M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

TDS. The return was processed under section 143(1) of the I.T. Act. 1961 on 17-05-2006, determining a Refund of Rs.30.282/- including interest. From the perusal of the I.T. Return, the following was observed: 1.1. As per annexure 5, notes to the computation, the assessee is engaged in providing IT enabled services involving research and production support

M/S. A.T. KEARNEY INDIA PRIVATE LIMITED,GURGAON vs. ITO, NEW DELHI

In the result the ground No

Bench: Smt Diva Singh & Shri Prashant Maharishiat Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent) At Kearney India Private Ito, Limited, Ward-1(1), Vs. 6Th Floor, Tower-D, Global New Delhi Business Park, Gurgaon Pan:Aadca1436G (Appellant) (Respondent)

TDS. The return was processed under section 143(1) of the I.T. Act. 1961 on 17-05-2006, determining a Refund of Rs.30.282/- including interest. From the perusal of the I.T. Return, the following was observed: 1.1. As per annexure 5, notes to the computation, the assessee is engaged in providing IT enabled services involving research and production support

HINDUSTAN COCA COLA BEVERAGES vs. JT.COMMISSIONER OF INCOME TAX

The appeal is allowed in the above terms, but in the circumstances, with

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE NAJMI WAZIRI

10. The further appeal filed by the Appellant in the ITAT against the aforementioned order of the CIT(A) came to be dismissed by the ITAT by an order dated 12th July 2002. The ITAT, inter alia, held that in terms of Circular No 718 dated 22nd August, 1995 the Appellant ought to have deducted TDS under Section

DIVYA CREATION,NOIDA vs. PR.CIT, NOIDA

In the result, the appeal of the assessee is allowed

Bench: Shri Amit Shukla & Shri O.P. Kantassessment Year: 2013-14 M/S. Divya Creation, Vs. Pr. Cit, Plot No. 97, Nsez, Noida Aayakar Bhawan, A2 D- Block, Sector 24, Noida Pan :Aadfd4879K (Appellant) (Respondent)

TDS, the Ld. DR submitted that Assessing Officer has allowed excess deduction as compared to allowable deduction as per Auditor’s Report in form No. 56F and which requires examination. On the issue related to deduction under section 10A on interest income of Rs.66,68,296/- earned on various FDR’s is concerned, the Ld. DR submitted that

MARUTI SUZUKI INDIA LIMITED,NEW DELHI vs. ACIT, SPL. RANGE-6, NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

10(34). Section115-O of the Act: 56. By the Finance Act, 1997, the Government introduced simplistic system by introduction of Chapter XII-D to the Act, comprising of Sec.115-O, 115-P and 115Q. The tax so paid was treated as the final tax on dividends and the dividends were exempt from any further incidence of tax in India

MARUTI SUZUKI INDIA LTD,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

10(34). Section115-O of the Act: 56. By the Finance Act, 1997, the Government introduced simplistic system by introduction of Chapter XII-D to the Act, comprising of Sec.115-O, 115-P and 115Q. The tax so paid was treated as the final tax on dividends and the dividends were exempt from any further incidence of tax in India

MARUTI SUZUKI INDIA LTD,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

10(34). Section115-O of the Act: 56. By the Finance Act, 1997, the Government introduced simplistic system by introduction of Chapter XII-D to the Act, comprising of Sec.115-O, 115-P and 115Q. The tax so paid was treated as the final tax on dividends and the dividends were exempt from any further incidence of tax in India

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

10(34). Section115-O of the Act: 56. By the Finance Act, 1997, the Government introduced simplistic system by introduction of Chapter XII-D to the Act, comprising of Sec.115-O, 115-P and 115Q. The tax so paid was treated as the final tax on dividends and the dividends were exempt from any further incidence of tax in India

MARUTI SUZUKI INDIA LTD.,NEW DELHI vs. DCIT, CIRCLE-16(1), NEW DELHI

Bench: Shri G. S. Pannu, Shri N.V.Vasudevan & Shri Vikas Awasthyआअसुं.6997/म ुं/2019(धन.व. 2016-17) Deputy Commissioner Of Income Tax Circle 11(3)(1), Mumbai ...... अपीलाथी/Appellant बनाम Vs. Total Oil India Pvt. Ltd. 3Rd Floor, The Leela Galleria, Andheri ( East), Mumbai 400 059 ..... प्रधिवादी/Respondent Pan: Aaace-2175-M C.O. No.57/Mum/2019 Total Oil India Pvt. Ltd. Mumbai – 400 059 ...... Cross Objector बनाम Vs. Deputy Commissioner Of Income Tax ...... प्रधिवादी/Respondent Circle 11(3)(1), Mumbai.

10(34). Section115-O of the Act: 56. By the Finance Act, 1997, the Government introduced simplistic system by introduction of Chapter XII-D to the Act, comprising of Sec.115-O, 115-P and 115Q. The tax so paid was treated as the final tax on dividends and the dividends were exempt from any further incidence of tax in India

XL INDIA BUSINESS SERVICES PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, appeal of the assessee is allowed for statistical purposes

Bench: Shri Bhavnesh Saini & Shri O.P. Kantassessment Year: 2011-12 M/S. Xl India Business Vs. Addl. Cit, Services Pvt. Ltd., Special Range-9, New Delhi Ff-101, Building No. G-11, Sarines Sonia Sadan, Community Centre, Vikas Puri, New Delhi Pan :Aaacx0309A (Appellant) (Respondent) & S.A. No.16/Del/2019 [Arising Out Of Ita No.2145/Del/2017] Assessment Year: 2011-12 M/S. Xl India Business Vs. Addl. Cit, Services Pvt. Ltd., Special Range-9, New Delhi Ff-101, Building No. G-11, Sarines Sonia Sadan, Community Centre, Vikas Puri, New Delhi Pan :Aaacx0309A (Appellant) (Respondent)

10-B of the Act and cannot be taxed separately under Section 56 of the Act.” 42. Thus, the ratio and principle laid down in the aforesaid judgments is quite clear that the computation of profit as given in sub-section (4) of Section 10A has to be seen in the context of entire income derived from income of export

XL INDIA BUSINESS SERVICES PVT. LTD.,NEW DELHI vs. ADDL. CIT, NEW DELHI

In the result, the appeal of the assessee is partly allowed

Bench: Shri R.K. Panda & Shri Amit Shukla

10-B of the Act and cannot be taxed separately under Section 56 of the Act.” 42. Thus, the ratio and principle laid down in the aforesaid judgments is quite clear that the computation of profit as given in sub-section (4) of Section 10A has to be seen in the context of entire income derived from income of export

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS deduction was filed under

AVV ENTERPRISES PVT. LTD.,DELHI vs. DCIT, CPC- TDS , GHAZIABAD

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS deduction was filed under

S vs. GUARDING SERVICES PVT. LTD.,NEW DELHIVS.ITO, TDS, WARD- 77(3), NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS deduction was filed under

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS deduction was filed under

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS deduction was filed under

CHRONICLE PUBLICATION PVT LTD,NEW DELHI vs. ACIT (CPC)-TDS, NEW DELHI

In the result, all appeals of different assesses are allowed

Bench: Ms. Sushma Chowla, Vp & Dr. B.R.R. Kumar, Am

10. We have heard the rival contention and perused the record. The issue which is arising in the present set of appeals is against the chargeability of late filing fee in terms of section 234E of the Act. The issue which is raised by different assessee before us is whether where the return for the TDS deduction was filed under