COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

5. Thus, by following the above decision, the present Tax Case Appeal is dismissed and the substantial questions of law are answered against the Revenue. No costs.” 5.2 In the present facts and circumstances of the case and by respectfully following the judicial precedent (supra), we are of the view that the action of the ld.CIT(A) cannot be countenanced

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

5. Thus, by following the above decision, the present Tax Case Appeal is dismissed and the substantial questions of law are answered against the Revenue. No costs.” 5.2 In the present facts and circumstances of the case and by respectfully following the judicial precedent (supra), we are of the view that the action of the ld.CIT(A) cannot be countenanced

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

5 of 2014 dated 11-2-2014, which has been relied by the\nTribunal in the impugned order cannot be upheld and the disallowance\nunder section 14A of the Act cannot go beyond the extent of exempted\nincome itself.\n.....\n9. We are unable to subscribe to the aforesaid view. The provisions of\nsection 14A were inserted as a response

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

FAMILY HEALTH PLAN (TPA) LTD.,CHENNAI vs. ITO TDS WARD 1(2), CHENNAI

In the result, the assessee’s appeals for assessment years

Bench: Shri N.R.S. Ganesan & Shri S. Jayaraman

5. By Finance Act, 2014 with effect from 01.10.2014, provisions of sub-section (3) was amended. Before the amendment, sub section (3) of Section 201 of the Act reads as follows:- (3) No order shall be made under sub-section (1) deeming a person to be an assessee in default for failure to deduct the whole or any part

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

5 of 2014 dated 11-2-2014, which has been relied by the\nTribunal in the impugned order cannot be upheld and the disallowance\nunder Section 14A of the Act cannot go beyond the extent of exempted\nincome itself.\n.....\n9. We are unable to subscribe to the aforesaid view. The provisions of\nSection 14A were inserted as a response

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

5 of 2014 dated 11-2-2014, which has been relied by the\nTribunal in the impugned order cannot be upheld and the disallowance\nunder section 14A of the Act cannot go beyond the extent of exempted\nincome itself.\n\n.....\n\n9. We are unable to subscribe to the aforesaid view. The provisions of\nsection 14A were inserted

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

5 of 2014 dated 11-2-2014, which has been relied by the\nTribunal in the impugned order cannot be upheld and the disallowance\nunder Section 14A of the Act cannot go beyond the extent of exempted\nincome itself.\n.....\n9. We are unable to subscribe to the aforesaid view. The provisions of\nSection 14A were inserted as a response

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

5 of 2014 dated 11-2-2014, which has been relied by the\nTribunal in the impugned order cannot be upheld and the disallowance\nunder section 14A of the Act cannot go beyond the extent of exempted\nincome itself.\n.....\n9. We are unable to subscribe to the aforesaid view. The provisions of\nsection 14A were inserted as a response

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

5 of 2014 dated 11-2-2014, which has been relied by the\nTribunal in the impugned order cannot be upheld and the disallowance\nunder section 14A of the Act cannot go beyond the extent of exempted\nincome itself.\n.....\n9. We are unable to subscribe to the aforesaid view. The provisions of\nsection 14A were inserted as a response