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88 results for “TDS”+ Section 80G(5)(ii)clear

Sorted by relevance

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Key Topics

Section 80G62Section 143(3)56Section 14A51Section 92C51Deduction46Addition to Income46Section 12A45Disallowance42Section 2(15)27Section 11

INTERGLOBE TECHNOLOGY QUOTIENT PRIVATE LIMITED,NEW DELHI vs. ASSISTANT COMMISSIONER CIRCLE 10(1), NEW DELHI

ITA 95/DEL/2024[2020-2021]Status: DisposedITAT Delhi28 May 2024AY 2020-2021

Bench: Shri M. Balaganesh & Shri Anubhav Sharma[Assessment Year: 2020-21

Section 139(1)Section 143(3)Section 144BSection 199Section 250Section 251(2)Section 80G

5) of the Companies Act are also eligible for deduction's 80G of the Act ITA No. 1523/Del./2022 subject to satisfying the requisite conditions prescribed for deduction w/s 80G of the Act. For this purpose, the issue is remanded to the file of AO to examine the same whether the payments satisfy the claim of donation's 80G

Showing 1–20 of 88 · Page 1 of 5

26
Transfer Pricing26
Section 80I23

GENPACT SERVICES LLC,GURGAON vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - INT TAX 1(3)(1), DELHI

In the result, appeal of the assessee is partly allowed

ITA 4477/DEL/2024[2020-21]Status: DisposedITAT Delhi31 Jul 2025AY 2020-21

Bench: Shri Prakash Chand Yadav\Nand\Nshri Brajesh Kumar Singh\N\Nita No. 4477/Del/2024\N[Assessment Year: 2020-21]\N\N| Genpact Services Llc,\Nplot 22A & B, Sector 18,\Nudyog Vihar,\Ngurgaon, Haryana-122002\Npan-Aaccg3353P\Nappellant\N|\Nassistant Commissioner Of Income\Ntax, Circle-International Tax-1(3)(1),\Nvs Delhi-110002\Nrespondent\N\N| Appellant By\Nshri Vishal Kalra, Adv.,\Nms. Reema Malik, Adv.& Ms.\Nsnigdha Gautam, Adv.\Nrespondent By\Nshri S.K. Jadhav, Cit Dr\N\Ndate Of Hearing\N30.07.2025\Ndate Of Pronouncement\N31.07.2025\N\Norder\N\Nper Brajesh Kumar Singh, Am,\Nthis Appeal By The Assessee Is Directed Against The Order Of The\Nassessing Officer Dated 29.07.2024 Passed U/S 143(3) R.W.S.144C(13) Of\Nthe Income Tax Act, 1961 (Hereinafter ‘The Act') In Pursuance To The\Ndirections Of Dispute Resolution Panel Dated 25.06.2024 Pertaining To\N Assessment Year 2020-21.\N2. The Relevant Facts Are That The Assessee Is An Indian Branch Office Of\Ngenpact Llc, A Usa Company. The Assessee Is A Service Provider\Nrendering Off-Shore Support Services Akin To Bpo Services, Including\Ncollections/Analytics Call Centre Services & Other Back-Office Support\Nservices To Its Aes. The Assessee Is Responsible For Rendering The\Ndesignated Bpo / Collections Services From Its Facility / Infrastructure In\Nindia. As For Assessment Year 2020-21, The Assessee Filed Its Return Of\Nincome (Roi') Declaring An Income Of Inr 20,57,10,540/- On 07.01.2021.\Nduring The Course Of Scrutiny, The Assessing Officer Made A Reference U/S\N92Ca Of The Act To The Transfer Pricing Officer (Tpo') To Determine The\Narm'S Length Price (‘Alp') In Respect Of International Transaction Entered\Ninto By The Assessee.\N2.

Section 133ASection 143(3)Section 92C

80G(5) of\nthe Act. Accordingly, Ground no.4 of the appeal is allowed.\n8. Ground No. 5 This ground arises out of claim of assessee that\nduring the FY 2009-10 (relevant to AY 2010-11), the Assessee acquired a\nbusiness of third-party debt collection services as well as part of the\nanalytics business from Genpact India

ACIT-CIRCLE-3(1), GURGAON vs. TERADATA INDIA PRIVATE LIMITED, GURGAON

Appeal of the revenue is allowed for AY 2018-19

ITA 1430/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Oct 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 37Section 80G

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part II-Corporate Tax Grounds 6. Denial of deduction under Section 80G. 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 21,47.646/- claimed under section 80G

TERADATA INDIA PVT LTD,GRUGRAM vs. DCIT CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

ITA 2337/DEL/2022[2018-19]Status: DisposedITAT Delhi13 Oct 2023AY 2018-19

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 37Section 80G

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part II-Corporate Tax Grounds 6. Denial of deduction under Section 80G. 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 21,47.646/- claimed under section 80G

TERADATA INDIA P.LTD,GURUGRAM vs. DCIT,CIRCLE-3(1), GURUGRAM

Appeal of the revenue is allowed for AY 2018-19

ITA 1248/DEL/2022[2017-18]Status: DisposedITAT Delhi13 Oct 2023AY 2017-18

Bench: Shri M. Balaganesh & Shri Yogesh Kumar Us

For Appellant: Shri Nageswar Rao, AdvFor Respondent: Shri Rajesh Kumar, CIT DR
Section 143(3)Section 37Section 80G

5. That once working capital adjustment is granted no separate adjustment on account of outstanding receivables is maintainable. Part II-Corporate Tax Grounds 6. Denial of deduction under Section 80G. 6.1. That on the facts and circumstances of the case and in law, the Learned AO has erred in disallowing the deduction of INR 21,47.646/- claimed under section 80G

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nand 'attributable to'. Further they held that

JCIT(OSD), RANGE-10, NEW DELHI , ITO C.R. BUILDING vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA

REC LIMITED,NEW DELHI vs. ACIT-10 (OSD), DELHI, NEW DELHI

ITA 319/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA

JCIT(OSD), RANGE-10, NEW DELHI , CR BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\nand 'attributable to'. Further they held that

JCIT(OSD), RANGE-10, NEW DELHI , C.R. BUILDING ITO vs. RURAL ELECTRIFICATION CORPORATION LTD. , KASTURBA NAGAR

In the result, appeals filed by the revenue in the AY 2020-21 and AY\n2021-22 are dismissed

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22
For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

TDS) under Section 195 of the Income-tax Act, 1961, as it deemed to\naccrue or arise in India. It is not relevant to the present issue.\n12. Further as held in the case of Meghalaya Steels Ltd (supra), the Hon'ble\nSupreme Court explained the distinction between the terms 'derived from'\n27\nITA Nos.319 & 320/Del/2025\nITA Nos.577& 578/Del/2025\nITA

ACTION ALLIANCE FOR RECYCLING BEVERAGE CARTONS ('AARC'),NEW DELHI vs. CIT (EXEMPTION), NEW DELHI

In the result, both the appeals filed by the assessee are accordingly allowed for statistical purpose

ITA 7685/DEL/2019[-]Status: DisposedITAT Delhi28 Feb 2020

Bench: Sh. R. K. Panda & Sh. K. N. Chary

Section 12ASection 194Section 80Section 80G

80G. 2. Facts of the case, in brief, are that the assessee is a society and filed an application in form 10A and 10G on 29th January, 2019 seeking registration u/s.12AA and exemption u/s.80G of the Income Tax Act, 1961. 3. The Ld. CIT(E) issued a questionnaire dated 19.02.2019 requesting it to submit certain documents in support

ACTION ALLIANCE FOR RECYCLING BEVERAGE CARTONS ('AARC'),NEW DELHI vs. CIT (EXEMPTION), NEW DELHI

In the result, both the appeals filed by the assessee are accordingly allowed for statistical purpose

ITA 7684/DEL/2019[-]Status: DisposedITAT Delhi28 Feb 2020

Bench: Sh. R. K. Panda & Sh. K. N. Chary

Section 12ASection 194Section 80Section 80G

80G. 2. Facts of the case, in brief, are that the assessee is a society and filed an application in form 10A and 10G on 29th January, 2019 seeking registration u/s.12AA and exemption u/s.80G of the Income Tax Act, 1961. 3. The Ld. CIT(E) issued a questionnaire dated 19.02.2019 requesting it to submit certain documents in support

EXL SERVICE.COM (INDIA) PVT. LTD.,NEW DELHI vs. DCIT (LTU), NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

ITA 302/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jan 2017AY 2010-11

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

For Appellant: Sh. Ajay Vohra, AdvFor Respondent: Sh. Piyush Jain, CIT DR
Section 143(3)Section 92D

TDS Office on the basis of disallowance of Rs. 2,69,241 being made in the draft assessment order. 14. The Ld. AO erred in law and on the facts and circumstances of the case by making an addition of Rs. 463 in respect of contribution to Employee State Insurance wrongly considering the date of payment to be beyond

DCIT (LTU), NEW DELHI vs. M/S. EXL SERVICE.COM (INDIA) PVT. LTD., NEW DELHI

In the result, the appeal by the assessee as well as ofthe department are partly allowed for statistical purposes

ITA 615/DEL/2015[2010-11]Status: DisposedITAT Delhi03 Jan 2017AY 2010-11

Bench: Sh. N. K. Saini, Am & Sh. Kuldip Singh, Jm Ita No. 302/Del/2015 : Asstt. Year : 2010-11 Exl Service.Com (India) Pvt. Ltd., Vs Deputy Commissioner Of Income 414, 4Th Floor, Dlf Jasola, Tax, Large Tax Payer Unit, Tower-B, Plot No. 10 & 11, Dda New Delhi District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Ita No. 615/Del/2015 : Asstt. Year : 2010-11 Deputy Commissioner Of Income Vs Exl Service.Com (India) Pvt. Ltd., 414, 4Th Floor, Dlf Jasola, Tower- Tax, Circle-1 (Ltu), New Delhi-110017 B, Plot No. 10 & 11, Dda District Centre, Jasola, New Delhi-110044 (Appellant) (Respondent) Pan No. Aaace5174C Assessee By : Sh. Ajay Vohra, Adv. Sh. Abhishek Agarwal, Adv. Revenue By : Sh. Piyush Jain, Cit Dr Date Of Hearing : 07.10.2017 Date Of Pronouncement : 03.01.2017 Order Per N. K. Saini, Am:

For Appellant: Sh. Ajay Vohra, AdvFor Respondent: Sh. Piyush Jain, CIT DR
Section 143(3)Section 92D

TDS Office on the basis of disallowance of Rs. 2,69,241 being made in the draft assessment order. 14. The Ld. AO erred in law and on the facts and circumstances of the case by making an addition of Rs. 463 in respect of contribution to Employee State Insurance wrongly considering the date of payment to be beyond

PLANMAN CONSULTING (INDIA) PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal in ITA No

ITA 5753/DEL/2013[2009-10]Status: DisposedITAT Delhi06 Nov 2015AY 2009-10

Bench: Sh. Inturi Rama Rao & Ms. Suchitra Kamble

For Appellant: Sh. Ved Jain, CAFor Respondent: Smt. Anjula Jain, Sr. DR
Section 143(1)Section 143(3)Section 14ASection 40Section 80G

ii) That the disallowance has been confirmed ignoring the fact that TDS has been deposited before the due date of filing the return and in view of the amendment to section 40(a)(ia) the same are allowable during the year under consideration. (iii)Without prejudice to the above and in the alternative, TDS being deposited in the succeeding year

PLANMAN CONSULTING (INDIA) PVT. LTD.,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal in ITA No

ITA 5752/DEL/2013[2008-09]Status: DisposedITAT Delhi06 Nov 2015AY 2008-09

Bench: Sh. Inturi Rama Rao & Ms. Suchitra Kamble

For Appellant: Sh. Ved Jain, CAFor Respondent: Smt. Anjula Jain, Sr. DR
Section 143(1)Section 143(3)Section 14ASection 40Section 80G

ii) That the disallowance has been confirmed ignoring the fact that TDS has been deposited before the due date of filing the return and in view of the amendment to section 40(a)(ia) the same are allowable during the year under consideration. (iii)Without prejudice to the above and in the alternative, TDS being deposited in the succeeding year

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

ITA 1545/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2016AY 2010-11

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Sawain, CIT DR
Section 143Section 143(3)Section 144CSection 92C

5 of the appeal of the assessee is against an addition of Rs. 3.02 lakhs by estimating the value of the scrap lying in stock as at the end of the relevant previous year on hypothetical and national basis. Ld. assessing officer on perusal of the significant accounting policies mentioned in scheduled 12 of the financial statements for the financial

ADIT(E), NEW DELHI vs. M/S. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2871/DEL/2014[2009-10]Status: DisposedITAT Delhi24 Dec 2020AY 2009-10

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree

ADIT (E), NEW DELHI vs. IILM FOUNDATION, NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 2675/DEL/2013[2008-09]Status: DisposedITAT Delhi24 Dec 2020AY 2008-09

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree

IILM FOUNDAION,NEW DELHI vs. ADIT (EXEMPTION), NEW DELHI

In the result, the appeal of the assessee is partly allowed and appeals of the Revenue are dismissed

ITA 1142/DEL/2011[2007-08]Status: DisposedITAT Delhi24 Dec 2020AY 2007-08

Bench: Shri G.S. Pannu & Shri Amit Shukla(Through Video Conferencing) Assessment Year: 2007-08

For Appellant: Shri Rohit Jain, Adv., Ms. TejasviFor Respondent: Ms. Sunita Singh, CIT-D.R
Section 11Section 12ASection 13Section 13(1)(c)Section 13(3)Section 143(3)

TDS Aarti Rai 29,750/- Dr. 6. From the above details, Assessing Officer inferred that these payments are in violation of Section 13(1)(c) read with section 13(3) and on these account the assessee is liable to lose its exemption. He further noted the name of these two persons does not appear as employee of the Banyan Tree