Court :
ITAT Bangalore
Brief :
These cross appeals are directed against the order dated 04- 01-2018 passed by Ld CIT(A)-3, Bengaluru and they relate to the assessment year 2011-12.
Citation :
ITA No.491/Bang/2018
IN THE INCOME TAX APPELLATE TRIBUNAL
“C’’BENCH: BANGALORE
BEFORE SHRI GEORGE GEORGE K., JUDICIAL
MEMBERAND
SHRI B.R. BASKARAN, ACCOUNTANT MEMBER
ITA No.491/Bang/2018
AssessmentYear:2011-12
Infosys BPM Ltd.
Electronic City
Hosur Road
Bengaluru
PAN NO :AACCP4478N
APPELLANT
Vs.
Deputy Commissioner of
Income-tax
Circle-3(1)(1)
Bangalore
RESPONDENT
IT(TP)A No.1156/Bang/2018
Assessment Year: 2011-12
Deputy Commissioner of Incometax
Circle-3(1)(1)
Bangalore
APPELLANT
Vs.
Infosys BPM Ltd.
Electronic City
Hosur Road
Bengaluru
RESPONDENT
Appellant by : Shri Padamchand Khincha, A.R.
Respondent by : Shri Mathivanam M. D.R.
Date of Hearing : 10.12.2020
Date of Pronouncement : 11.12.2020
O R D E R
PERB.R. BASKARAN, ACCOUNTANT MEMBER:
These cross appeals are directed against the order dated 04- 01-2018 passed by Ld CIT(A)-3, Bengaluru and they relate to the assessment year 2011-12.
2. The assessee is in appeal before us on the following issues:-
(a) Disallowance of Provision for Software expenses –Rs.3,89,30,461/-
(b) Disallowance of Software expenses u/s 40(a)(i) of the Act –Rs.1,35,82,093/-
(c) Disallowance of software expenses treating the same as capital in nature – Rs.13,80,31,912/-
(d) Incorrect allowance of TDS credit.
3. The revenue is in appeal before us on the following issues:-
(a) Deduction allowed u/s 10A of the Act
(b) Whether Ld CIT(A) has power to remit the issue of disallowance of software expenses treating it as Capital expenditure to the file of AO?
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