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1 - 10 of 18 (0.59 seconds)Section 10A in The Income Tax Act, 1961 [Entire Act]
Section 80JJAA in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 92CA in The Income Tax Act, 1961 [Entire Act]
Ananda Bazar Patrika (P) Ltd vs Its Workmen on 7 May, 1963
• The Supreme Court in the case of Ananda Bazar Patrika Pvt Ltd
v Its Workmen (1969) [2 LLJ 670-71] also laid out the
following similar principle (extract of the case law enclosed at
page 553- 554 of the Paperbook II):
Arkal Govind Raj Rao vs Ciba Geigy Of India Ltd., Bombay on 6 May, 1985
• Arkal Govind Raj Rao v Ciba Geigy of India Ltd, Bombay
(1985) Supreme Court [2 LU 401])
• All India Reserve Bank Employees' Assn v Reserve Bank of
India (1965) Supreme Court [2 LU 175, 188]
• We also wish to highlight the judgement of the Hon'ble
Bangalore Tribunal in the case of Texas Instruments (India) Pvt
Ltd (115 TTJ 976), which is engaged in the development of
computer software. The Hon'ble Tribunal held that the
employees of the company were workmen' for the purposes of
IT(TP)A.1344/Bang/2011 Page - 39
section 8OJJAA and the company which was engaged in the
development of computer software was eligible for deduction
under section 80JJA (copy of the case law is enclosed at page
540-548 of the Paperbook II).
All India Reserve Bank Employees ... vs Reserve Bank Of India on 23 April, 1965
• Arkal Govind Raj Rao v Ciba Geigy of India Ltd, Bombay
(1985) Supreme Court [2 LU 401])
• All India Reserve Bank Employees' Assn v Reserve Bank of
India (1965) Supreme Court [2 LU 175, 188]
• We also wish to highlight the judgement of the Hon'ble
Bangalore Tribunal in the case of Texas Instruments (India) Pvt
Ltd (115 TTJ 976), which is engaged in the development of
computer software. The Hon'ble Tribunal held that the
employees of the company were workmen' for the purposes of
IT(TP)A.1344/Bang/2011 Page - 39
section 8OJJAA and the company which was engaged in the
development of computer software was eligible for deduction
under section 80JJA (copy of the case law is enclosed at page
540-548 of the Paperbook II).
Bajaj Tempo Ltd. Bombay vs Commissioner Of Income Tax,Bombay ... on 24 April, 1992
• It would be pertinent to note the objectives with which section
8OJJAA was introduced into the tax legislation. Section
80JJAA was introduced into the by the Finance (No 2) Act,
1998, to be operative from April 1, 1999. The Finance
Minister's speech as well as the memorandum explaining the
provisions of the Finance Bill refer to deduction being
introduced to encourage employers to generate more
employment opportunities (extract enclosed for your reference
at page 559-560 of the Paperbook II). The objective of
introducing section 8OJJAA is also explained by Circular No
772 dated December 23, 1998 (extract of the circular enclosed
for your reference on page 561 of the Paperbook II). By virtue
of introduction of this section, a fiscal incentive was intended
to be offered to employers giving employment to a specified
minimum number of employees. Hence, the interpretation of
the section should be in a manner which promotes the
objective sought to be achieved and not frustrate it.
• Further, the Appellant wishes to humbly submit that being a
beneficial provision, it must be liberally construed. These were
the principles brought out by the Supreme Court while dealing
with deduction under section 80J in the case of Bajaj Tempo
vs CIT (196 ITR 188). Hence, the section would need to be
interpreted in a purposive manner.
Aztec Software And Technology Service ... vs Acit on 12 July, 2007
1. M/s. Kodiak Networks (I) P. ITA.1413/Bang/2010
Ltd v. ACIT