INCOME TAX OFFICER(TDS),WARD-18(2), BANGALORE vs. M/S SYMPHONY MARKETING SOLUTIONS I P LTD, BANGALORE

In the result, Revenue’s appeal for Assessment Years 2009-10 to 2011-12 are dismissed

TDS under Section 192 of the Act. In that view of the matter, the Assessing Officer passed orders under Section 201(1) and 201(1A) of the Act for Assessment Years 2009- 10 to 2011-12 raising demands as under :- S.No. Asst. Year Date of order Demand Raised

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

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

46,44,58,385/- • SEZ-Pune - Rs.1,25,36,40,014/- • SEZ-Kolkata - Rs. 18,44,50,860/- • SEZ-Gurgaon - Rs. 8,22,33,583/- • SEZ-Mumbai - Rs. 4,08,00,128/- 6.6. After entering into APA, income of assessee from export of IT services increased by sum of Rs.7,74,21,28,914/-, thereby, increasing income in the hands

KARNATAKA HOUSING BOARD,BANGALORE vs. DCIT, EXEMPTIONS, CIRCLE-1, BANGALORE

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\N\Nita Nos.512 & 513/Bang/2025\N Assessment Year : 2021-22 & 2015-16\N\Nkarnataka Housing Board\N4Th Floor Cauvery Bhavan\Nk.G. Road\Nbangalore 560 009\Nvs.\Ndcit (Exemptions)\Ncircle-1\Nbangalore\N\Npan No :Aaajk0398K\Nappellant\Nrespondent\N\Nappellant By\Nrespondent By\N: Sri Padamchand Khincha, A.R.\N: Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing\N: 17.09.2025\Ndate Of Pronouncement\N: 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide\Ndin & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For\Nthe Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With\Ndin & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For\Nthe Assessment Year 2015-16 Passed U/S 250 Of The Income Tax\Nact, 1961 (In Short “The Act”). Since The Issues In Both The Appeals\Nare Similar, These Are Clubbed Together, Heard Together And\Ndisposed Of By This Common Order For The Sake Of Convenience.\N\N2. First, We Take Up Assessee'S Appeal In Ita No.512/Bang/2025\Nfor The Assessment Year 2021-22 For Adjudication. The Assessee\Nhas Raised The Following Grounds Of Appeal:\N\N1. General Ground\N1.

46) after 01.04.2011 does not preclude a statutory\ncorporation, board, or whatever such body may be called, from\nclaiming that it is set up for a charitable purpose and seeking\nexemption under Section 10(23C) or other provisions of the\nAct.\n\n19. In para B.4 it is categorically held that it does not preclude the\nstatutory Boards and Corporations

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

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

TDS; but is a statutory deduction on an asset which is otherwise eligible for deduction of depreciation. Section 40(a)(i) and (ia) of the Act provides for disallowance only in respect of expenditure, which is revenue in nature, therefore, the provision does not apply to a case of the assessee whose claim is for depreciation, which

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

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

TDS; but is a statutory deduction on an asset which is otherwise eligible for deduction of depreciation. Section 40(a)(i) and (ia) of the Act provides for disallowance only in respect of expenditure, which is revenue in nature, therefore, the provision does not apply to a case of the assessee whose claim is for depreciation, which

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

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

TDS; but is a statutory deduction on an asset which is otherwise eligible for deduction of depreciation. Section 40(a)(i) and (ia) of the Act provides for disallowance only in respect of expenditure, which is revenue in nature, therefore, the provision does not apply to a case of the assessee whose claim is for depreciation, which

SOMCHAND GIRIRAJ GUPTA ,VIJAYAPUR vs. INCOME TAX OFFICER WARD- 1 & TPS , VIJAYAPUR

In the result appeal filed by assessee stands allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2015-16 Shri Somchand Giriraj Gupta, The Income Tax Officer, Mukund Nagar, Ward 1 & Tps, Station Road, Vijayapur. Vijayapura. Vs. Pan: Abtpg6461F Appellant Respondent Assessee By : Shri V. Srinivasan, Ca Revenue By : Smt. H. Kabila, Addl. Cit (Dr) Date Of Hearing : 27-08-2021 Date Of Pronouncement : 11-10-2021 Order Per Beena Pillai

46 of the Page 2 of 18 RFCTLARR Act applies to private negotiations and not applicable to Government Compulsory acquisition 3. The Id CIT(A) ought to have applied Circular of CBDT Vide no. 36 dt 25.10.2016 and granted exemption to the entire consideration received from compulsory acquisition of land. 4. The Id CIT(A) erred

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,CHITRADURGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,HAVERI vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

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

section 201(1A) of the Act, by Ld.AO, branch wise, qua assessment year, in paper book at page 3-6 as under: Page 5 of 74 ITA No.507 to 566 /Bang/2020 Theerthahalli Branch Payment to Cash Medical Payment to Chinnu Kulkarni Services Benefit u/s 192 Graphics 194C u s 194C Interest Interest Interest TDS 201 201 201 TDS TDS deductible