ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE vs. M/S. GMR INFRASTRUCTURE LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

GMR INFRASTRUCTURE LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. GMR INFRASTRUCTURE LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

GMR INFRASTRUCTURE LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(2), BANGALORE vs. M/S GMR INFRASTRUCTURE LTD , BANGALORE

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

GMR HIGHWAYS LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCLE- 3(1)(2), BANGALORE

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU vs. M/S. GMR INFRASTRUCTURE LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

GMR INFRASTRUCTURE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

GMR INFRASTRUCTURE LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BANGALORE

In the result, Ground no. 1 raised for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

section 143(1). This ground of the appellant is ALLOWED. 23. The learned Departmental Representative relied on the order of the Assessing Officer could not controvert the findings of the CIT (Appeals) with any new evidence or data and accordingly we uphold the order of the learned CIT (Appeals) that this ground of appeal and dismiss the grounds of revenue

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

section 234B amounting to Rs. 3,66,41,150 be deleted. The appellant prays accordingly.” Page 5 of 25 ITA Nos. 1849 & 2248/Bang/2019 “1. The order of the Learned CIT (Appeals), in so far as it is prejudicial to the interest of revenue, is opposed to law and the facts and circumstances of the case

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

section 234B amounting to Rs. 3,66,41,150 be deleted. The appellant prays accordingly.” Page 5 of 25 ITA Nos. 1849 & 2248/Bang/2019 “1. The order of the Learned CIT (Appeals), in so far as it is prejudicial to the interest of revenue, is opposed to law and the facts and circumstances of the case

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

234B and 234D.” 5. Ground No.1 being general in nature, no adjudication is called for thereon. 6. Ground No.2 - Disallowance of Subscription charges paid to Forrester Research Inc., USA. 6.1 This ground is raised by the assessee in respect of the disallowance under Section 40(a)(i) of the Act of subscription charges amounting to 7 IT(TP)A Nos.102

KANTILAL JAIN,BANGALORE vs. INCOME TAX OFFICER, WARD-3(3)(1), BANGALORE

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

Bench: Shri Chandra Poojariassessment Year: 2017-18

TDS credit of Rs. 1,21,659 be allowed, and c) Interest levied under sections 234B and 234C be deleted

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

section 234B and 234D. Prayer 61. In view of the above and other grounds to be adduced at the time of hearing, the appellant prays that the DRP directions and the final assessment order passed by the learned AO be quashed or in the alternative, the aforesaid grounds and the relief prayed for there under be allowed. The appellant submits

THE JOINT COMMISSIONER OF INCOME TAX SPECIAL RANGE-4 , BANGALORE vs. M/S MPHASIS LIMITED , BANGALORE

In the result, both the appeals are dismissed

Bench: Shri N.V. Vasudevan & Shri B R Baskaranassessment Year: 2009-10

TDS under section 195 and consequently not liable for disallowance under section 40(a)(i). Levy of Interest under section 234B

HEWLETT PACKARD (INDIA) SOFTWARE OPERATION PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.413/Bang/2022 Assessment Year: 2017-18

234B of the Act amounting to INR 15,95,29,740. IT(TP)A No.413/Bang/2022 Hewlett Packard (India) Software Operation Pvt. Ltd., Bangalore Page 5 of 32 3.6 The NFAC erred in the levying interest under section 234C of the Act on the assessed income instead of considering the returned income thereby levying an excess interest

MRS. SABENA PRAKASH ,BENGALURU vs. INCOME TAX OFFICER, WARD-3(2)(1), BANGALORE

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

234B of the Act on the facts and circumstances of the case.\n11. Without prejudice the learned Assessing Officer erred in law in initiating the penalty\nproceedings under the provisions of section 274 read with section 270A of the Act on the\nfacts and circumstances of the case.\n12. The Appellant craves to add, alter, delete or substitute

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.

TDS amounting to Rs.1,76,112 under section 40(a)(ia) of the Act.\n\n15. 2. The learned Assessing officer has failed to appreciate that the provisions of section 40(a)(ia) are applicable in computing the income under section 11 to 13 as per Explanation 3 to section 11 introduced by the Finance Act 2018 w.e.f