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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

10A income is chargeable to tax in view - 34 - of Section 4 of the Act. However, subject to the assessee satisfying the conditions prescribed income under Section 10-A is exempted from making such payment. Once the assessee is made to pay tax on such exempted income in the other contracting State then Section 90(1)(a)(ii) enables

PR. COMMISSIONER OF INCOME TAX vs. M/S SASKEN

Appeals are dismissed at the stage of admission

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

Section 10A of the Income Tax Act, 1961, (for short ‘the Act’). The assessee filed returns, which was processed and subsequently taken up for scrutiny and notices were issued. The respondent – assessee produced necessary books of accounts, when the information was called for by the Assessing Authority. The Assessing Authority disallowed

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

disallowance under Section 40(a)(ia) of the Act is to ensure prevention of revenue leakage on foreign payments as recovery of tax from non resident payees was difficult. With regard to the claim of set off of STP unit losses of the assessee, it is 17 submitted that in view of decision of the Supreme Court in ‘COMMISSIONER

CGI INFORMATION SYSTEMS vs. THE INCOME TAX OFFICER

Appeals are allowed

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 10A of the IT Act was disallowed. For A.Y. 1999-2000, 2000-2001 deduction claimed under Section 10A was allowed

CGI INFORMATION SYSTEMS vs. THE INCOME TAX OFFICER

Appeals are allowed

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 10A of the IT Act was disallowed. For A.Y. 1999-2000, 2000-2001 deduction claimed under Section 10A was allowed

CGI INFORMATION SYSTEMS vs. DEPUTY COMMISSIONER OF

Appeals are allowed

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 10A of the IT Act was disallowed. For A.Y. 1999-2000, 2000-2001 deduction claimed under Section 10A was allowed

THE PR COMMISSIONER OF INCOME TAX, CIT(A) vs. M/S INFOSYS LTD

Bench: P.S.DINESH KUMAR,T.G. SHIVASHANKARE GOWDA

Section 10A of the Act on account of disallowance of Rs.25,20,566/- made under Section 14A of the Act? 6. Whether

COMMISSIONER OF INCOME TAX-III vs. M/S. ONMOBILE GLOBAL LTD

In the result, the matter is remitted to the Tribunal to

Bench: ALOK ARADHE,R. NATARAJ

disallowed the deduction claimed in respect of stamp duty charges, professional and legal charges, depreciation on computers as well as claims made under Section 80JJAA of the Act as well as Section 10A

PR.COMMISSIONER OF INCOMETAX-2 vs. M/S.EYGBS (INDIA) PVT LTD

Bench: CHIEF JUSTICE,C M JOSHI

disallowance was founded on the proviso to Section 92C(4) of the Act. - 12 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 17. It is material to note that the TP adjustments are made pursuant to the APA entered into by the Assessee with CBDT. Section 92CC

M/S SUBEX LIMITED vs. THE DEPUTY COMMISSIONER OF

Appeal is allowed

Bench: P.S.DINESH KUMAR,M G UMA

disallowance of deduction of Rs.9,53,10,234/- being the sale of hardware component from export turnover under Section 10A

THE COMMISSIONER OF INCOME TAX vs. M/S SHRIRAM CHITS

Appeal is allowed

Bench: ARAVIND KUMAR,JAYANT PATEL

disallowance of deduction of Rs.9,53,10,234/- being the sale of hardware component from export turnover under Section 10A

THE PR COMMISSIONER OF INCOME TAX vs. M/S EXIDE LIFE INSURANCE COMPANY LTD

In the result, both the appeals stand dismissed

Bench: S.SUJATHA,RAVI V HOSMANI

disallowance of surplus from shareholders account treated as income from other sources by assessee by holding that surplus available both in Policy Holder’s 6 Account and share Holder’s account is to be consolidated and net surplus only to be taxed as income from business without appreciating that income from life insurance business is treated differently when compared

THE PR COMMISSIONER OF INCOME TAX vs. M/S EXIDE LIFE INSURANCE CO LTD

In the result, both the appeals stand dismissed

Bench: S.SUJATHA,RAVI V HOSMANI

disallowance of surplus from shareholders account treated as income from other sources by assessee by holding that surplus available both in Policy Holder’s 6 Account and share Holder’s account is to be consolidated and net surplus only to be taxed as income from business without appreciating that income from life insurance business is treated differently when compared

PRINCIPAL COMMISSIONER OF INCOME TAX-4 vs. M/S MCML SYSTEMS PVT LTD

Bench: ABHAY SHREENIWAS OKA (CJ),S.G.PANDIT

disallowed deductions under Section 10A of the Income Tax Act, 1961 (for brevity ‘the Act’) observing that under Section 10A

THE COMMISSIONER OF INCOME-TAX vs. M/S L.G SOFT INDIA PVT LTD

The appeal is disposed off accordingly

Bench: The Hon’Ble Mr. Justice Ravi Malimath

disallowed by the Assessing Officer. Even in terms of Section 10A of the Act such a claim cannot be disallowed

THE COMMISSIONER OF INCOME-TAX vs. M/S L.G SOFT INDIA PVT LTD

The appeal is disposed off accordingly

Bench: The Hon’Ble Mr. Justice Ravi Malimath

disallowed by the Assessing Officer. Even in terms of Section 10A of the Act such a claim cannot be disallowed

M/S WIPRO LIMITED vs. THE ADDITIONAL COMMISSIONER OF INCOME-TAX,

In the result, the appeal is disposed of in terms of

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the claim of the assessee under Section 14A of the Act. The tribunal in respect of losses incurred by the units eligible for deduction under Section 10A

THE COMMISSIONER OF INCOME TAX vs. M/S MOTOROLA INDIA ELECTRONICS (P) LTD

Bench: N.KUMAR,RATHNAKALA

section 10A, the assessee would be entitled for deduction, as the assessee is a 100% exporter, i.e. the entire business of the assessee consists of development and export of software. The assessing authority did not agree with the said contention and therefore, he disallowed