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

depreciation at 60%.", "result": "Partly Allowed", "sections": [ "14A", "8D", "40(a)(ia)", "9(1)(vii)", "10A", "10AA", "115JB", "271(1)(c)", "274

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

274" ], "issues": "The primary issues involved the correctness of disallowances made under Section 14A and 40(a)(ia) of the Income Tax Act, the allowability of set-off of losses, the treatment of software payments as royalty or fees for technical services, depreciation

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

274" ], "issues": "Whether disallowance under Section 14A can exceed exempt income and if it applies when no exempt income is earned. Whether software AMC and license payments constitute 'technical services' or 'royalty' for disallowance purposes. Whether set-off of losses from eligible units is permissible. Treatment of computer software as an intangible asset for depreciation

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

depreciation on software was also decided in favor of the assessee.", "result": "Partly Allowed", "sections": [ "14A", "8D", "40(a)(ia)", "9(1)(vii)", "10A", "10AA", "115JB", "271(1)(c)", "274

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

depreciation on software at 60%, and dismissed additions for unrealized gains and disallowances in book profits.", "result": "Partly Allowed", "sections": [ "14A", "8D", "40(a)(i)", "40(a)(ia)", "10A", "10AA", "9(1)(vii)", "195", "115JB", "271(1)(c)", "274

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

depreciation. The relevant para of the decision of the Hon’ble Apex Court in the case of Yokogowa India Ltd., reported in 391 ITR 274 is extracted below for reference: 17. If the specific provisions of the Act provide [first proviso to Sections

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

depreciation. The relevant para of the decision of the Hon’ble Apex Court in the case of Yokogowa India Ltd., reported in 391 ITR 274 is extracted below for reference: 17. If the specific provisions of the Act provide [first proviso to Sections

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

depreciation. The relevant para of the decision of the Hon’ble Apex Court in the case of Yokogowa India Ltd., reported in 391 ITR 274 is extracted below for reference: 17. If the specific provisions of the Act provide [first proviso to Sections

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

depreciation. The relevant para of the decision of the Hon’ble Apex Court in the case of Yokogowa India Ltd., reported in 391 ITR 274 is extracted below for reference: 17. If the specific provisions of the Act provide [first proviso to Sections

ACIT, ERODE vs. SKM EGG PRODUCTS EXPORT (INDIA) LIMITED, ERODE

In the result, the appeals filed by the Revenue are dismissed

Bench: Shri N.R.S. Ganesan & Shri A. Mohan Alankamony

depreciation. The relevant para of the decision of the Hon’ble Apex Court in the case of Yokogowa India Ltd., reported in 391 ITR 274 is extracted below for reference: 17. If the specific provisions of the Act provide [first proviso to Sections

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

274 (Bangalore - Trib.)\n15.1 Further, the Hyderabad Bench of the ITAT in the case of S&P Capital\nIQ (India) (P.) Ltd. (supra) and the Bangalore Bench of the ITAT in the case of\nI & B Seeds (P.) Ltd. (supra) held that by way of amendment through Finance\nAct, 2021 clause (b) of Section

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

274 (Bangalore - Trib.)\n15.1\nFurther, the Hyderabad Bench of the ITAT in the case of S&P Capital\nIQ (India) (P.) Ltd. (supra) and the Bangalore Bench of the ITAT in the case of\nI & B Seeds (P.) Ltd. (supra) held that by way of amendment through Finance\nAct, 2021 clause (b) of Section

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

274 r.w.s 271(1)(c) of the Act is typically\nissued if the AO is satisfied during the course of assessment that the\ntaxpayer has concealed income.\n• In Para 5.1 of the order imposing penalty, the AO has observed that\nit is pertinent mention that the assessee has understated his\nincome. and however, the penalty notices u/s_274\nr.w.s

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, THIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

274 r.w.s 271(1)(c) of the Act is typically\nissued if the AO is satisfied during the course of assessment that the\ntaxpayer has concealed income.\nIn Para 5.1 of the order imposing penalty, the AO has observed that\nit is pertinent mention that the assessee has understated his\nincome. and however, the penalty notices u/s_274\nr.w.s

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

274 r.w.s 271(1)(c) of the Act is typically\nissued if the AO is satisfied during the course of assessment that the\ntaxpayer has concealed income.\nIn Para 5.1 of the order imposing penalty, the AO has observed that\nit is pertinent mention that the assessee has understated his\nincome. and however, the penalty notices u/s_274\nr.w.s

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI,

274\nr.w.s 271(1)(c) was issued for ‘concealed the particulars of income'.\nThus, the penalty levied is in contradiction to the show cause notice\nissued. As claimed and demonstrated by the appellant, neither\nExplanation 5A(i) nor 5A(ii) applies to the case to fall within the\nambit of penalty.\n6. 2. 13. In view of the above findings

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, TIRUVANNAMALAI

In the result, all the six appeals of the Revenue are\ndismissed

274 r.w.s 271(1)(c) of the Act is typically\nissued if the AO is satisfied during the course of assessment that the\ntaxpayer has concealed income.\n•\nIn Para 5.1 of the order imposing penalty, the AO has observed that\nit is pertinent mention that the assessee has understated his\nincome. and however, the penalty notices u/s_274\nr.w.s

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2(2), CHENNAI, CHENNAI vs. ETHIRAJULU VAJRAVEL KUMARAN, CHENNAI

In the result, all the six appeals of the Revenue are\ndismissed

274 r.w.s 271(1)(c) of the Act is typically\nissued if the AO is satisfied during the course of assessment that the\ntaxpayer has concealed income.\nIn Para 5.1 of the order imposing penalty, the AO has observed that\nit is pertinent mention that the assessee has understated his\nincome.\nand however, the penalty notices u/s_274\nr.w.s