BIOCON LIMITED vs. THE DEPUTY

In the result, the impugned order dated 30

Bench: ALOK ARADHE,R. NATARAJ

1. The Tribunal was right in holding that the appellant was not entitled to deduction under Section 35(2AB) of the Act to the extent the expenses eligible for deduction under the said provisions pertained to unit entitled for deduction under Section 10B of the Act? 3 2. The Tribunal was right in holding that Section

THE COMMISSIONER OF INCOME TAX vs. M/S. TRIDENT MINERALS (100% EOU)

The appeal is dismissed

Bench: H.T.NARENDRA PRASAD,B.VEERAPPA

disallowance of excess profits amounting to Rs.4,76,52,385/- due to transactions with sister concerns from computation of the eligible deduction under Section 10B of the Act, was withdrawn by the assessee, when actually it was not so. 2. It is the case of the assessee that they carry business of production, manufacture and export of iron

PR COMMISSIONER OF INCOME TAX-4 vs. M/S JEANS KNIT PVT LTD

In the result, we do not find any

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the assessee's claim for deduction under Section 10B of the Act. 5. The Assessing Officer inter alia held that assessee is entitled to deduction under Section 10B of the Act only after verification and the contention of the assessee that old machinery from FFIPL was transferred to it only in April 2007 does not deserve acceptance

PR.COMMISSIONER OF vs. M/S JEANS KNIT PVT.LTD

In the result, we do not find any

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the assessee's claim for deduction under Section 10B of the Act. 5. The Assessing Officer inter alia held that assessee is entitled to deduction under Section 10B of the Act only after verification and the contention of the assessee that old machinery from FFIPL was transferred to it only in April 2007 does not deserve acceptance

PR COMMISSIONER OF vs. M/S JEANS KNIT PVT LTD

In the result, we do not find any

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the assessee's claim for deduction under Section 10B of the Act. 5. The Assessing Officer inter alia held that assessee is entitled to deduction under Section 10B of the Act only after verification and the contention of the assessee that old machinery from FFIPL was transferred to it only in April 2007 does not deserve acceptance

SAINT GOBAIN CRYSTALS & DETECTORS (I) LIMITED vs. DEPUTY COMMISSIONER OF INCOME TAX

In the result, the order of the tribunal insofar as

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

1 was not entitled to deduction under Section 10B for the assessment year 2008-09, on the basis that the ten consecutive assessment years for the purposes of the said provision would begin from the assessment year 1997-98, when the Appellant commenced manufacture, and not from the assessment year 1999-00 when the Appellant actually started claiming the relief

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

PR COMMISSIONER OF vs. M/S SYNGENE

In the result, we do not find any merit in this appeal, the

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the deduction claimed by the assessee under Section 10B of the Act to the tune of Rs.21,31,59,892/- and added it to the income of the assessee. 5 4. The assessee thereupon approached the Commissioner of Income Tax (Appeals) who by an order dated 22.06.2012 inter alia held that Assessing Officer as unable to counter the claim

M/S METRIX PRECISION COMPONENTS PVT. LIMITED vs. THE DEPUTY COMMISSIONER OF INCOME TAX

In the result, the appeal is allowed

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

disallowed the claim of deduction of the assessee under Section 10B of the Act. 3. The assessee thereupon filed an appeal before the Commissioner of Income Tax (Appeals). The Commissioner of Income Tax (Appeals) by an order dated 20.09.2012 inter alia held that the assessee has not satisfied the conditions required for claiming deduction under Section 10B

M/S GRANITE MART LIMITED vs. THE INCOME-TAX OFFICER

In the result the order passed by the

Bench: ALOK ARADHE,M.NAGAPRASANNA

1) of the Act were issued to the appellant. The Assessing Officer allowed the deduction under Section 10B of the Act only to the extent of direct export made by the appellant and disallowed

THE PR COMMISSIONER OF INCOME TAX vs. M/S MPHASIS LTD

The appeal is dismissed accordingly

Bench: SATISH CHANDRA SHARMA,V SRISHANANDA

10B deduction by following the decision of this Hon’ble High Court in the case of CIT v/s Tata Elxsi and even when the recomputation done by the assessing authority is in accordance with the provisions of the Act. 8. It is submitted that the Tribunal erred in setting aside the disallowance of depreciation @ 60% on switches and routers amounting

SMT. PUNEETHA @ PUNEETHA B. A. vs. SRI. D. RAVI

The appeal is dismissed accordingly

Bench: R DEVDAS

10B deduction by following the decision of this Hon’ble High Court in the case of CIT v/s Tata Elxsi and even when the recomputation done by the assessing authority is in accordance with the provisions of the Act. 8. It is submitted that the Tribunal erred in setting aside the disallowance of depreciation @ 60% on switches and routers amounting

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

Bench: N.KUMAR,RATHNAKALA

10B of Income Tax Act, 1961 (hereinafter referred to as ‘the Act’ for brevity). - 3 - 2. The assessee had earned interest from the following sources:- 1. Deposits lying in the EEFC account and 2. Advancing of inter-corporate loans out of the funds of the undertaking. The assessee had outstanding borrowings by way of External Commercial Borrowings (ECBs in short

THE PR. COMMISSIONER OF INCOME TAX CIT (A) vs. M/S. LAKSHMINARAYANA MINING COMPANY

The appeals are dismissed

Bench: S SUNIL DUTT YADAV,B.S PATIL

10B could not be disallowed or restricted merely on the ground that certain plant and machinery is situated outside the 7 ‘bonded area’ and as the assessee is an exporter and not an importer in terms of the Notification under 54/1997 dated 3.6.1997 issued under Section 25(1

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

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

1. THE COMMISSIONER OF INCOME TAX C.R.BUILDING, QUEENS ROAD BENGALURU 2. THE ASST. COMMISSIONER OF INCOME TAX CIRCLE – 11(5) 3 C.R.BUILDING, QUEENS ROAD BENGALURU ... APPELLANTS (BY SRI: K.V.ARAVIND, ADVOCATE) AND: M/S.L.G.SOFT INDIA PRIVATE LIMITED CHERRY HILLS EMBASSY GOLF LINKS BUSINESS PARK BENGALURU – 560 071 ... RESPONDENT (BY SRI:T.SURYANARAYANA, ADVOCATE) THIS INCOME TAX APPEAL IS FILED UNDER SECTION

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

1. THE COMMISSIONER OF INCOME TAX C.R.BUILDING, QUEENS ROAD BENGALURU 2. THE ASST. COMMISSIONER OF INCOME TAX CIRCLE – 11(5) 3 C.R.BUILDING, QUEENS ROAD BENGALURU ... APPELLANTS (BY SRI: K.V.ARAVIND, ADVOCATE) AND: M/S.L.G.SOFT INDIA PRIVATE LIMITED CHERRY HILLS EMBASSY GOLF LINKS BUSINESS PARK BENGALURU – 560 071 ... RESPONDENT (BY SRI:T.SURYANARAYANA, ADVOCATE) THIS INCOME TAX APPEAL IS FILED UNDER SECTION

PR COMMISSIONER OF INCOME TAX-5 vs. M/S NOVELL SOFTWARE DEVELOPMENT (INDIA) PVT.LTD.

In the result, we do not find any merit in this appeal

Bench: ALOK ARADHE,R. NATARAJ

1)(vi) of the Act? (2) Whether on the facts and in the circumstances of the case, the Tribunal is right in setting aside disallowance made under Section 14A of the Act without the same is made in accordance with Rule 8D of I.T. Rules?". Thereafter, additional substantial question of law was formulated which reads as under: "Whether the direction