THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

31. Thus, Section 90 empowers the Central Government to enter into an agreement with the Government of any country for two purposes: (a) for granting of relief in respect of income tax paid or payable (b) for avoidance of double taxation of income - 46 - 32. Prior to the amendment, the relief was granted in respect of income on which

THE COMMISSIONER OF INCOME TAX vs. M/S CHESLIND, TEXTILES LTD

The appeal stands allowed

Bench: B.MANOHAR,N.KUMAR

depreciation also merits a similar treatment. 31. As the income of 10-A unit has to be excluded at source itself before arriving at the gross total income, the loss of non 10-A unit cannot be set off against the income of 10-A unit under Section

THE COMMISSIONER OF INCOME TAX vs. M/S WIPRO LTD

In the result, the appeals are partly allowed

Bench: B.MANOHAR,DILIP B.BHOSALE

depreciation? A-8. Whether the Tribunal was correct in holding that the donations made to Khandesh Education Society do not attract the provisions of Section 40A(9) of the Act? 7 5. In ITA 133/07, the following two substantial questions of law arise for our consideration: A-9. Whether the Tribunal was correct in holding that the stock transfers made

M/S SANKHLA POLYMERS (P) LTD vs. THE INCOME TAX OFFICER WARD-12(2)

In the result, the appeal relating to the assessment

Bench: D.V.SHYLENDRA KUMAR,B.SREENIVASE GOWDA

10 or section 10A or section 10B or section 11 or section 12 apply, if any such amount is credited to the profit and loss account; or (iii) the amount of loss brought forward or unabsorbed depreciation, whichever is less as per books of account. Explanation – For the purposes of this clause – (a) the loss shall not include depreciation

M/S UDAYA SOUHARDA CREDIT CO OP SOCIETY LTD vs. THE INCOME TAX OFFICER

In the result, Writ appeals stand dismissed

Bench: S.SUJATHA,S RACHAIAH

10(2)(vi) and the method of carrying it forward is to add it to the amount of the allowance or -27- depreciation in the following year and deeming it to be part of that allowance ; the effect of deeming it to be part of that allowance is that it falls in the following year within Clause

M/S SWABHIMANI SOUHARDA CREDIT CO-OPERATIVE LTD vs. INCOME TAX OFFICER (ITO) WARD-5(2)(3

In the result, Writ appeals stand dismissed

Bench: S.SUJATHA,S RACHAIAH

10(2)(vi) and the method of carrying it forward is to add it to the amount of the allowance or -27- depreciation in the following year and deeming it to be part of that allowance ; the effect of deeming it to be part of that allowance is that it falls in the following year within Clause

M/S SRI VARUN SOUHARDA CREDIT CO OP LTD vs. THE INCOME TAX OFFICER

In the result, Writ appeals stand dismissed

Bench: S.SUJATHA,S RACHAIAH

10(2)(vi) and the method of carrying it forward is to add it to the amount of the allowance or -27- depreciation in the following year and deeming it to be part of that allowance ; the effect of deeming it to be part of that allowance is that it falls in the following year within Clause

M/S UDAYA SOUHARDA CREDIT CO-OP SOCIETY LTD vs. THE INCOME TAX OFFICER

In the result, Writ appeals stand dismissed

Bench: S.SUJATHA,S RACHAIAH

10(2)(vi) and the method of carrying it forward is to add it to the amount of the allowance or -27- depreciation in the following year and deeming it to be part of that allowance ; the effect of deeming it to be part of that allowance is that it falls in the following year within Clause

M/S SWABHIMANI SOUHARDA CREDIT CO OPERATIVE LTD vs. INCOME TAX OFFICER (ITO) WARD-5(2)(3)

In the result, Writ appeals stand dismissed

Bench: S.SUJATHA,S RACHAIAH

10(2)(vi) and the method of carrying it forward is to add it to the amount of the allowance or -27- depreciation in the following year and deeming it to be part of that allowance ; the effect of deeming it to be part of that allowance is that it falls in the following year within Clause

PR. COMMISSIONER OF INCOME TAX vs. M/S. GMR SPORTS PVT. LTD.,

In the result, the appeals are disposed of

Bench: ALOK ARADHE,M.G.S. KAMAL

31,47,200/-. The assessee thereupon filed an appeal before the Commissioner 8 of Income Tax (Appeals), who by an order dated 31.07.2014 directed the Assessing Officer to treat the franchise fees as revenue expenditure and delete the addition. It was held by the Commissioner of Income Tax (Appeals) that in terms of Section

PR COMMISSIONER OF INCOME TAX vs. M/S GMR SPORTS PVT LTD

In the result, the appeals are disposed of

Bench: ALOK ARADHE,M.G.S. KAMAL

31,47,200/-. The assessee thereupon filed an appeal before the Commissioner 8 of Income Tax (Appeals), who by an order dated 31.07.2014 directed the Assessing Officer to treat the franchise fees as revenue expenditure and delete the addition. It was held by the Commissioner of Income Tax (Appeals) that in terms of Section

PR. COMMISSIONER OF INCOME TAX vs. M/S. GMR SPORTS PVT. LTD.,

In the result, the appeals are disposed of

Bench: ALOK ARADHE,M.G.S. KAMAL

31,47,200/-. The assessee thereupon filed an appeal before the Commissioner 8 of Income Tax (Appeals), who by an order dated 31.07.2014 directed the Assessing Officer to treat the franchise fees as revenue expenditure and delete the addition. It was held by the Commissioner of Income Tax (Appeals) that in terms of Section

M/S. MARMON FOOD AND BEVERAGE TECHNOLOGIES INDIA vs. THE INCOME TAX OFFICER

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

depreciation for each of the relevant assessment years. (7) The provisions of sub-section (8) and sub-section (10) of section 80IA shall, so far as may be, apply in relation to the undertaking referred to in this section as they apply for the purposes of the undertaking referred to in section 80-IA. (7A) Where any undertaking

M/S. MARMON FOOD AND BEVERAGE TECHNOLOGIES INDIA vs. THE INCOME TAX OFFICER

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

depreciation for each of the relevant assessment years. (7) The provisions of sub-section (8) and sub-section (10) of section 80IA shall, so far as may be, apply in relation to the undertaking referred to in this section as they apply for the purposes of the undertaking referred to in section 80-IA. (7A) Where any undertaking

M/S. MARMON FOOD AND BEVERAGE TECHNOLOGIES INDIA vs. THE INCOME TAX OFFICER

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

depreciation for each of the relevant assessment years. (7) The provisions of sub-section (8) and sub-section (10) of section 80IA shall, so far as may be, apply in relation to the undertaking referred to in this section as they apply for the purposes of the undertaking referred to in section 80-IA. (7A) Where any undertaking

THE COMMISSIONER OF INCOME-TAX vs. M/S.GE INDIA TECHNOLOGY

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

depreciation for each of the relevant assessment years. (7) The provisions of sub-section (8) and sub-section (10) of section 80IA shall, so far as may be, apply in relation to the undertaking referred to in this section as they apply for the purposes of the undertaking referred to in section 80-IA. (7A) Where any undertaking

M/S. MARMON FOOD AND BEVERAGE TECHNOLOGIES INDIA vs. THE INCOME TAX OFFICER

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

depreciation for each of the relevant assessment years. (7) The provisions of sub-section (8) and sub-section (10) of section 80IA shall, so far as may be, apply in relation to the undertaking referred to in this section as they apply for the purposes of the undertaking referred to in section 80-IA. (7A) Where any undertaking

M/S. MARMON FOOD AND BEVERAGE TECHNOLOGIES INDIA vs. THE INCOME TAX OFFICER

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

depreciation for each of the relevant assessment years. (7) The provisions of sub-section (8) and sub-section (10) of section 80IA shall, so far as may be, apply in relation to the undertaking referred to in this section as they apply for the purposes of the undertaking referred to in section 80-IA. (7A) Where any undertaking