ABAN SINGAPORE PTE LIMITED,CHENNAI vs. DCIT INTL TAX 1(1), CHENNAI

In the result, the appeal of assessee is allowed

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.500/Chny/2025 Assessment Years: 2022-23 Aban Singapore Pte Limited Deputy Commissioner Of Income Room No.8713, Bsnl Building, Tax, 4Th Floor, Bsnl Towers, Intl Tax-1(1), No.16, Greams Road, Chennai. Chennai [Pan: Aaqca2845Q]

115A or section 293A a pply for the purposes of computing profits or gains or any other income referred to in those sections. (2) The amounts referred to in sub-section (1) shall be the following, namely :- (a) the amount paid or payable 33 (whether in or out of India) to the assessee or to any person on his behalf

ABAN OFFSHORE LIMITED,CHENNAI vs. DCIT, INTL, TAX 1(1), CHENNAI

Bench: Shri Aby T.Varkey, Hon'Ble & Shri S.R. Raghunatha, Hon'Bleआयकर अपीलसं./Ita Nos.: 1240/Chny/2024 निर्धारण वर्ष / Assessment Year: 2014-15 Aban Offshore Limited, 113, Janpriya Crest, Pantheon Road, Egmore, Chennai - 600 008. Pan: Aaaca 3012H (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By The Deputy Commissioner Of Income Tax, Vs. International Taxation 1(1), Chennai. (प्रत्यर्थी/Respondent) : Shri P. Murali Mohan Rao, Ca (Through Virtual Mode) : Ms. R. Anita, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 19.02.2025 घोषणा की तारीख/Date Of Pronouncement : 28.04.2025 आदेश /O R Der Per S. R. Raghunatha: This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Chennai-16, Dated 13.03.2024 For The Assessment Year 2014-15. 2. The Assessee Has Raised The Following Grounds Of Appeal: 1. The Ld. Cit(A) Erred In Not Considering The Fact That The Order Passed U/S.250 Of The Income Tax Act, 1961, Dated 13.03.2024 Is Erroneous Both On Facts & In Law To The Extent The Order Is Prejudicial To The Interest Of The Appellant :-2-:

115A r.w.s 44DA of the Act i.e., technical services. 8. The Ld. CIT(A) ought to appreciate the fact that the assessee has deducted the tax and same is paid as per section 44BB(1) of the Act i.e., 10 percent of the aggregate receipts during the year will be chargeable to tax as Business Income

SERVIONT GLOBAL SOLUTIONS LIMITED,CHENNAI vs. DCIT CORPORATE CIRCLE 6(1), CHENNAI

In the result, appeal of the assessee is allowed

Bench: Shri Mahavir Singh & Shri Girish Agrawalassessment Year: 2011-12 Servoint Global Solutions Deputy Commissioner Of Limited Income Tax, Central Circle- No. 4/600 & 4/197, 7Th 6(1), Chennai. Vs. Street, Dr. Vsi Estate, Phase-Ii, Thiruvanmiyur, Chennai-600 041. Pan: Aaaci0947 F (Appellant) (Respondent) Present For: Appellant By : Shri S. P. Chidambaram, Ca Respondent By : Shri Chinthapalli Mehar Chand, Jcit Date Of Hearing : 24.05.2022 Date Of Pronouncement : 19.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A)-16, Chennai Vide Ita No. 257/Cit(A)-15/2014-15 Dated 01.01.2019 Against The Order Of Ld. Dcit, Corporate Circle-6(1), Chennai Passed U/S 143(3) R.W.S. 92Ca(3) Of The Income-Tax Act,1961 (Hereinafter Referred To As The Act), Dated 23.02.2015 For Ay 2011-12. 2. The First Issue Involved In The Present Appeal Before Us Relates To Disallowance Of Payments Made Towards Purchase Of Software By The Assessee U/S. 40(A)(I) Of The Act Amounting To Rs.2,61,69,512/- For Non-Deduction Of Tax At Source U/S.195 Of The Act.

115A of the Act and since the deduction of tax at source was not done on the payment made, provisions of Section 40(a)(i) of the Act becomes applicable. Accordingly, the learned Assessing Officer disallowed

M/S. SERVIONT GLOBAL SOLUTIONS LTD.,,CHENNAI vs. ACIT, CC-6(1),, CHENNAI

In the result, the appeal of the Assessee is allowed

Bench: Shri Mahavir Singh & Shri Girish Agrawalआयकर अपील सं./Ita No.: 756/Chny/2020 िनधा"रण वष" /Assessment Year: 2010 - 2011

115A of the Act and since the deduction of tax at source was not done on the payment made, provisions of Section 40(a)(i) of the Act becomes applicable. Accordingly, the learned Assessing Officer disallowed