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

10A of the Act (iii) Disallowance of capital loss under section 94(7) of the Act ITA Nos. 1447 and 1448/Bang/2017

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

10A of the Act (iii) Disallowance of capital loss under section 94(7) of the Act ITA Nos. 1447 and 1448/Bang/2017

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

10A of the Act (iii) Disallowance of capital loss under section 94(7) of the Act ITA Nos. 1447 and 1448/Bang/2017

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

disallowance has resulted in enhancement of business profits leading to increase in deduction allowable to the assessee under section 10A. 2.3 The Ld.AO thus passed the assessment order making an addition in the hands of the assessee at Rs.1,59,40,469/-. Page 7

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

10A and consequent increase in income, as confirmed / sustained by the appellate order. 11.1 The learned Commissioner of Income tax (Appeals)-I, Bangalore has erred in levying interest under section 234B and 234D of the Act. On facts and in the circumstances of the case and law applicable, interest is not leviable under section 234B and 234D. The appellant denies

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

7 (supra), being general in nature, no adjudication is called for thereon. 5. Ground Nos.2 to 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

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

7 (supra), being general in nature, no adjudication is called for thereon. 5. Ground Nos.2 to 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

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

7 (supra), being general in nature, no adjudication is called for thereon. 5. Ground Nos.2 to 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

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.

7 of 34\n\n9.5 The AR submitted that the explanation below sub-section 1 of\nsection 10AA does not disturb the computation of deduction under section\n10AA of the Act to be made at the unit level. It only shifts the stage of\ndeduction under section 10AA of the Act. The deduction is now to be\nclaimed from

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

7 IT(TP)A Nos.799 & 942/Bang/2015 Infosys Limited Synopsys International Old Ltd. (supra) and CIT Vs. Samsung Electronics Co. Ltd. (supra), we uphold the disallowance made by the authorities below, of software expenses of Rs.10,21,856 paid to overseas entities under Section 40(a)(i) of the Act for not deducting tax at source under Section

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

disallowed the claim of the assessee has been reversed by Hon’ble Supreme Court in case of CIT vs Yokogawa, (supra), by observing as under: 16. From a reading of the relevant provisions of Section 10A it is more than clear to us that the deductions contemplated therein is qua the eligible undertaking of an assessee standing

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

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

7. Issue No.4 relates to the issue whether Deemed exports are eligible for deduction section 10A/10AA/10B:- 7.1 This issue relates to rejection of claim of deduction u/s 10A/10AA/10B of the Act in respect of sale proceeds received from customers located in SEZ units in India, though it was received in foreign currency. This issue is being urged by 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

7. Issue No.4 relates to the issue whether Deemed exports are eligible for deduction section 10A/10AA/10B:- 7.1 This issue relates to rejection of claim of deduction u/s 10A/10AA/10B of the Act in respect of sale proceeds received from customers located in SEZ units in India, though it was received in foreign currency. This issue is being urged by the assessee

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

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

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

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

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

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

Bench: Shri Chandra Poojaria & Smt. Beena Pillai

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