PACHISIA PLASTICS PRIVATE LIMITED ,KANAKPURA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS , GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

PACHISIA PLASTICS PRIVATE LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS , GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

LALITH KUMAR DOSI ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS, GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

PACHISIA PLASTICS PRIVATE LIMITED ,KANAKAPURA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS , GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

PACHISIA PLASTICS PRIVATE LIMITED ,KANAKAPURA vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS , GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

LALIT KUMAR DOSI ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS, GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

PACHISIA PLASTICS PRIVATE LIMITED ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS , GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

MANOJ KUMAR JAISWAL ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CPC TDS , GHAZIABAD

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

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

section 234E. Considering this the Hon. Bombay High Court had held (already discussed supra) that this is nothing but a privilege and a special service to the deductor allowing him to file the TDS return/statements beyond the time prescribed by the Act and/or the Rules. Thus, this argument no. 3 is also rejected.” 8. The next argument

M/S ABB AB,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, the assessee appeals for A

Bench: Shri G. Manjunatha & Shri Pavan Kumar Gadaleit(I.T)A Nos.464/Bang/2018 & 2878/Bang/2019 (Assessment Years : 2012-13 & 2013-14) M/S. Abb Ab C/O Abb India Limited, 21St Floor, World Trade Centre, Dr. Rajkumar Road, Malleshwaram (West), Bangalore-560 055 ….Appellant Pan Aafca9560R Vs. Dy. Commissioner Of Income Tax, (International Taxation) Circle 1(1), Bangalore. ……Respondent. Assessee By: Shri Percy Pardiwala, Advocate. Revenue By: Shri S. Sundar Rajan, Addl. Cit (D.R) & Shri K.V. Arvind, Standing Counsel For Department.

Section 199 of the Act and Rule 37BA of the Income Tax Rules, 1962 while granting TDS credit.” 3. The Brief

BSR INFRATECH INDIA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2017-18

TDS credit in the appropriate assessment year is examined in the light of Section 199(3) r.w. Rule 37BA(3

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3

IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(2)(1) , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3

IBM ISRAEL LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3

SHRI. KANTHULA RAVISHANKAR,,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE

In the result, the assessee’s appeal for asst

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazkanthula Ravishanker, ‘Ravshan’ No.7, Bruton Road, Bangalore. . Appellant Vs. The Asst. Commissioner Of Income-Tax, Circle-2(3)(1), Bangalore . Respondent Appellant By : Shri A.C Raju, C.A Respondent By : Shri B.R Ramesh, Cit Date Of Hearing : 03-1-2018 Date Of Pronouncement : 19-1-2018 O R D E R Per Shri Jason P Boaz: This Appeal By The Assessee Is Directed Against The Order Of The Commissioner Of Income-Tax (Appeals) – 7, Bangalore Dated 30/8/2016 For Asst. Year 2012-13. 2. Briefly Stated, The Facts Of The Case Are As Under:- 2.1 The Assessee, Prop. K.K Corporation, Engaged In Business As Selling Agents For M/S Raymonal Ltd., Products For The States Of Ita No.1897/B/16 2

TDS commencing from F.Y 2008-09 should be allowed for reducing yearwise utilization admittedly made before him. 3.5.2 Section 199(3

DCIT vs. SASKEN NETWORK ENGG. LTD.,,

In the result, appeal by the Revenue is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2007-08 The Deputy Commissioner Vs. M/S. Sasken Network Engineering Limited, Of Income Tax, No.139/25, Amarjyothi Layout, Circle - 12(3), 14/3, 4Th Floor, Rastrothana Ring Road, Domlur, Bhavan (Opp. Rbi), Nrupathunga Road, Bengaluru-560071. Bengaluru. Pan : Aaics 4405 Q Appellant Respondent Appellant By : Smt. R. Premi, Jcit(Dr)(Itat), Bengaluru. Respondent By : Shri. C. Narayan, Ca Date Of Hearing : 07.07.2021 Date Of Pronouncement : 12.07.2021 O R D E R Per N.V. Vasudevanthis Is An Appeal By The Revenue Against The Order Dated 30.01.2013 Of Cit(Appeals)-Iii, Bengaluru, Relating To Assessment Year 2007-08. 2. The Facts & Circumstances Under Which The Said Appeal By The Revenue Arises For Consideration Are The Assessee Is A Company Incorporated Under The Companies Act, 1956 & Engaged Inter Alia In The Business Of Installation & Commissioning Services. The Assessee Filed Its Return Of Income ('Rol') Under Section 139(1) Of The Income-Tax Act, 1961 (Act') On October 31, 2007 Declaring Taxable Income Of Rs 3,05,04,940 On Which Taxes Of Rs 1,02,67,963 Were Payable. On Account Of Credit For Taxes Deducted At Source (Tds') Amounting To Rs 1,21,26,857 & Self Assessment Tax Amounting To Rs 1,60,0000 A Page 2 Of 9 Refund Of Rs 34,58,894 Was Claimed. The Rol Was Selected For Scrutiny & The Assessment Was Concluded Vide Assessment Order Under Section 143(3) Of The Act Dated December 17, 2009 Wherein Income Returned By The Assessee In The Rol Was Accepted By The Deputy Commissioner Of Income-Tax, Circle 12(3) (A0).

TDS without noticing the statutory position that in terms of section 199 r.w.s. 35BB (3)(i) that credit for TDS

M/S INFOSYS LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

TDS under section 195. However, it is submitted that the DRP refused to follow the same for the reason that the view has not been accepted by the department and an appeal to ITAT has been filed on this issue. It was therefore held that there is no infirmity in the proposed disallowance by the Ld.AO. The Ld.AO disallowed

DIVYA DINESH ,BENGALURU vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result appeal of the assessee is allowed

3,89,646/- was raised.\n5. Against the intimation order, the assessee filed rectification\napplication under section 154 of the Act which came to be rejected by\nthe CPC vide order dated 14th March 2021.\n6. Being aggrieved the assessee filed an appeal before the learned\nCIT(A) against the order passed under section 154 of the Act.\n6.1 Before