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Documents citing Sonata Information Technology Ltd. vs Additional Commissioner Of ... on 31 January, 2006

Infotech Enterprises Limited, ... vs Assessee on 29 October, 2013

"We have considered the order of the AO and the submissions made by the taxpayer. The issue involved in the present case is identical to the issue in the case of Sonata Information Technology Ltd. vs. AddI.CIT. In this case, the AO found that the assessee was a distributor of software for a foreign company. The AO found that the assessee was liable to deduct tax u/s. 195 of I.T. Act and 10 ITA.No.115 & 2184/Hyd/2011 Infotech Enterprises Limited, Hyd.
Income Tax Appellate Tribunal - Hyderabad Cites 37 - Cited by 0 - Full Document

Avesthagen Ltd.,, Bangalore vs Ito, Bangalore on 3 August, 2018

In the case of Sonata Information Technology Ltd. vs. Ad. CIT, 106 TTJ 797,, the tribunal followed the earlier tribunal orders rendered in the case of Samsung Electronics Co. Ltd. vs. ITO (Supra) and in the case of Sonata Software Ltd. vs. ITO 9Supra). We have already seen that both these tribunal orders are not applicable in the facts of the present case and hence, for the same reasons, this tribunal order is also not applicable in the present case.
Income Tax Appellate Tribunal - Bangalore Cites 20 - Cited by 0 - Full Document

Deputy Commissioner Of Income Tax,, ... vs M/S Infosys Bpo Ltd, Bangalore on 27 September, 2019

18.2.2005  Sonata Software Ltd v ITO [2006] 6 SOT 700 (Bang) dt. 28.4.2005  Mphasis BFL Ltd v ITO [2006] 9 SOT 756 (Bang) dt. 20.1.2006  Sonata Information Technology Ltd v Ad. CIT [2006] 103 17'D 324 (Bang) dt.31.1.2006 ITA Nos.1333 & 1367(B)/2014 19Hewlett Packard (India) (P) Ltd v ITO [2006] 5 SOT 660 (Bang) dt. 31.12.2006 It is submitted that these decisions were in force during year under consideration and that decision of Hon'ble Karnataka High Court in Samsung was not there during FY 2006-07 relevant to AY 2007-08. Ld.AR thus argued that, when software expenses were incurred/paid during the FY 2006-07 relevant to AY 2007-08, by virtue of existing favourable decisions by coordinate bench of this Tribunal, there was no liability on assessee to deduct TDS on software payments.
Income Tax Appellate Tribunal - Bangalore Cites 45 - Cited by 0 - Full Document

M/S Pmc Sierra India Pvt. Ltd.,, vs Department Of Income Tax on 26 August, 2016

14.2 Before us, the learned Authorised Representative contended that this company ought to be excluded from the list of comparables on the ground that it is functionally different to the assessee. It is submitted by the learned Authorised Representative that this company is engaged in 'e-Business Consulting Services', consisting of Web Strategy Services, I T design services and in Technology Consulting Services including product development consulting services. These services, the learned Authorised Representative contends, are high end ITES normally categorised as knowledge process Outsourcing ('KPO') services. It is further submitted that this company has not provided segmental data in its Annual Report. The learned Authorised Representative submits that since the Annual Report of the company does not contain detailed descriptive information on the business of the company, the assessee places reliance on the details available on the company's website which should be considered while evaluating the company's functional profile. It is also submitted by the learned Authorised Representative that KPO services are not comparable to software development services and therefore companies rendering KPO services ought not to be considered as comparable to software development companies and relied on the decision of the co- ordinate bench in the case of Capital IQ Information Systems (India) (P.) Ltd . v. Dy. CIT (International Taxation) [2013] 32 taxmann.com 21 (Hyd. - Trib.) and prayed that in view of the above reasons, this company i.e. e- Zest software Ltd., ought to be omitted from the list of comparables.
Income Tax Appellate Tribunal - Bangalore Cites 12 - Cited by 0 - Full Document
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