SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

37 of the compilation). 4.5 It is also imperative here to look for the intention of the statute. The memo of Finance Bill, 2015 which most recently amended the sub section (1) of section 200A only intends to amend the manner in which the Late Fees is to be processed while processing the statement of TDS

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

37 of the compilation). 4.5 It is also imperative here to look for the intention of the statute. The memo of Finance Bill, 2015 which most recently amended the sub section (1) of section 200A only intends to amend the manner in which the Late Fees is to be processed while processing the statement of TDS

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

37 of the compilation). 4.5 It is also imperative here to look for the intention of the statute. The memo of Finance Bill, 2015 which most recently amended the sub section (1) of section 200A only intends to amend the manner in which the Late Fees is to be processed while processing the statement of TDS

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

37 of the compilation). 4.5 It is also imperative here to look for the intention of the statute. The memo of Finance Bill, 2015 which most recently amended the sub section (1) of section 200A only intends to amend the manner in which the Late Fees is to be processed while processing the statement of TDS

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

37 of the compilation). 4.5 It is also imperative here to look for the intention of the statute. The memo of Finance Bill, 2015 which most recently amended the sub section (1) of section 200A only intends to amend the manner in which the Late Fees is to be processed while processing the statement of TDS

CHATE TUTORIALS PVT LTD,AURANGABAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK, NASHIK

In the result, both the bunch of appeals filed by the respective assessee’s in ITA Nos

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.476 To 480/Pun/2024 Chate Tutorials Pvt. Ltd., Vs. Acit,Tds Circle, Chate House, Plot No.4, Nashik Near N-2 Cricket Stadium, Cidco, Aurangabad – 431 003 Maharashtra Tan : Nskco1565E Appellant Respondent

37 of the compilation). 4.5 It is also imperative here to look for the intention of the statute. The memo of Finance Bill, 2015 which most recently amended the sub section (1) of section 200A only intends to amend the manner in which the Late Fees is to be processed while processing the statement of TDS

SHRI BHASKARACHARYA PRATISHTHAN,CHH. SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

CHATE TUTORIALS PVT. LTD. AURANGABAD , AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

CHATE TUTORIALS PVT. LTD. ,AURANGABAD vs. LD. ASSISTANT COMMISSIONER OF INCOME TAX, TDS CIRCLE, NASHIK , NASHIK

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

SHRI BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS, CPC TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, CPC-TDS

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

SHREE BHASKARACHARYA PRATISHTHAN,CHH SAMBHAJINAGAR vs. LD. DEPUTY COMMISSIONER OF INCOME TAX, GHAZIABAD

In the result, both the bunch of appeals filed by the\nrespective assessee's in ITA Nos

37 of\nthe compilation).\n4.5 It is also imperative here to look for the intention of the statute.\nThe memo of Finance Bill, 2015 which most recently amended the sub\nsection (1) of section 200A only intends to amend the manner in which\nthe Late Fees is to be processed while processing the statement of TDS

M/S. TATA TECHNOLOGIES LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, appeal of assessee is partly allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita No.1433/Pun/2014 यििाारण वषा / Assessment Year : 2007-08 M/S. Tata Technologies Limited, Plot No.25, Rajiv Gandhi Infotech Park, अऩीऱाथी/Appellant Hingewadi, Pune – 411057 …. Pan: Aaact3092N Vs. The Dy. Director Of Income Tax …. प्रत्यथी / Respondent (International Taxation)-Ii, Pune

37,009 Software license USA Corporation Proforma Corporation 40,329 Software license USA Spicer Corporation 42,437 Software license USA Tata Technologies Pte 14,17,522 Software license Singapore Ltd Total 56,43,917 14. The first issue which is raised in the present appeal is the taxability of software under the provisions of Income Tax Act i.e. section

DEPUTY COMMISSIONER OF INCOME-TAX CIRCLE -5, PUNE vs. SERUM INSTITUTE OF INDIA PVT LTD.,, PUNE

In the result, the appeal filed by the Revenue stands dismissed

37(1).” We also find that the AO for assessment years 2011-12 and 2012-13 pursuant to the remand made by the ITAT accepted vide order dated 26.12.2019 passed u/s 143(3) r.w.s. 254 had accepted the position that the purpose of foreign visits of the employees is only for the purpose of to take decision whether the machinery

JOHN DEERE EQIPMENT P. LTD.,,PUNE vs. DEPUTY DIRECTOR OF INCOME-TAX,,

In the result, all the appeals of assessee are allowed

Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09

section 9(1)(vi) Explanation 2(iii) and 2(iva) of the Act and pointed out that the Hon’ble High Court of Madras in Verizone Communications Singapore Pte Ltd. Vs. DDIT (supra) had discussed the issue of equipment royalty, whereas in M/s. T-3 Energy Services India Pvt. Ltd. Vs. JCIT (supra), on which the learned Authorized Representative