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1 - 9 of 9 (0.36 seconds)Section 10A in The Income Tax Act, 1961 [Entire Act]
Section 43B in The Income Tax Act, 1961 [Entire Act]
Section 6 in The Income Tax Act, 1961 [Entire Act]
Ranbaxy Laboratories Ltd. vs Addl. Commissioner Of Income Tax, Range ... on 22 January, 2008
(3) ITAT Hyderabad Tribunal in the case of Mylan
Laboratories Ltd., vs. Addl. CIT [ (2014) 46
taxmann.com 76 (Hyderabad-Trib.) ].
Indo Rama Synthetics (I) Ltd vs C.I.T,New Delhi on 5 January, 2011
17. Upon consideration of the rival contentions
and the material on record, we find that the loyalty
rewards do not fall in the same category as bonus and
commission as envisaged under section 36(1)(ii) of the
Act. Therefore, respectfully following the judgment of the
Hon'ble Delhi High Court in the case of Sri Ram Ltd.. vs.
CIT (supra), we direct the A.O. the allow this expenditure.
Section 45 in The Income Tax Act, 1961 [Entire Act]
The Assistant Commissioner Of Income ... vs M/S. Tata Elxsi Ltd. on 9 July, 2015
18. Coming to Ground No.8 of the Revenue's
appeal which is against the direction of the DRP to reduce
the telecommunication charges from both the export
turnover as well as total turnover for the purpose of
computation of deduction under section 10A of the I.T.
Act, we find that this issue is covered in favour of the
assessee by the decision of the Hon'ble Karnataka High
Court in the case of CIT & another vs. Tata Elxsi (2012)
349 ITR 98 (Karnataka) (HC). We find that the DRP has
followed the decision of the Coordinate Bench of this
Tribunal wherein similar decision has been taken.
Therefore, we do not see any reason to interfere with the
final assessment order on this issue passed in accordance
with the directions of the DRP. Accordingly, Ground No.8
of the Revenue is rejected.
Shri Ram Piston And Rings Ltd. vs Cit on 17 July, 2007
15. As regards Ground No.5 regarding loyalty
rewards, brief facts are that the company had made a
provision of Rs.86,25,630 for loyalty rewards payable to
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its employees. The A.O. proceeded to disallow the same
under section 43B of the I.T. Act to an extent of
Rs.3,00,538 after considering that Rs.83,25,920 was
actually paid on or before the due date of filing the return.
It was submitted by the Ld. Counsel for the assessee that
section 43B read with section 36(1)(ii) refers to any sum
paid to an employee as statutory bonus or commission,
whereas, loyalty rewards paid by the assessee is to reward
his employee who completes certain period of work with
the company and therefore, it cannot be equated to bonus
or commission referred to in section 36(1)(ii) and
therefore, the disallowance of Rs.3,00,538 is to be deleted.
Assessee placed reliance upon the judgments of the
Hon'ble Delhi High court in the case of Shri Ram Pistons
& Rings Ltd., vs. CIT 307 ITR 363 (Del.)
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