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C. HARI SHANKAR
Coforge Limited (formerly Known As Niit Technologies Limited) – Appellant
Versus
Malika Malhotra – Respondent
| Table of Content |
|---|
| 1. appeals directed against a common order. (Para 1 , 2) |
| 2. taxable income and deductions claimed under section 10b. (Para 3 , 4 , 5) |
| 3. arguments advanced by the appellant regarding disallowance. (Para 6) |
| 4. counterarguments presented by the revenue. (Para 7) |
| 5. court's analysis on legal and financial reasoning. (Para 8 , 9 , 10 , 11) |
| 6. determination of deductions related to expenditures. (Para 12 , 13 , 14) |
| 7. court's decision on the appeals. (Para 15) |
| 8. final order with no costs. (Para 16) |
JUDGMENT
Rajiv Shakdher, J. - Table of Contents
Background facts:
ITA 213/2020
ITA 214/2020
ITA 215/2020
Submissions on behalf of the appellant/assessee:
Submissions advanced on behalf of the revenue:
Analysis and reasons:
Deduction claimed under Section 35DD:
Disallowance under Section 14A of the Act:
Commuted/discounted one-time lease rent:
Conclusion:
Preface: -
1. The above-captioned appeals are directed against a common order dated 28.01.2020, passed by the Income Tax Appellate Tribunal [in short "Tribunal"] Pertinently, ITA 213/2020 and ITA 215/2020 concern assessment year [AY] 2007-2008 while ITA 214/2020 concerns AY 2008-2009.
1.1. On 13.01.2021, all three appeals were admitted and
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