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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

5) of the Act defines the mandatory requirements and the time limit for rectification and the assessee has not filed any revised return for claim of tax credit with reference to income computed under Section 10A. - 28 - 17. Thereafter, the Assessing Authority proceeded to decide the claim on merits also. Insofar as assessment year 2001-02 is concerned

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

5) of the Act defines the mandatory requirements and the time limit for rectification and the assessee has not filed any revised return for claim of tax credit with reference to income computed under Section 10A. - 28 - 17. Thereafter, the Assessing Authority proceeded to decide the claim on merits also. Insofar as assessment year 2001-02 is concerned

COMMISSIONER OF INCOME TAX-III vs. M/S MPHASIS SOFTWARE AND SERVICES

The appeals stand dismissed

Bench: ARAVIND KUMAR,VINEET SARAN

disallowance made by the Assessing Officer. The Tribunal dismissed the appeal of the Revenue and allowed the claim of the assessee and granted benefit under 4 Section 10A for the ‘on-site’ work carried out by the assessee through its sub-contractor i.e., AE. Aggrieved by the said order, these appeals have been filed, which have been admitted

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

disallowance of deduction under Section 10A in respect of deemed export on account of sale to another STP unit, the Tribunal, relying upon the decision of Tata Elxsi Ltd. (supra), held in favour of the assessee. Aggrieved by the order of the Tribunal, the revenue has I.T.A.Nos.44-45/2016 - 5

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

5. In respect of exclusion of communication charges and reimbursement expenses incurred in foreign currency from export turnover for purpose of computing the deduction under Section 10A of the Act, the claim of the assessee was allowed and the Assessing Officer was directed to exclude the expenses from total turnover as well. The claim of the assessee for deduction under

MADHU SOUHARDA PATHINA SAHAKARI NIYAMITHA vs. THE INCOME TAX OFFICER

The appeal stands dismissed

Bench: S.G.PANDIT,K. V. ARAVIND

disallowance of deduction under Section 80P of the Act, on the ground of non-filing of return of income, can be made only by invoking Section 80AC of the Act. However, Section 80AC has been made applicable to Section 80P of the Act by the Finance Act, 2018 with effect from 01.04.2018, i.e., from the Assessment Year 2018–19. Since

CGI INFORMATION SYSTEMS vs. DEPUTY COMMISSIONER OF

Appeals are allowed

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

5 - 3. For A.Y. 1996-97, though assessee was eligible to claim exemption under Section 10A of the Income Tax Act, 1961 ('IT Act' for short), it claimed deduction under Section 80HHE of the IT Act and the same was allowed. For A.Y. 1997-98, assessee claimed deduction under Section 10A of the IT Act for the first time

CGI INFORMATION SYSTEMS vs. THE INCOME TAX OFFICER

Appeals are allowed

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

5 - 3. For A.Y. 1996-97, though assessee was eligible to claim exemption under Section 10A of the Income Tax Act, 1961 ('IT Act' for short), it claimed deduction under Section 80HHE of the IT Act and the same was allowed. For A.Y. 1997-98, assessee claimed deduction under Section 10A of the IT Act for the first time

CGI INFORMATION SYSTEMS vs. THE INCOME TAX OFFICER

Appeals are allowed

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

5 - 3. For A.Y. 1996-97, though assessee was eligible to claim exemption under Section 10A of the Income Tax Act, 1961 ('IT Act' for short), it claimed deduction under Section 80HHE of the IT Act and the same was allowed. For A.Y. 1997-98, assessee claimed deduction under Section 10A of the IT Act for the first time

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

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

5. Whether on the facts and in the circumstances of the case and in law, the Tribunal is right in directing the Assessing Authority to allow proportionate deduction under Section 10A of the Act on account of disallowance

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

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

5 under Section 143(3) of the Act was passed by the Assessing Authority, by which the assessing authority 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

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

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

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 of the Act. This appeal has been admitted to consider the following question of law: " Whether on the facts and in the circumstances of the case, the Honorable ITAT was right in law in excluding

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 of the Act. This appeal has been admitted to consider the following question of law: " Whether on the facts and in the circumstances of the case, the Honorable ITAT was right in law in excluding

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

disallowance when the assessee had identified the expenditure attributable based on estimated time spent by functionaries responsible for managing companies investments and cash surpluses. It is also submitted that the finding recorded by the tribunal in importing the concept of Section 80IA(5) to Section 10A

THE COMMISSIONER OF INCOME TAX vs. M/S QUEST GLOBAL ENGINEERING SERVICES PVT. LTD.,

In the result, we don to find any

Bench: ALOK ARADHE,R. NATARAJ

disallowance under Section 14A of the Act, the Commissioner of Income Tax (Appeals) upheld the order of the Assessing Officer. In the result, the appeal preferred by the assessee was partly allowed. The assessee as well as the revenue filed appeals before the Income Tax Appellate Tribunal against the order of Commissioner of Income Tax (Appeals). The Tribunal

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

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

disallowance, the assessee filed appeal before the Commissioner of Income Tax Appeals, Bengaluru. The Appellate Authority partly allowed the appeal filed by the assessee in respect of deductions made under Section 10A of the Act. The revenue, aggrieved by the said order, filed ITA ITA.Nos.36-37/2018 - 3 - Nos.2089 and 2094/Bang/2016 before the Tribunal. The Tribunal upheld the order

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

disallowing the claim. On appeal, the order of assessment was set aside and relief under Section 10A of the Act was granted to the assessee. Aggrieved by the same, the Revenue preferred an appeal before the Tribunal. The same was dismissed. Hence, the present appeal in Income Tax Appeal 368 of 2010. 5