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Documents citing M/S Wipro Limited , Bnagalore vs Joint Commissioner Of Income Tax ... on 5 October, 2020

M/S Infosys Limited , Bangalore vs Assistant Commissioner Of Income Tax ... on 31 January, 2023

125. We heard the parties. We notice that the Hon'ble ITAT in Assessee's own case for AY 2005-06 [IT(TP)A No. 102/B/13 dated 10.11.2017] and AY 2006-07 [IT(TP)A No. 799/B/15 dated ITA Nos.125, 126, 226 & 227/Bang/2019 Page 97 of 129 10.11.2017] admitted the additional grounds of appeal pertaining to claim of relief under section 90, 91 and directed the AO to consider the said claim in the light of the decision of the Karnataka High Court in the case of Wipro Limited v DCIT decision dated 25.3.2015 [2016] 382 ITR 179 after verification of necessary details and documents. Accordingly we remit the issue back to the AO with a direction to keep in mind the above decision of the coordinate Assessee's own case for AY 2005-06 and AY 2006-07 while considering the issue from allowability u/s.90/91 perspective. The AO is further directed to keep in mind the directions given in the earlier part of this order (Ground 12 in assessee's appeal) with regard to the allowability u/s.37 of the foreign tax credit and the additional foreign tax claimed by assessee in respect of state taxes paid. Needless to say that the assessee be given a reasonable opportunity of being heard. It is ordered accordingly.
Income Tax Appellate Tribunal - Bangalore Cites 141 - Cited by 1 - Full Document

M/S Wipro Limited vs The Additional Commissioner Of ... on 9 December, 2020

9. Learned counsel for the revenue submits that all the remaining issues covered by decisions of this court in M/S WIPRO LTD. VS. DCIT, 383 ITR 179 (KAR) and 'COMMISSIONER OF INCOME-TAX & ANOTHER VS. TATA ELXSI LTD.' 382 ITR 654 (KAR) are pending adjudication at the instance of the revenue before the Supreme Court. In view of aforesaid submission needless to state that the Assessing Officer shall decide the issues in accordance with the decision which may be rendered by the Supreme Court.
Karnataka High Court Cites 17 - Cited by 0 - Full Document

Pr Commissioner Of vs M/S Wipro Limited on 9 December, 2020

14. At this stage, learned counsel for the revenue submits that all the remaining issues covered by decisions of this court in M/S WIPRO LTD. VS. DCIT, 383 ITR 179 (KAR) and 'COMMISSIONER OF INCOME-TAX & ANOTHER VS. TATA ELXSI LTD.' 382 ITR 654 (KAR) are pending adjudication at the instance of the revenue before the Supreme Court. In view of aforesaid submission needless to state that the Assessing Officer shall decide the issues in accordance with the decision which may be rendered by the Supreme Court.
Karnataka High Court Cites 32 - Cited by 0 - Full Document

Deputy Commissioner Of Income Tax ... vs M/S Infosys Limited , Bangalore on 9 January, 2023

23.1. It is submitted that Foreign tax credit was claimed in the revised return of income amounted to Rs. 336,90,86,298.. During the assessment, vide letter dated 29.2.2016 filed with the Ld.AO on 4.3.2016, the assessee requested the Ld.AO to allow foreign tax credit of Rs.6,80,43,71,180/- as against the claim of Rs.3,36,90,86,298/- as made in the revised return of income. The increase in the claim was, in view of the decision of the Hon'ble Karnataka High Court in the case of Wipro Ltd v DCIT reported in 382 ITR 179, which held that Foreign tax credit relating to income eligible for deduction under section 10A is also allowable under section 90. It is submitted that, along with the said letter, the assessee filed the copy of the aforesaid decision and the evidences for payment of tax in foreign countries.
Income Tax Appellate Tribunal - Bangalore Cites 83 - Cited by 0 - Full Document

Canon India Pvt. Ltd., Gurgaon vs Acit, National Faceless Assesment ... on 20 October, 2021

49. Subsequently, the Hon'ble High Court of Karnataka in the case of Wipro Ltd [supra] clarified the law in relation to the claim of foreign tax credit. The Hon'ble High Court, while interpreting the provisions of section 90(1)(a)(ii) of the Act, providing for relief from double taxation where income of the assessee is chargeable under the Act as well as in the corresponding law in force in foreign country has held that income u/s 10A of the Act is chargeable to tax u/s 4 of the Act and is includible in the total income u/s 5 of the Act, but no tax is charged on such income because of exemptions given u/s 10A of the Act only for a period of 10 years.
Income Tax Appellate Tribunal - Delhi Cites 25 - Cited by 0 - Full Document
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