M/S. COMPUTER SCIENCE CORPORATION INDIA PVT. LTD.,CHENNAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 2(1) , INDORE

In the result, all the three appeals are partly allowed for statistical purpose and the Stay Application is also disposed of

Bench: Ms. Suchitra Kamble & Shri Bhagirath Mal Biyani

92C(2) of the Act. ITA Nos.179/Ind/2016, 292/Ind/2017, 319/Ind/2018 & SA No.46/Ind/2021 A.Ys. 2011-12, 2012-13 & 2013-14 Page 4 of 29 Corporate Tax related grounds 5. On the facts and in the circumstances of the case and in law, the ld AO/DRP has erred in disallowing an expense of Rs.6,07,00,658/- under Section

COMPUTER SCIENCES CORPORATION INDIA PRIVATE LIMITED,CHENNAI vs. ACIT, CHENNAI

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniassessment Year: 2007-08 Computer Sciences Acit, Corporation India Private Company Circle 1(3), Limited, Chennai [Formerly Covansys (India) Private Limited], बनाम/ Unit 13, Block 2, Sdf Buildings, Vs. Madras Export Processing Zone, Tambaram, Chennai (Assessee / Appellant) (Revenue / Respondent) Pan: Aaacc1351M Assessee By Shri Neeraj Jain, Adv. Shri Abhishek Agrawal, Ca Revenue By Shri P.K. Mishra, Cit Dr Date Of Hearing 12.07.2023 Date Of Pronouncement

disallowing expenditure towards earning of such income, under section 14A, whereas, no expenditure was in fact incurred by the assessee towards earning such income. 25. The ld. AO has erred in computing interest u/s 234B of the Act on the assessed income since the addition to the returned income on account of Transfer Pricing adjustment is only a notional income

CUMMINS TECHNOLOGIES INDIA (P) LTD.,DEWAS vs. ACIT CIRCLE 1(1), UJJAIN

In the result, the appeal of the assesse is allowed

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanicommins Technologies India Acit, Circle -1(1) Private Limited Ujjain Vs. Industrial Area No.2, A.B. Road, M.P. (Appellant / Assessee) (Revenue) Pan: Aabct2018B Assessee By Shri Ketan Ved & Pinkesh Vakharia Ars Revenue By Ms. Simran Bhullar, Cit-Dr Date Of Hearing 29.11.2023 Date Of Pronouncement 30.11.2023

section 92C(3) of the Act and still made adjustments to the arm's length price determined by the Assessee. 7. Inappropriate disallowance