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    <title>2020 (10) TMI 450 - ITAT BANGALORE</title>
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    <description>The Tribunal held that the assessee could not be treated as an assessee in default for payments made for software purchases before 15.10.2011, the date of the Karnataka High Court&#039;s decision in Samsung Electronics Co. Ltd. Consequently, demands raised under Section 201(1) and interest charged under Section 201(1A) for assessment years 2009-10 to 2011-12 were not sustainable. For the assessment year 2012-13, demands related to payments made before 15.10.2011 were also deleted. Appeals for assessment years 2009-10 to 2011-12 were allowed, and demands were deleted. Appeals for the assessment year 2012-13 were partly allowed, with demands for payments made before 15.10.2011 being deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=399476</link>
      <description>The Tribunal held that the assessee could not be treated as an assessee in default for payments made for software purchases before 15.10.2011, the date of the Karnataka High Court&#039;s decision in Samsung Electronics Co. Ltd. Consequently, demands raised under Section 201(1) and interest charged under Section 201(1A) for assessment years 2009-10 to 2011-12 were not sustainable. For the assessment year 2012-13, demands related to payments made before 15.10.2011 were also deleted. Appeals for assessment years 2009-10 to 2011-12 were allowed, and demands were deleted. Appeals for the assessment year 2012-13 were partly allowed, with demands for payments made before 15.10.2011 being deleted.</description>
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