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Income Tax : Infosys Technologies Ltd. Tuesday said it will appeal against an order from the income tax department seeking more than 4 billion ...
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Corporate Law : NCLAT Delhi rules on the admissibility of a Section 7 application by State Bank of India against Advantage Overseas Pvt. Ltd., all...
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Income Tax : As per section 10A(4) of Income Tax Act, 1961, profits derived from export of articles or things or computer software shall be amo...
Income Tax : Circular No. 14/2014-Income Tax CBDT had issued Circular No.12/2014 dated 18th July, 2014 to clarify that mere transfer or re-dep...
Income Tax : Circular No. 12/2014-Income Tax Section 10AA of the Income-tax Act, 1961, inter-alia, provides for deduction in respect of the pr...
Income Tax : A clarificatory Circular No. 01/2013 dated 17.01.2013 was issued by CBDT to address various contentious issues leading to tax disp...
Income Tax : A clarificatory Circular No. 01/2013, dated 17-1-2013 (hereinafter referred to as 'Circular') was issued by CBDT to address variou...
Since export turnover has been defined by Parliament and there is a specific exclusion of freight and insurance, the expression “export turnover” cannot have a different meaning when it forms a constituent part of the total turnover for the purposes of the application of the formula prescribed by section 10A(4).
The above ruling provides that tax holiday under section 10A would be available to a foreign office, i.e. a branch carrying on-site software development only if it is a liaison office. An independent branch carrying out full -fledged marketing operat
Infosys Technologies Ltd. Tuesday said it will appeal against an order from the income tax department seeking more than 4 billion rupees ($88.8 million) in taxes for software sales made at the overseas premises of its international clients. The Econo
The Delhi bench of Income-tax Appellate Tribunal (the Tribunal) in the case of DDIT v. Virage Logic International (ITA No. 494(Del) 2010) held that transfer of a computer software by an Indian branch of a foreign company [approved as 100 percent Export Oriented Unit (EOU) by Software Technology Parks of India (STPI)] to its head office is a transaction eligible for claiming tax benefits under section 1 0A of the Income-tax Act, 1961 (the Act).
Manufacturing of a new product with a new technology at the same place after taking a fresh approval from SEZ authority does not amount to ‘splitting up or reconstruction’ of an existing business for the purpose of section 10A of the Act.
In respect of AY 2003-04, the assessee had an unit in Chennai which was engaged in software development and whose profits were eligible for deduction u/s 10A. The assessee had another unit in Delhi which was engaged in trading and had suffered a loss. The assessee claimed that it was eligible for a deduction u/s 10A
The short question that arises for consideration is whether blending and packing of tea for export in the industrial unit in the Special Economic Zone amount to manufacture or production of an article qualifying for exemption under Section 10A of the Act, that is, during the period prior to introduction of “blending” as “manufacture” with effect from 10.2.2006.
The agitation by the revenue is that the assessee company was not entitled to deduction under section 10A as the CIT (A) failed to appreciate the fact that the assessee had commenced manufacture, production of software prior to its registration as STPI and the STPI authorities had granted approval
14. It is relevant to state the provision of section 10A(4) as applicable to the assessment year, in which the assessee began production with effect from 01.02.1993 and became entitled to get deduction. The relevant section 10A(4) reads as under :- “Notwithstanding anything contained in any other provision of this Act, in computing the total income of the assessee
7.1 As per the provision of section 10A of the Act, assessee is entitled to claim the deduction in respect of the profits and gains as derived by the assessee’s undertaking from the export of the articles of the things for the period of the 10 consecutive A.Y’s. Sub-section (2) to sec. 10A has laid down certain conditions for the eligibility of the undertaking to claim the deduction
