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297 results for “TDS”+ Carry Forward of Lossesclear

Sorted by relevance

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Key Topics

Addition to Income66Disallowance55Section 4051Section 153A43Section 143(3)41Deduction36Transfer Pricing34Section 10A30Section 6828TDS

M/S INFOSYS BPM LIMITED ,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-3 , BANGALORE

In the result, the appeal of the assessee is treated as partly allowed

ITA 2884/BANG/2018[2009-10]Status: DisposedITAT Bangalore22 Nov 2021AY 2009-10

Bench: Shri George George K. & Shri B.R. Baskaranassessment Year:2009-10

For Appellant: Shri Padamchand Khincha, A.RFor Respondent: Shri Sumer Singh, D.R
Section 10ASection 115JSection 143(3)Section 14ASection 40

carried out in a recognized stock exchange shall not be treated as a speculative transaction. Further, an 'eligible transaction' for this purpose would be one that fulfils the conditions laid down in Explanation to Section 43(5)(d). Any loss in a speculative transaction can be set off only against profit from speculative transactions. In the case on hand

Showing 1–20 of 297 · Page 1 of 15

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28
Section 1126
Section 36(1)(vii)24

SKF TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ACIT, BANGALORE

ITA 1481/BANG/2010[2006-07]Status: DisposedITAT Bangalore31 Mar 2016AY 2006-07

Bench: Shri. Abraham P. George

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. G. R. Reddy, CIT – DR -I
Section 144C(5)

carry forward loss and disallowance of group information technology (IT) expenditure twice, appearing in the appeals for A. Ys. 2007-08, the other grounds are common for both the years. 03. Common grounds are dealt with first. Vide its ground I assessee assails the TP adjustment of Rs.1,13,68,945/- for A. Y. 2006-07 and Rs.91

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

ITA 452/BANG/2019[2008-09]Status: DisposedITAT Bangalore21 Aug 2019AY 2008-09

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao
Section 10ASection 115JSection 143(1)Section 143(3)

carry forward losses, it is contended that the CIT(A) erred in not adjudicating the issue in appeal and in not following that the decision of the Hon’ble Apex Court in the case of CIT Vs. Yokogawa India Ltd., which is squarely applicable to the facts of the case on hand. 5.2.1 Before us, the learned

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

ITA 454/BANG/2019[2010-11]Status: DisposedITAT Bangalore21 Aug 2019AY 2010-11

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao
Section 10ASection 115JSection 143(1)Section 143(3)

carry forward losses, it is contended that the CIT(A) erred in not adjudicating the issue in appeal and in not following that the decision of the Hon’ble Apex Court in the case of CIT Vs. Yokogawa India Ltd., which is squarely applicable to the facts of the case on hand. 5.2.1 Before us, the learned

M/S MCML SYSTEMS PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(1)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2010-11 is allowed

ITA 453/BANG/2019[2009-10]Status: DisposedITAT Bangalore21 Aug 2019AY 2009-10

Bench: Shri N. V. Vasudevan & Shri Jason P Boaz

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Shri. C. H. Sundar Rao
Section 10ASection 115JSection 143(1)Section 143(3)

carry forward losses, it is contended that the CIT(A) erred in not adjudicating the issue in appeal and in not following that the decision of the Hon’ble Apex Court in the case of CIT Vs. Yokogawa India Ltd., which is squarely applicable to the facts of the case on hand. 5.2.1 Before us, the learned

BIOCON LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal filed by assessee for assessment year

ITA 557/BANG/2016[2011-12]Status: DisposedITAT Bangalore12 Nov 2021AY 2011-12

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 92C

carry out fresh benchmarking analysis from the Loan Connector database for companies having a BBB rating 7.3 The Honorable DRP has failed to appreciate that the yield on BBB rated bonds is not comparable to the Appellant's loan to its AE as such rating assigned by the Honorable DRP is without substantial basis. 7.4 The Honorable DRP has erred

JCIT, BANGALORE vs. M/S BIOCON LTD.,, BANGALORE

In the result appeal filed by assessee for assessment year

ITA 558/BANG/2016[2011-12]Status: DisposedITAT Bangalore12 Nov 2021AY 2011-12

Bench: Shri B.R. Baskaran & Smt Beena Pillai

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Muzaffar Hussain, CIT (DR)
Section 143(3)Section 144CSection 144C(5)Section 92C

carry out fresh benchmarking analysis from the Loan Connector database for companies having a BBB rating 7.3 The Honorable DRP has failed to appreciate that the yield on BBB rated bonds is not comparable to the Appellant's loan to its AE as such rating assigned by the Honorable DRP is without substantial basis. 7.4 The Honorable DRP has erred

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

ITA 1981/BANG/2018[2010-11]Status: DisposedITAT Bangalore12 Jan 2023AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R
Section 143(3)

forward contracts other than already determined in the contract. Accordingly, we direct the AO to re- compute the same in the light of above observation and decide afresh after giving opportunity of hearing to the assessee. 9. Ground No.2 raised only in ITA No.1980/Bang/2018 is with regard to holding that MTM loss being unascertained liability need to be added

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

In the result, the appeal filed by the revenue is dismissed

ITA 1980/BANG/2018[2009-10]Status: DisposedITAT Bangalore12 Jan 2023AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R
Section 143(3)

forward contracts other than already determined in the contract. Accordingly, we direct the AO to re- compute the same in the light of above observation and decide afresh after giving opportunity of hearing to the assessee. 9. Ground No.2 raised only in ITA No.1980/Bang/2018 is with regard to holding that MTM loss being unascertained liability need to be added

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

ITA 1982/BANG/2018[2012-13]Status: DisposedITAT Bangalore12 Jan 2023AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sreenivas T. Bidari, D.R
Section 143(3)

forward contracts other than already determined in the contract. Accordingly, we direct the AO to re- compute the same in the light of above observation and decide afresh after giving opportunity of hearing to the assessee. 9. Ground No.2 raised only in ITA No.1980/Bang/2018 is with regard to holding that MTM loss being unascertained liability need to be added

PRASANNA KUMAR,MANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-2(2), BANGALORE

In the result, the appeal filed by the assessee is allowed

ITA 229/BANG/2022[2018-19]Status: DisposedITAT Bangalore30 May 2022AY 2018-19

Bench: Shri B.R. Baskaranit(It)A No.229/Bang/2022 (Assessment Year:2018-19) Shri Prasanna Kumar Dy. Commissioner Of Income Tax 4-3-298/12, Palemar International Taxation Vs. Bejai Church, Cross Road Circle - 2(2), Bangalore Mangalore 575004 Pan –Bfapk0601P Appellant Respondent Appellant By: Smt. Sheetal, Advocate Respondent By: Shri Ganesh R. Ghale, Advocate Standing Counsel For Revenue Date Of Hearing: 26.05.2022 Date Of Pronouncement: 30.05.2022

For Appellant: Smt. Sheetal, AdvocateFor Respondent: Shri Ganesh R. Ghale, Advocate
Section 143(3)Section 50C

carry forward of loss 3. The facts relating to the first issue are that the assessee is a non- resident and he filed his return of income declaring total income of Rs.1,01,010/- and claimed refund of tax of Rs.22.63 lakhs. The refund has arisen because, TDS

M/S SCANIA COMMERCIAL VEHICLES INDIA PVT LTFD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

The Appeal of the Assessee is allowed

ITA 261/BANG/2022[2017-18]Status: DisposedITAT Bangalore16 Dec 2025AY 2017-18

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubey

For Appellant: Shri Narendra Kumar Jain, Advocate
Section 143(3)Section 68Section 92C

carry forward of losses for any subsequent years to the Assessee.In the result, this ground is also allowed. 19. In view of this, the Appeals of the Assessee on all the corporate grounds, no. 17-20 is allowed. In the result, Appeal of the Assessee is allowed. 20. ITA No. 777/Bang/2022 is filed for Assessment Year 2018-19 against

DEPUTY COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S INFOSYS BPO LTD, BANGALORE

In the result appeal filed by assessee stands partly allowed

ITA 1333/BANG/2014[2007-08]Status: DisposedITAT Bangalore27 Sept 2019AY 2007-08

Bench: Shri J. Sudhakar Reddy & Smt.Beena Pillai

For Appellant: Shri P.C. Khincha, CAFor Respondent: Miss. Neera Malhotra, CIT, DR
Section 10ASection 14ASection 40

carried on by assessee. We therefore do not find force in submissions made by Ld.AR regarding forward contract in foreign exchange partaking character of treasury operations. ITA Nos.1333 & 1367(B)/2014 28 In our considered opinion, forward contract has been entered by assessee in relation to business income and therefore any loss or gain earned by assessee on account

DCIT, BANGALORE vs. M/S CORE OBJECTS INDIA PVT. LTD.,, BANGALORE

In the result appeal filed by assessee stands allowed as indicated hereinabove and appeal filed by revenue stands allowed partly

ITA 517/BANG/2015[2010-11]Status: DisposedITAT Bangalore01 Apr 2021AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.517/Bang/2015 Assessment Year : 2010-11

For Appellant: Shri Muzaffar Hussain, CIT (DR)For Respondent: Smt. Tanmayee Rajkumar
Section 10ASection 143Section 144CSection 144C(13)Section 194JSection 40Section 9(1)(iv)

carry forward of the loss under the head 'Income from other Sources' amounting to Rs. 2, 16,017 for set off against income in subsequent years. 3. Interest under section 234B The learned AO has erred in levying interest under section 234B of the Act amounting to Rs. 8,802,484. 4. Interest under section 234C The learned

M/S. IDEB PROJECTS PVT. LTD,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 529/BANG/2017[2012-13]Status: DisposedITAT Bangalore07 Nov 2023AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012-13

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri M.H. Naik, D.R
Section 14ASection 250Section 36(1)(iii)

TDS for which disallowance was made in the earlier year) for which no return of income needs to be filed. 11. The Hon'ble Commissioner of Income Tax Appeals erred in stating that the assesse is entitled to carry forward loss

M N DASTUR & COMPANY PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BANGALORE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 119/BANG/2022[2016-17]Status: DisposedITAT Bangalore26 May 2022AY 2016-17

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.K.R.Pradeep, CAFor Respondent: Sri.Sankar Ganesh K, JCIT-DR
Section 143(1)Section 154Section 194JSection 199

loss account out of the advances received from the clients and the balance advances is carried forward to subsequent years and shown as advances received from clients. It was submitted that at times no advances are received from the clients but services have been rendered and invoices raised and income offered to tax on accrual basis, however, the payments

M N DASTUR & COMPANY PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 4(1)(2), BANGALORE

In the result, the appeals filed by the assessee are allowed for statistical purposes

ITA 118/BANG/2022[2015-16]Status: DisposedITAT Bangalore26 May 2022AY 2015-16

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.K.R.Pradeep, CAFor Respondent: Sri.Sankar Ganesh K, JCIT-DR
Section 143(1)Section 154Section 194JSection 199

loss account out of the advances received from the clients and the balance advances is carried forward to subsequent years and shown as advances received from clients. It was submitted that at times no advances are received from the clients but services have been rendered and invoices raised and income offered to tax on accrual basis, however, the payments

XCHANGING SOLUTIONS LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the assessee is partly allowed

ITA 1294/BANG/2012[2008-09]Status: DisposedITAT Bangalore31 Oct 2016AY 2008-09

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

For Appellant: Shri Nageshwar Rao, AdvocateFor Respondent: Shri G.R. Reddy, CIT-I (D.R)
Section 115JSection 143(3)Section 211(6)Section 244A

TDS claim by INR 3,98,089 and reduction in refund claim by INR 3,98,089 together with applicable interest under Section 244A of the Act. The Petitioner submits that the above additional grounds are being raised by way of abundant caution. The additional grounds raise issues which are fundamental to the appeal and the non- admission

DCIT, BANGALORE vs. M/S NSL SUGARS LTD.,, BANGALORE

In the result, the appeal by the revenue in ITA No

ITA 37/BANG/2016[2011-12]Status: DisposedITAT Bangalore08 Nov 2019AY 2011-12

Bench: Shri N V Vasudevan & Shri A K Garodiaassessment Year : 2011-12

For Appellant: Shri B.S. Balachandran, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT(DR-I), ITAT, Bangalore
Section 70Section 72Section 80A(1)Section 80CSection 80I

forward unabsorbed losses and unabsorbed depreciation, etc. ITA No. 37/B/2016, 1228/B/17 & CO No.66/B/2016 Page 9 of 18 12. The Hon’ble Supreme Court further held that under s. 80-I(6) the profits derived from one industrial undertaking cannot be set off against loss suffered from another and the profit is required to be computed as if profit making industrial

M/S NSL SUGARS LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(1)(2), BANGALORE

In the result, the appeal by the revenue in ITA No

ITA 1228/BANG/2017[2012-13]Status: DisposedITAT Bangalore08 Nov 2019AY 2012-13

Bench: Shri N V Vasudevan & Shri A K Garodiaassessment Year : 2011-12

For Appellant: Shri B.S. Balachandran, AdvocateFor Respondent: Shri C.H. Sundar Rao, CIT(DR-I), ITAT, Bangalore
Section 70Section 72Section 80A(1)Section 80CSection 80I

forward unabsorbed losses and unabsorbed depreciation, etc. ITA No. 37/B/2016, 1228/B/17 & CO No.66/B/2016 Page 9 of 18 12. The Hon’ble Supreme Court further held that under s. 80-I(6) the profits derived from one industrial undertaking cannot be set off against loss suffered from another and the profit is required to be computed as if profit making industrial