Ld. CIT(A) has erred in upholding the action of the Ld. AO to re-compute the deduction allowable under section 10A of the Act on the returned business income instead of assessed business income. 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

5. On facts and circumstances of the case, the Ld. CIT(A) has erred in upholding the action of the Ld. AO to re-compute the deduction allowable under section 10A of the Act on the returned business income instead of assessed business income. 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

5. On facts and circumstances of the case, the Ld. CIT(A) has erred in upholding the action of the Ld. AO to re-compute the deduction allowable under section 10A of the Act on the returned business income instead of assessed business income. Disallowance

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

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

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

5 – Computation of deduction under section 10A of the Act 5.1 In these grounds (supra) raised in respect to the computation of deduction under section 10A of the Act and non-allowance of carry forward losses, it is contended that the CIT(A) erred in not adjudicating the issue in appeal and in not following that the decision

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

5 – Computation of deduction under section 10A of the Act 5.1 In these grounds (supra) raised in respect to the computation of deduction under section 10A of the Act and non-allowance of carry forward losses, it is contended that the CIT(A) erred in not adjudicating the issue in appeal and in not following that the decision

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

5 – Computation of deduction under section 10A of the Act 5.1 In these grounds (supra) raised in respect to the computation of deduction under section 10A of the Act and non-allowance of carry forward losses, it is contended that the CIT(A) erred in not adjudicating the issue in appeal and in not following that the decision

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.

5) is\ncomputed and after which the consideration of various Deductions under Chapter VI-A in Section\n80HH etc. comes into picture. Therefore analogy of Chapter VI Deductions cannot be telescoped or\nimported in Section 10-A or 10-B of the Act. The words 'derived by an Undertaking' in Section 10-A\nor 10-B are different from 'derived

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

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

5 IT(TP)A Nos.102 & 233/Bang/2013 Infosys Limited 7.1 The learned Commissioner of Income tax (Appeals) – I, Bangalore has erred in not giving any finding as to whether provision for software expenses amounting to Rs. 7,36,83,260/- is liable for disallowance under section 40(a)(i) / 40(a)(ia). 7.2 The learned Commissioner of Income tax (Appeals

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

5. In order to appreciate the rival contentions, it would be apposite to have a glance at the relevant provisions in this regard. 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

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

5, but no tax is charged because of the exemption given under section 10A only for a period of 10 years. Merely because the exemption has been granted in respect of the taxability of the said source of income, it cannot be postulated that the assessee is not liable to tax. The said exemption granted under the statute

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

5, but no tax is charged because of the exemption given under section 10A only for a period of 10 years. Merely because the exemption has been granted in respect of the taxability of the said source of income, it cannot be postulated that the assessee is not liable to tax. The said exemption granted under the statute

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 under section 40(a)(ia) of the Act has to be ignored. • As regards computation of 10A deduction, the DRP directed the Ld.AO to compute in accordance with the decision of Hon’ble Karnataka High Court in case of CIT vs Tata Elxsi Ltd., and others reported in (2011) 247 CTR 334; • the DRP also directed the Ld.AO

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

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

5. Ground no. 7.4 – Set-off of inter unit profit and losses and Ground no. 7.5 – Computation of deduction u/s. 10A of the Act on the basis of consolidated profits, export turnover and total turnover. 5.1 The Ld.AO in the draft assessment order set-off brought forward business losses, incurred by the non-eligible units, with the profit

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

5. Ground no. 7.4 – Set-off of inter unit profit and losses and Ground no. 7.5 – Computation of deduction u/s. 10A of the Act on the basis of consolidated profits, export turnover and total turnover. 5.1 The Ld.AO in the draft assessment order set-off brought forward business losses, incurred by the non-eligible units, with the profit

OPTO CIRCUITS INDIA PVT LTD ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-5(1)(2), BANGALORE

In the result, the appeal filed by the assessee is allowed for statistical purposes

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

disallowance referring to sub-sections (5) & (6) of section 10A / 10B of the I.T.Act, which are applicable to the deduction