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

In the result, I proceed to pass the following:

Bench: The Hon’Ble Mr.Justice Aravind Kumar

Section 35(2AB) in respect of Research and Development expenditure in a sum of ` 89,35,48,193/-, a sum of ` 48,41,82,071/- was disallowed and same came to be added to the income of assessee-company. Further, a sum of `2,63,68

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

68. What follows is, if the provisions contained in Section 90 is more beneficial to the assessee as compared to the - 85 - terms in the agreement by India with the Government of any country outside India then, notwithstanding such agreement, the provisions of the Act to the extent they are beneficial to that assesseee apply. The benefit claimed

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

The appeals stand disposed of, accordingly

Bench: N.KUMAR,B.SREENIVASE GOWDA

68. What follows is, if the provisions contained in Section 90 is more beneficial to the assessee as compared to the - 85 - terms in the agreement by India with the Government of any country outside India then, notwithstanding such agreement, the provisions of the Act to the extent they are beneficial to that assesseee apply. The benefit claimed

SRI CHANDRAKAR K KAMATH vs. THE DEPUTY COMMISSIONER OF

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S NEW MEDIA COMPANY vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S HOTEL FISHLAND vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S PRODIGY TECHNOVATIONS PVT LTD vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S. K K BROTHERS vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S TEACHERS CO OPERATIVE BANK vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S. LAKSHMINIRMAN BANGALORE PVT.LTD vs. THE DEPUTY COMMISSIONER OF INCOME-TAX

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

MINTENT SERVICED APARTMENTS PVT LTD., vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S PRAKASH BUS CORPORATION PVT LTD vs. THE DEPUTY COMMISSIONER OF

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

ECOLE SOLUTIONS PVT LTD vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S MAHRISHI MELTCHEMS PRIVATE LIMITED vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

M/S NEW MEDIA COMPANY vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

SRI. FATHERAJ SINGHVI vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

SREE C B EDUCATIONAL AND CULTURAL TRUST vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered

DR V. NARAYANASWAMY vs. UNION OF INDIA

Bench: The Hon’Ble Mr.Justice Aravind Kumar

68 Chavan, T.Suryanarayana, Smt.Lakshmy Iyengar, Ashok A. Kulkarni, Balram R. Rao, Smt.Vani H., Shankar A., learned advocates appearing for petitioners and Sri.K.V.Aravind, learned Senior standing counsel along with Sri.Jeevan J. Neeralagi appearing for respondents. 3. The learned advocates appearing for the petitioners have contended as under: (a) Levy or impost is regarded as a written or consideration for services rendered