M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

TDS under section 195 of the Act on the amount aid to J&P Coats Ltd. Page 20 IT(IT)A Nos. 1344 & 1345/Bang/2019 20. Aggrieved by the order passed by the Ld.CIT(A), the assessee is in appeal before this Tribunal. 21. Before us, the Ld.AR submitted that, the view taken by authorities below is based on the amendment

M/S. MADURA COATS PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX., (INTERNATIONAL TRANSACTION), CIRCLE- 1(2), BANGALORE

In the result, appeals filed by assessee for A

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(It)A Nos. 1344 & 1345/Bang/2019 Assessment Years : 2016-17 & 2017-18 M/S. Madura Coats Pvt. The Deputy Ltd., Commissioner Of 7Th Floor, Jupiter Income Tax Prestige Technology (International Park, Vs. Taxation), Outer Ring Road, Circle – 1(2), Bangalore – 560 103. Bangalore. Pan: Aabcm8297K Appellant Respondent Assessee By : Shri Ajay Rotti, Ca : Shri Shehnawaz Ul Rahaman, Revenue By Addl. Cit (Dr) Date Of Hearing : 13-04-2022 Date Of Pronouncement : 31-05-2022 Order Per Beena Pillaipresent Appeals Are Filed By Assessee Against Order Dated 30.03.2019 Passed By Ld.Cit(A)-12, Bangalore For A.Ys. 2016-17 & 2017-18. It Is Submitted That The Issues Alleged By Assessee In Both These Years Are Identical & On Similar Facts. 2. Brief Facts Of The Case Are As Under: 2.1 Madura Coats Pvt Ltd (Mcpl) Is An Indian Company Carrying On The Business As Manufacturer & Merchant Of Sewing Threads & Other Goods, Possesses The Requisite Expertise & Experience By Virtue Of Having Several Qualified Personnel In Its Employment. During The Course Of Verification Conducted Us

TDS under section 195 of the Act on the amount aid to J&P Coats Ltd. Page 20 IT(IT)A Nos. 1344 & 1345/Bang/2019 20. Aggrieved by the order passed by the Ld.CIT(A), the assessee is in appeal before this Tribunal. 21. Before us, the Ld.AR submitted that, the view taken by authorities below is based on the amendment

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , UDUPI , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

M/S MAHARASHTRA APEX CORPORATION LIMITED ,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1 , , UDUPI

240 & 241/Bang/2018

Bench: Shri A. K. Garodia & Shri Pavan Kumar Gadale

TDS. Subsequently on application by appellant he passed orders under ITA Nos. 239 to 255/Bang/2018 Page 31 of 37 Section

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. SRI. SURESH S KANAJI, BENGALURU

In the result, appeal of the revenue is hereby dismissed

TDS credit.\nThis discrepancy was evident from a mismatch between the figures of\nreceipts reported in Form 26AS and those declared in the financial\nstatements. Contract receipts were revised multiple times without\nsufficient justification. For example, in AY 2017-18, receipts were initially\ndeclared as 4.86 crore, later revised to ₹17.92 crore, and ultimately\nreported as ₹4.93 crore. Additionally

ASSISTANT COMMISSIONER OF INCOME-TAX, BANGALORE vs. M/S. CHESLIND TEXTILES LTD.,, BANGALORE

In the result appeal filed by revenue stands dismissed

Bench: Shri J. Sudhakar Reddy & Ms. Beena Pillaiassessment Year : 2011-12

Section 9(1)(vi) and 9(1)(vii) Page 4 of 9 of the Act. Once the payment in question is not treated as ETS or royalty then, the same being business income in the hands of the non-resident marketing agents is not chargeable to tax in India in the absence of PE. The CIT (Appeals) has allowed

AJIT KUMAR,BANGALORE vs. ACIT, INTERNATIONAL TAXATION, CIRCLE-1(2) , BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kit(It)A No.449/Bang/2025 Assessment Year : 2015-16

239(1) of the Act and observed that the assessee can claim refund only after filing return of income (RoI) as per section 139 of the Act (RoI filed in response to notice under section 148 of the Act). Therefore, the assessee is not eligible for refund. Accordingly, the AO passed the Order under section 144C

M/S AUOTDESK ASIA PTE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri Chandra Poojari & Shri George George K.

239,185; b) Determining a tax payable of INR 293,512,480; c) Raising a demand of INR 8,039,645 upon the Appellant. 3 Erroneous treatment of the consideration received for INR sale of software as 'royalty' 279,418,171 3.1 The AO and the Dispute Resolution Panel ('DRP') have erred in not holding that consideration received

ASSISTANT COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-2(3), BANGALORE vs. M/S RNS INFRASTRUCTURE LTD , BANGALORE

In the result appeal filed by revenue stands dismissed

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

TDS under section 194 A of the act against interest paid to nonbanking financial companies. It is also an admitted fact that the companies to whom assessee has made payments are repeated companies like M/s. L & T Finance Ltd., M/s. Bajaj Finance Ltd., M/s. Reliance Capital Ltd., M/s. India Bulls Ltd., M/s. Diamler Finance Ltd., M/s. Kotak Mahindra Bank