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TMI Blog2015 (10) TMI 1892X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s.Cognizant Technology Solutions India Pvt. Ltd. Vs. ACIT [2013 (1) TMI 767 - ITAT CHENNAI ] hereby direct the Ld. Assessing Officer to include the interest from EEFC deposit and the other deposit in the bank account as part of the profits eligible for deduction u/s.10B of the Act because the nature of income earned on both the deposits are similar and the nature of deductions in Section 10A & 10B of the Act is also similar though available to assessee’s engaged in different field. Decided in favour of the assessee. - ITA No. 2868/Mds./2014 - - - Dated:- 26-8-2015 - A. Mohan Alankamony, AM, J. For the Appellant : Mr K M Mohandass, CA For the Respondent : Dr B Nischal, JCIT, DR ORDER Per A. Mohan Alankamony , Account ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld the order of the Ld. Assessing Officer by holding that the interest from EEFC deposits and Bank deposits is not eligible for deduction u/s.10B of the Act, as the interest is not derived from the export of things/articles. 4. At the outset, Ld. A.R. relied in the decision of this Tribunal in the case M/s. Cognizant Technology Solutions India Pvt. Ltd. Vs. ACIT in ITA Nos.114 2100/Mds./2011 for the assessment years 2005-06 2007-08 vide order dated 23rd January, 2013 wherein the Tribunal decided the issue in favour of the assessee. On the other hand, Ld.D.R placed reliance in the orders of the Revenue and also relied in the case of Penta Media Graphica Ltd., Vs. ACIT reported in [2013] 35 Taxmann.com (Madras) . 5. I have heard bot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer, 9 SOT 665 (Del); in the case of CIT vs. Syntel Ltd. in ITA Nos.1974, 1976 1978 of 2009; in the case of Rajesh Exports Ltd. vs. ACIT in ITA No.51 of 2008, etc. Accordingly, we direct the Assessing Officer to include the gain from EEFC account as part of the profits eligible for deduction under section 1OA of the Act. This issue is decided in favour of the assessee. -9-. ITA 114, 90 2100/2011 therefore it is also in the nature of export profits. This issue has been decided by the Hon ble Delhi High Court in favour of the assessee in the case of CIT vs. Indian Toners and Developers Ltd., 326 ITR 435. This issue is decided in favour of the assessee by a series of Tribunal orders in the case of M/s. Rishabh International vs. JCIT, Mumbai ..... X X X X Extracts X X X X X X X X Extracts X X X X
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