Disallowing:
(i) Rs.18,07,31,409/- u/s 80JJAA
(ii) Interest of Rs.2,99,06,766/- on a loan and
(iii) rent ... case the software engineers in
respect of whom deduction under s. 80JJAA has been
claimed have not been employed in a supervisory capacity
even though
holding that the assessee
company is eligible for deduction u/s 80JJAA in respect of
additional wages paid to software engineers employed
without appreciating ... mentioned by the learned AR, Finance Act,
2013 amended Sub- sec.80JJAA , the words "manufacture or production of an
article nr thing
that AO ( CPC ) has erred in disallowing the deduction u/s 80JJAA
amounting to Rs. 762810/- u/s 143(1)(a) and simultaneously ... Assessee claimed
deduction amounting to Rs 7,62,815/- u/s 80JJAA of the I.T Act,
1961. He complied with and eligible
action of the revenue
authorities in not allowing deduction u/s.80JJAA of the Act amounting to
Rs.7,57,22,069/-. The provisions ... 80JJAA of the Act, as applicable
for AY 2008-09 reads as follows:
IT(TP)A No.169 & 149/Bang/2014
Page
justified in holding that the assessee is entitled for
deduction u/s 80JJAA of the Act in the facts and circumstances of the
case ... claimed a deduction of Rs 4,75,71,586/- u/s 80JJAA of the Act in the
return of income filed in ITR-6 , however
violation of principle of equity and
natural justice.
2. Deduction under section 80JJAA of the Income-tax Act, 1961
2.1 The Honourable Dispute Resolution Panel ... have erred in denying the deduction under section 80JJAA of the
Income-tax Act, 1961 ("the Act"). They have erred in disregarding
appeal relates to the. claim of the assessee under Section 80JJAA of the IT Act which was disallowed by the AO in the assessment proceedings ... claimed a deduction of Rs. 2,55,81,220 under Section 80JJAA for the asst
10AA in respect of onsite 7 8
activities
Deduction u/s. 80JJAA 8 9
Disallowance of payments made to overseas
subsidiaries
viz., Infosys China, Infosys
section 43B(f) of the Act
vii) Disallowance of deduction u/s. 80JJAA of the Act
viii) Disallowance of interest paid under the Micro, Small
Ground 5 pertaining to non-granting of deduction u/s 80JJAA in respect of workmen
employed by the appellant working for less than 300 days ... That the DCIT erred in not granting the deduction u/s 80JJAA in respect of the workmen
who were employed by the appellant during
