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414 results for “TDS”+ Section 234bclear

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Key Topics

Addition to Income74Section 10A58Section 4055Disallowance49Deduction48Section 143(3)47TDS44Section 234B43Transfer Pricing34Section 148

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

In the result appeal filed by assessee for assessment year 2012-

ITA 1848/BANG/2019[2012-13]Status: DisposedITAT Bangalore18 Dec 2020AY 2012-13

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Padamchand Khincha, C.A
Section 143(3)Section 194BSection 201fSection 234BSection 234CSection 40

234B amounting to Rs. 3,93,70,932 be deleted. c) Interest levied under section 234C amounting to Rs.22,440 be deleted. The appellant prays accordingly. Brief facts of the case are as under: 2.1Assessee is company engaged in the business of conducting horse races. It has been observed by Ld.AO that assessee would collect ticket money from across

Showing 1–20 of 414 · Page 1 of 21

...
27
Section 14A27
Section 153C26

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

In the result, Ground no. 1 raised for A

ITA 1705/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1741/BANG/2017[2010-11]Status: DisposedITAT Bangalore25 May 2022AY 2010-11

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1742/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1599/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1600/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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 LIMITED, BENGALURU

In the result, Ground no. 1 raised for A

ITA 1743/BANG/2017[2012-13]Status: DisposedITAT Bangalore25 May 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1643/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1744/BANG/2017[2013-14]Status: DisposedITAT Bangalore25 May 2022AY 2013-14

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 495/BANG/2020[2016-17]Status: DisposedITAT Bangalore25 May 2022AY 2016-17

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

ITA 1622/BANG/2017[2011-12]Status: DisposedITAT Bangalore25 May 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri Yogesh A Thar, CA
Section 14ASection 201Section 234B

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

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

ITA 1849/BANG/2019[2013-14]Status: DisposedITAT Bangalore11 Oct 2021AY 2013-14

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

For Respondent: Shri Padamchand Khincha
Section 194BSection 201fSection 37Section 37(1)Section 40

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

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

ITA 2248/BANG/2019[2013-14]Status: DisposedITAT Bangalore11 Oct 2021AY 2013-14

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

For Respondent: Shri Padamchand Khincha
Section 194BSection 201fSection 37Section 37(1)Section 40

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

ITA 102/BANG/2013[2005-06]Status: DisposedITAT Bangalore10 Nov 2017AY 2005-06

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri H.N. Khincha, C.AFor Respondent: Shri R. N. Parbat, CIT-III (D.R)
Section 143(3)Section 195Section 40Section 92ASection 92C

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

ITA 579/BANG/2022[2017-18]Status: DisposedITAT Bangalore18 Aug 2022AY 2017-18

Bench: Shri Chandra Poojariassessment Year: 2017-18

For Appellant: Shri B.R. Sudheendra, A.RFor Respondent: Shri Ganesh R. Ghale, Standing Counsel
Section 143(1)Section 194DSection 234BSection 234CSection 250

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

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

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 10ASection 14ASection 2Section 2(24)Section 40

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

ITA 3418/BANG/2018[2009-10]Status: DisposedITAT Bangalore03 Jun 2020AY 2009-10

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

For Appellant: Shri Pradeep Kumar, CIT(DR)(ITAT), BengaluruFor Respondent: Shri Padam Chand Khincha, CA
Section 10ASection 143(3)Section 147Section 148Section 195Section 40

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

ITA 413/BANG/2022[2017-18]Status: DisposedITAT Bangalore03 Oct 2022AY 2017-18

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

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 192Section 195Section 37Section 40Section 92C

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

M/S PLAYSIMPLE GAMES PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE - 5(1)(2), BANGALORE

In the result, the appeal is allowed for statistical purposes

ITA 1125/BANG/2019[2016/17]Status: DisposedITAT Bangalore09 Mar 2022

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2016-17

For Appellant: Shri Deepak Kumar Jain, CAFor Respondent: Shri Priyadarshi Mishra, Addl.CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 195Section 234BSection 234DSection 40Section 9(1)(vi)

234B and section Page 5 of 9 234D is computed at Rs. 24,76,287/- and Rs. 11,297/- respectively. As a consequence, a sum of Rs. 1,00,82,021/- is determined as payable by the appellant. 7. Before the CIT(Appeals), the Appellant also submitted that the impugned payments do not constitute royalty or fees for technical services

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S TECNOTREE CONVERGENCE LTD , GURGAON

In the result, Revenue’s appeal for Assessment Year 2011-12 is dismissed

ITA 1447/BANG/2017[2010-11]Status: DisposedITAT Bangalore03 Jul 2019AY 2010-11

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

For Respondent: Shri. Pradeep Kumar, CIT
Section 10ASection 10A(3)Section 115JSection 143(1)Section 143(3)Section 155Section 40Section 94(7)

TDS was not done thereon, the payments are liable for disallowance under section 40(a)(i) of the Act. 10.5.2 Section 195 of the Act deals with the deduction of tax at source from out of the payments made to non-residents. Under Section 195 of the Act, an obligation is cast on a person making payment