UNITED INDIA INSURANCE CO LTD,CHENNAI vs. PCIT, CHENNAI

30 to 43B in computing the profits and gains of a business\nshall be added back;\n(i) any gain or loss on realisation of investments shall be added or deducted, as the case\nmay be, if such gain or loss is not credited or debited to the profit and loss account;\n(ii) any provision for diminution

UNITED INDIA INSURANCE CO.LIMITED,CHENNAI vs. PCIT-3, CHENNAI

30 to 43B in computing the profits and gains of a business\nshall be added back;\n(i) any gain or loss on realisation of investments shall be added or deducted, as the case\nmay be, if such gain or loss is not credited or debited to the profit and loss account;\n(ii) any provision for diminution

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

30 to 43B in computing the profits and gains of a business\nshall be added back;\n(i) any gain or loss on realisation of investments shall be added or deducted, as the case\nmay be, if such gain or loss is not credited or debited to the profit and loss account;\n(ii) any provision for diminution

UNITED INDIA INSUANCE CO LIMITED,CHENNAI vs. PCIT 3, CHENNAI

30 to 43B in computing the profits and gains of a business\nshall be added back;\n(i) any gain or loss on realisation of investments shall be added or deducted, as the case\nmay be, if such gain or loss is not credited or debited to the profit and loss account;\n(ii) any provision for diminution

ALBERT & CO. P. LTD.,CHENNAI vs. ITO CORPORATE WARD 6(1), CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

30% in view of the amendment made to the provisions of Section 40(a)(ia) by the Finance Act, 2014.The Learned Departmental Representative relied upon the order passed by the CIT(A) on this issue and submitted that sufficient relief has already been granted to the Appellant by the CIT(A). 20. We have heard the rival submissions and perused

ALBERT & CO. P. LTD.,CHENNAI vs. ITO CORPORATE WARD 6(1), CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

30% in view of the amendment made to the provisions of Section 40(a)(ia) by the Finance Act, 2014.The Learned Departmental Representative relied upon the order passed by the CIT(A) on this issue and submitted that sufficient relief has already been granted to the Appellant by the CIT(A). 20. We have heard the rival submissions and perused

ALBERT & CO. P LTD. ,CHENNAI vs. ITO CORPORATE WARD 6(1) , CHENNAI

Appeal is partly allowed

Bench: Shri G. Manjunatha & Shri Rahul Chaudhary

30% in view of the amendment made to the provisions of Section 40(a)(ia) by the Finance Act, 2014.The Learned Departmental Representative relied upon the order passed by the CIT(A) on this issue and submitted that sufficient relief has already been granted to the Appellant by the CIT(A). 20. We have heard the rival submissions and perused

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

section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

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

section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

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

section 40(a)(ia) of the Act:\n\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

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

section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

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

section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

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

Section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

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

section 40(a)(ia) of the Act:\nThe next issue in this appeal of assessee is as regards to the\norder of Ld.CIT(A) in confirming the action of the AO in making\ndisallowance u/s.40(a)(ia) of the Act on the payment towards\nSoftware Annual Maintenance Charges ('Software AMC') and\npayments towards license to use software ('Software License

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing Rs 8,22,89,728 under section 14A of the Act read with Rule 8D of the Rules. 4. The Honourable DRP/AO have erred in law and on facts by applying the provisions of under section 14A of the Act read with Rule 8D of the Rules, without any satisfaction on record to prove that the claim

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing Rs 8,22,89,728 under section 14A of the Act read with Rule 8D of the Rules. 4. The Honourable DRP/AO have erred in law and on facts by applying the provisions of under section 14A of the Act read with Rule 8D of the Rules, without any satisfaction on record to prove that the claim

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing Rs 8,22,89,728 under section 14A of the Act read with Rule 8D of the Rules. 4. The Honourable DRP/AO have erred in law and on facts by applying the provisions of under section 14A of the Act read with Rule 8D of the Rules, without any satisfaction on record to prove that the claim

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowing Rs 8,22,89,728 under section 14A of the Act read with Rule 8D of the Rules. 4. The Honourable DRP/AO have erred in law and on facts by applying the provisions of under section 14A of the Act read with Rule 8D of the Rules, without any satisfaction on record to prove that the claim

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)

30,484 Systems Pty Ltd Flexera United 6 Software Ltd USD 8,592 3,85,351 Kingdom (Ind) Mobile 7 USA USD 4,900 2,18,197 Complete Inc Parasoft 8 USA USD 3,456 1,55,002 Corporation Tibco Software 9 USA USD 3,834 1,74,961 Inc 10 Xenos Group Canada