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

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

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

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

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

68 SOT 184 (Bangalore – Trib); and ITA Nos. 1447 and 1448/Bang/2017 ITA Nos. 1519 and 1520/Bang/2017 Page 21 of 45 (ii) DCIT Vs. S. R. M. Agro Foods (2016) 161 ITD 786 (Mumbai – Trib). 10.3.2 In the course of hearings before us, the amendments to Section 9 the Act, particularly the Explanations inserted in the Section, came

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

Section 14A disallowance and interest on ECB loan from out of the total corporate expenses of Rs.157.15 crores and accordingly arrived at the figure of Rs.83.62 crores (referred above). The A.O. proposed to allocate the above said expenditure in the ratio of turnover of various divisions and units. 11.3 The assessee objected to the proposal put forth

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

Section 14A disallowance and interest on ECB loan from out of the total corporate expenses of Rs.157.15 crores and accordingly arrived at the figure of Rs.83.62 crores (referred above). The A.O. proposed to allocate the above said expenditure in the ratio of turnover of various divisions and units. 11.3 The assessee objected to the proposal put forth

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

section 10A and 10B of the Act 10,90,60,594 As per ROI 99,59,24,204 Less: As per FAO 88,68

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

section 10A and 10B of the Act 10,90,60,594 As per ROI 99,59,24,204 Less: As per FAO 88,68

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

68,25,501 under section 234B of the Act. 11.2. The learned ACIT has erred in law and on facts in not granting credit for foreign taxes paid by the Appellant. 12. Relief 12.1. The Appellant prays that directions be given to grant all such relief arising from the preceding grounds as also all reliefs consequential thereto

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

10A of the Act. The relevant computation of deduction u/s.10A has been reproduced by the DRP in para 3.1.1.4 which has been reproduced herein above. We note that submission needs to be verified by Ld.AO. On one hand Ld.Counsel submitted additional income is supported by invoices raised by assessee on AE, on the other hand, assessee has declared the additional

M/S DELL INTERNATIONAL SERVICES INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX LTU , BANGALORE

In the result, the appeal is allowed

Bench: Shri N.V. Vasudevan & Shri B R Baskaran

68 of PB-II), which was also adopted by the TPO in his show cause notice (Page 84 of PB-I). The segmental results i.e., results pertaining to software services segment of this company was: Segmental Operating Revenues Rs.63,71,32,544 Segmental Operating Expenses Rs.51,75,13,211 Operating Profit Rs.11,96,19,333 OP/TC

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE vs. M/S TATA ELXSI. LTD, BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

10A of the Act, following the decisions of the Hon’ble Karnataka High Court in the cases of: 6. As regards export sales of Rs.27,68,91,445/- not realized within prescribed time, the ld.CIT(A), referring to the provisions of section

M/S TATA ELXSI LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

10A of the Act, following the decisions of the Hon’ble Karnataka High Court in the cases of: 6. As regards export sales of Rs.27,68,91,445/- not realized within prescribed time, the ld.CIT(A), referring to the provisions of section

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE vs. M/S TATA ELXSI. LTD., BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V.Vasudevan & Shri Inturi Rama Raom/S.Tata Elxsi Ltd., Itpb Road, Hoody, Whitefield Road, Bengaluru-560 048. … Appellant Pan:Aaact 7872 Q Vs

10A of the Act, following the decisions of the Hon’ble Karnataka High Court in the cases of: 6. As regards export sales of Rs.27,68,91,445/- not realized within prescribed time, the ld.CIT(A), referring to the provisions of section

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded in book profit computation for Assessment Year 2010-11 in terms of clause (i) of Explanation I to Section 115JB(2) of the Act. Corporate tax matters 18. Without prejudice

ITO, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded in book profit computation for Assessment Year 2010-11 in terms of clause (i) of Explanation I to Section 115JB(2) of the Act. Corporate tax matters 18. Without prejudice

DCIT, BANGALORE vs. M/S XCHANGING SOLUTIONS LTD.,, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded in book profit computation for Assessment Year 2010-11 in terms of clause (i) of Explanation I to Section 115JB(2) of the Act. Corporate tax matters 18. Without prejudice

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. ITO, BANGALORE

In the result, the appeals of the assessee are partly allowed and that of the revenue are dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojari

68,510, out of provision of INR 6,41,61,438 created during Assessment Year 2009-10 and added to book profit for that year, should be excluded in book profit computation for Assessment Year 2010-11 in terms of clause (i) of Explanation I to Section 115JB(2) of the Act. Corporate tax matters 18. Without prejudice

SAP LABS INDIA PVT. LTD.,,BANGALORE vs. ADDL.C.I.T.,

In the result, the appeal filed by the assessee as well as the revenue is partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

10A unit. 15. We heard rival submissions and perused material on record. The issue in the ground of appeal is covered by the decision of the co- ordinate bench of Tribunal in the case of the same assessee for assessment year 2007-08 in ITA No.1006/Bang/2011 dated 30/06/2016, to which one of us viz., the Hon’ble Judicial Member

DCIT vs. M/S SAP LABS INDIA PVT. LTD.,, BANGALORE

In the result, the appeal filed by the assessee as well as the revenue is partly allowed

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

10A unit. 15. We heard rival submissions and perused material on record. The issue in the ground of appeal is covered by the decision of the co- ordinate bench of Tribunal in the case of the same assessee for assessment year 2007-08 in ITA No.1006/Bang/2011 dated 30/06/2016, to which one of us viz., the Hon’ble Judicial Member