JOHN DEERE INDIA PVT. 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

v) of Explanation 2 of section 9(1)(vi) of the Act. He, then referred to amendment made by Finance Act, 2012, which according to him, had clarified that right to use computer software, (including granting of license) was ‘royalty’. He referred to Explanation 4 under section 9(1)(vi) of the Act. He also referred to Memorandum

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

v) of Explanation 2 of section 9(1)(vi) of the Act. He, then referred to amendment made by Finance Act, 2012, which according to him, had clarified that right to use computer software, (including granting of license) was ‘royalty’. He referred to Explanation 4 under section 9(1)(vi) of the Act. He also referred to Memorandum

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

v) of Explanation 2 of section 9(1)(vi) of the Act. The Assessing Officer further referred to clarification issued by the Finance Act, 2012 which had vide Explanation 4 provided that the right to use computer software including granting of licence was royalty. The Assessing Officer referred to the Memorandum of Finance Bill, 2012 and held that in view

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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 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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v) Section 200A(2) provides that the Government can make a scheme to centrally process the TDS statements as provided in section 200A(1). Thus, the function of CPC is to process the TDS statements as provided u/s 200A(1) of the Act and while doing so, it is authorised to undertake all actions as mentioned in 200A(1

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without

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

v. The Assistant Commissioner (ST), Tirupur\n2020-TIOL-1858-HC-MAD\nd. Thus, such late fees, interest and additional interest for TDS\nquarterly statement cannot be determined by TDS-CPC by way of\nprocessing under section 200A(2). Therefore, demand notice\nbased on such justification report cannot be issued except for\ntax/refund, but if issued, then it is issued without