PR COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY SOLUTIONS PVT LTD

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

depreciation under Section 32 of the Act. It is also submitted that aforesaid payment was made towards purchase of software was in the nature of royalty in terms of Explanation 2 to Section 9(1)(vi) of the Act and since, no TDS was deduction under Section 195

PR. COMMISSIONER OF vs. M/S TALLY SOLUTIONS PVT LTD.,

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

depreciation under Section 32 of the Act. It is also submitted that aforesaid payment was made towards purchase of software was in the nature of royalty in terms of Explanation 2 to Section 9(1)(vi) of the Act and since, no TDS was deduction under Section 195

PR COMMISSIONER OF INCOME TAX-7 vs. M/S TALLY SOLUTIONS PVT LTD

In the result, the appeals fail and are hereby

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

depreciation under Section 32 of the Act. It is also submitted that aforesaid payment was made towards purchase of software was in the nature of royalty in terms of Explanation 2 to Section 9(1)(vi) of the Act and since, no TDS was deduction under Section 195

PR COMMISSIONER OF vs. M/S WIPRO LIMITED

In the result, the appeal is disposed of in terms

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

195 of the Act. 7. It is also argued that since payment to non resident was in the nature of royalty in terms of Explanation 2 to Section 9(1)(vi) of the Act and no TDS 16 was deducted on the payment, therefore, disallowance under Section 40(a)(ia) of the Act has rightly been made. It is also

M/S J K INDUSTRIES LTD vs. THE JOINT COMMISSIONER OF INCOME TAX

In the result, all questions are answered against the

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

depreciation of the earlier years and by setting off these amounts, if any, before arriving at the total income of the assessee. 12. The other point canvassed by Sri Shankar is relating to the amount which qualifies as the export incentives under sub-section (1) of Section 80HHC and for the purpose of computing the same as per the formula

COMMISSIONER OF INCOME TAX-III vs. M/S WIPRO LIMITED

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

depreciation of Rs.17.06,58,039/- on software imported even though the assessing authority had rightly disallowed the expenditure under section 40(a)(i) of IT Act as the assessee had failed to comply with the provisions of section 195

COMMISIONER OF INCOME vs. M/S WIPRO LIMITED

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

depreciation of Rs.57,38,83,507/- on 3 software imported even though the assessing authority had rightly disallowed the expenditure under section 40(a)(i) of IT Act as the assessee had failed to comply with the provisions of section 195

THE COMMISSIONER OF INCOME-TAX vs. M/S LUWA INDIA PVT LTD

Bench: RAVI MALIMATH,N.KUMAR

depreciation of Rs.57,38,83,507/- on 3 software imported even though the assessing authority had rightly disallowed the expenditure under section 40(a)(i) of IT Act as the assessee had failed to comply with the provisions of section 195

THE PR. COMMISSIONER OF INCOME TAX vs. M/S SAMSUNG R AND D INSTITUTE INDIA BANGALORE PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

depreciation on the payments made for the same. The Assessing Officer [AO] disallowed the same on the ground that tax was not deducted at source under Section 195

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand

M/S WIPRO LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 145A of the Income- tax Act which was inserted with effect from assessment year 1999-2000. The said provision states that the valuation of stock should include the amount of any tax duty, cess or fee - 94 - actually paid or incurred to bring the goods to its present location and condition. The Department has followed a consistent stand