RAJIV GANDHI UNIVERSITY OF HEALTH SCIENCES,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALORE

In the result, the appeal filed by the assessee in ITA No

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 11(5) of the Act by investing the accumulation made u/s 11(2) of the Act in the specified Page 3 of 15 ITA Nos. 584 & 563/Bang/2022 investments has rightly claimed the accumulation u/s 11(2) of the Act and same is to be allowed to the Appellant. 3. The denial of credit for TDS

RAJIV GANDHI UNIVERSITY OF HEALTH SCIENCES,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALORE

In the result, the appeal filed by the assessee in ITA No

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 11(5) of the Act by investing the accumulation made u/s 11(2) of the Act in the specified Page 3 of 15 ITA Nos. 584 & 563/Bang/2022 investments has rightly claimed the accumulation u/s 11(2) of the Act and same is to be allowed to the Appellant. 3. The denial of credit for TDS

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\N\Nappellant Respondent\N\Nappellant By : Sri Padamchand Khincha, A.R.\Nrespondent By : Sri K.M. Mahesh, D.R.\N\Ndate Of Hearing : 17.09.2025\Ndate Of Pronouncement : 15.12.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Appeals At The Instance Of The Assessee Are Directed Against The Orders Of The 1D. Cit(A)/Nfac Dated 18.02.2025 Vide Din & Order No.Itba/Nfac/S/250/2024-25/1073418441(1) For The Assessment Year 2021-22 & Vide Order Dated 31.1.2025 With Din & Order No.Itba/Nfac/S/250/2024-25/1072790068(1) For The Assessment Year 2015-16 Passed U/S 250 Of The Income Tax Act, 1961 (In Short “The Act”). Since The Issues In Both The Appeals Are Similar, These Are Clubbed Together, Heard Together & Disposed 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 For The Assessment Year 2021-22 For Adjudication. The Assessee Has Raised The Following Grounds Of Appeal:\N\N1. General Ground\N\N1.

11.\n9. 3. On facts and circumstances of the case and law applicable, impugned disallowance under section 43B amounting to Rs.17,67,052 is bad in law and liable to be quashed.\n\n10. Disallowance under section 43B is bad in law\n\n11.1 The learned Assessing Officer has erred in making additions in respect of various statutory and contractual

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.

section 11 is to be\nallowed as claimed by the appellant.\n\n4. Non accounting of Receipts of Maintenance Charges and Expenses in relation to\nNational Games Village\n5.1 The learned Assessing officer has erred in making an additional of Rs.3,65,00,000 on\naccount of recording of income and expenditure relating to maintenance charges is bad in\nlaw

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(2), BANGALORE vs. M/S. BANGALORE TURF CLUB LIMITED, BANGALORE

In the result, appeal filed by assessee stands partly allowed and appeal filed by revenue stands dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14

TDS under section 194B or section 194 BB of the Act. Consequentially no disallowance could be made under section 40 (a) (ia) of the act in the hands of assessee. Accordingly ground No. 2-4 raised by assessee stands allowed.” 9.2 The facts for year under consideration are identical and nothing contrary has been placed on record by revenue

BANGALORE TURF CLUB LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BENGALURU

In the result, appeal filed by assessee stands partly allowed and appeal filed by revenue stands dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2013-14

TDS under section 194B or section 194 BB of the Act. Consequentially no disallowance could be made under section 40 (a) (ia) of the act in the hands of assessee. Accordingly ground No. 2-4 raised by assessee stands allowed.” 9.2 The facts for year under consideration are identical and nothing contrary has been placed on record by revenue

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessees are allowed

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

TDS:- “10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis-construing this

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessees are allowed

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

TDS:- “10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis-construing this

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessees are allowed

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

TDS:- “10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis-construing this

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S SYNDICATE BANK `,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE - 3, BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX(TDS), RANGE - 3, BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this

M/S. SYNDICATE BANK,GANDHINAGAR vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

TDS:- "10. In the instant case, the assessee is a Cooperative Bank. Clause 5 of sub-section (3) of Section 194A expressly exempts the Bank from deducting the tax at source on interest payable by the Bank to its members and other Cooperative Societies. As stated by the assessee, they did not properly construe this provision. By mis- construing this