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Civil Appeal Nos. 8489-8490 of 2013

3) Brief facts:

(a) The Respondent – HCL Technologies Ltd. is a company registered under the Companies Act, 1956 and engaged in the business of development and export of computer softwares and rendering technical services.

(b) The Respondent has shown gross income from business at Rs. 267,01,76,529/- while claiming deductions under Section 10A of the IT Act to the tune of Rs. 273,45,39,379/- showing a net loss of Rs. 6,43,62,850/-. The Respondent filed its return of income for the Assessment Year 2004-05 on 01.11.2004 declaring the undisclosed income at Rs. 91,25,68,114/-. Thereafter, on 31.03.2005, a revised return of income for Rs. 91,16,99,060/- was filed by the Respondent which was selected for scrutiny under Section 143 of the Income Tax Act, 1961 (in short ‘the IT Act’).