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Case Law Details

Case Name : Cognizant Technology Solutions India Pvt. Ltd. Vs ACIT (ITAT Chennai)
Appeal Number : ITA No. 363/Chny/2023
Date of Judgement/Order : 26/07/2023
Related Assessment Year : 2018-19
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Cognizant Technology Solutions India Pvt. Ltd. Vs ACIT (ITAT Chennai)

The case of Cognizant Technology Solutions India Pvt. Ltd. vs ACIT involves an appeal against the assessment order for Assessment Year (AY) 2018-19. The appellant, Cognizant Technology Solutions India Pvt. Ltd., challenged the short grant of deduction under Section 10AA of the Income Tax Act and the short grant of advance tax and Tax Deducted at Source (TDS) belonging to amalgamated entities.

1. Grounds of Appeal: The appellant appealed against the assessment order, highlighting two main issues: the short grant of deduction under Section 10AA and the short grant of advance tax and TDS credits related to entities that were amalgamated.

2. Short Grant of Deduction u/s 10AA: The appellant claimed a deduction under Section 10AA, which was fully allowed under Section 143(1) of the Income Tax Act. However, during the scrutiny assessment, an arithmetical/system error occurred, leading to a shortfall in the allowed deduction. The ITAT Chennai directed the Assessing Officer (AO) to recompute and allow the full deduction under Section 10AA.

3. Short Grant of Advance Tax and TDS: Entities that were amalgamated with the appellant offered their income for taxation, and the appellant included the corresponding receipts in its total income. The appellant sought credit for advance tax and TDS payments made by these amalgamated entities. The Ld. CIT(A) directed the AO to verify the claims and allow the credit as per law.

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