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39 results for “disallowance”+ Permanent Establishmentclear

Sorted by relevance

Delhi1,108Mumbai935Chennai512Bangalore292Kolkata232Ahmedabad135Jaipur89Cochin63Chandigarh56Raipur47Karnataka39Amritsar37Indore35Hyderabad29Rajkot26Pune22Cuttack22Visakhapatnam21Guwahati19Lucknow16Surat14SC13Varanasi11Dehradun8Panaji7Agra6Nagpur4Telangana4Kerala3Patna2Calcutta1Jabalpur1Jodhpur1Rajasthan1Allahabad1Ranchi1

Key Topics

Section 260A264Section 26050Section 14810Section 65(1)9Section 639Revision u/s 2638Section 376Section 12A6Addition to Income6Section 139(1)

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

The appeals stand disposed of, accordingly

ITA/211/2009HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Permanent Establishments in foreign countries and also the incomes which are subjected to withholding tax in foreign countries. 15. The assessee-Company claims that it is entitled to relief of such income taxes paid in the foreign jurisdiction. The entitlement to relief of foreign tax is governed by the relevant Double Taxation Avoidance Agreements (DTAAs) with the foreign countries

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

The appeals stand disposed of, accordingly

ITA/881/2008HC Karnataka25 Mar 2015

Bench: N.KUMAR,B.SREENIVASE GOWDA

Section 260

Showing 1–20 of 39 · Page 1 of 2

5
Disallowance5
Deduction3

Permanent Establishments in foreign countries and also the incomes which are subjected to withholding tax in foreign countries. 15. The assessee-Company claims that it is entitled to relief of such income taxes paid in the foreign jurisdiction. The entitlement to relief of foreign tax is governed by the relevant Double Taxation Avoidance Agreements (DTAAs) with the foreign countries

M/S AMD FAR EAST LTD., vs. THE JOINT DIRECTOR OF INCOME-TAX

ITA/419/2016HC Karnataka08 Sept 2021

Bench: S.SUJATHA,RAVI V HOSMANI

Section 115JSection 143Section 144CSection 260Section 260ASection 37Section 92C

disallowing - 4 - deduction under Section 37[1] of the Act in respect of expatriate costs incurred by the assessee’s permanent establishment

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/882/2017HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/897/2017HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/563/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/507/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/560/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/562/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

THE PR COMMISSIONER OF INCOME TAX vs. M/S GOOGLE INDIA PRIVATE LTD

The appeals stand disposed of

ITA/125/2020HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/898/2017HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/505/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/561/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/502/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE IRELAND LIMITED vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/506/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/504/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/549/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/550/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

M/S GOOGLE INDIA PRIVATE LTD vs. THE COMMISSIONER OF INCOME TAX

The appeals stand disposed of

ITA/564/2018HC Karnataka17 Apr 2021

Bench: SATISH CHANDRA SHARMA,S VISHWAJITH SHETTY

Section 260A

established its IT Enabled Services division for provision of IT Enables Services which primarily involved rendering support services in administering the Google editorial guidelines in relation to global advertisements and responding to the queries from customers globally. The appellant under the said agreement has been rendering outsourced services for which the appellant is being separately compensated by the Google Ireland

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

The appeal is disposed of

ITA/231/2013HC Karnataka11 Nov 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 115WSection 260Section 260ASection 3Section 7

permanent establishments of the assessee outside India, which were excluded for computing the fringe benefit tax liability. The Assessing Officer by an order dated 30.12.2008 inter alia held that assessee had made reimbursement of medical expenses to its employees and has claimed that the same is exempt upto Rs.15,000/- in the hands of the employees, and therefore, the assessee