COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 10A/ 10AA of the Act is infructuous and accordingly, dismissed. 23. Accordingly, the Grounds of appeal are partly allowed for A.Y. 2010-11 to A.Y.2012-13 and on the very same reasoning, similar grounds raised by the Assessee in other appeals as noted in the chart supra stands partly allowed. - 34 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1),, CHENNAI

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita Nos.1193, 1194, 1205, 1206 & 1207/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs Cognizant Technology Solutions The Asst. Commissioner India Pvt. Ltd., Of Income Tax, No.5/535, Okkiam Thoraipakkam, Central Circle 1(1), Old Mahabalipuram Road, Chennai. Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent) & आयकर अपील सं./Ita Nos.1262, 1263, 1264, 1265 & 1266/Chny/2024 ("नधा"रण वष" / Assessment Years: 2010-11, 2011-12, 2012-13, 2013-14 & 2014-15) Vs The Asst. Commissioner Of Cognizant Technology Income Tax, Solutions India Pvt. Ltd., Central Circle 1(1), No.5/535, Okkiam Chennai. Thoraipakkam, Old Mahabalipuram Road, Chennai – 600 096. Pan : Aaacd 3312M (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 10A/ 10AA of the Act is infructuous and accordingly, dismissed. 23. Accordingly, the Grounds of appeal are partly allowed for A.Y. 2010-11 to A.Y.2012-13 and on the very same reasoning, similar grounds raised by the Assessee in other appeals as noted in the chart supra stands partly allowed. - 34 - ITA Nos.1193, 1194, 1205 to 1207, 1262 to 1266/CHNY/2024

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED,CHENNAI vs. THE ASSISTANT COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE 1(1), CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter

ASSISTANT COMMISSIONER OF INCOME TAX, CHENNAI vs. COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LIMITED, CHENNAI

gains. At that stage\nthe aggregate of the incomes under other heads and the\nprovisions for set off and carry forward contained in Sections 70,\n72 and 74 of the Act would be premature for application. The\ndeductions under Section 10A therefore would be prior to the\ncommencement of the exercise to be undertaken under Chapter