DELL INDIA P LTD,BANGALORE vs. INCOME TAX OFFICER(TDS), LTU, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

438/-. The Ld.AO also levied consequential interest of Rs.1,62,01,719/- under Section 201(1A) of the Act. Page 4 ITA Nos. 1644/Bang/2014, 1151/Bang/2015 & 2035/Bang/2016 3. Aggrieved by the order of Ld.AO, assessee preferred appeal before Ld.CIT(A). 3.1. The Ld.CIT(A) disposed of the issues raised by assessee in ITA 1644 for assessment year 2012-13, by following

INCOME TAX OFFICER, BANGALORE vs. M/S.DELL INDIA PVT.LTD.,, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

438/-. The Ld.AO also levied consequential interest of Rs.1,62,01,719/- under Section 201(1A) of the Act. Page 4 ITA Nos. 1644/Bang/2014, 1151/Bang/2015 & 2035/Bang/2016 3. Aggrieved by the order of Ld.AO, assessee preferred appeal before Ld.CIT(A). 3.1. The Ld.CIT(A) disposed of the issues raised by assessee in ITA 1644 for assessment year 2012-13, by following

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

TDS u/s 195 of the I.T.Act (refer grounds 2.9 to 2.15). We are of the view that these grounds need not be adjudicated, since, on perusal of the final assessment, it is clear that the disallowance of ESOP expenses has made under IT(TP)A No.413/Bang/2022 Hewlett Packard (India) Software Operation Pvt. Ltd., Bangalore Page 26 of 32 the provisions

M/S DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, appealsof the assessee are partly allowed

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

TDS on the amount retained by the Airlines while making the payment to the assessee. Our attention was also invited to the proviso to section 40(a)(ia) of the Act, according to which if the respondent has paid the tax on the receipt and filed the return before the due date of filing the return, the assessee cannot

M/S. DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, appealsof the assessee are partly allowed

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

TDS on the amount retained by the Airlines while making the payment to the assessee. Our attention was also invited to the proviso to section 40(a)(ia) of the Act, according to which if the respondent has paid the tax on the receipt and filed the return before the due date of filing the return, the assessee cannot

M/S. DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, appealsof the assessee are partly allowed

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

TDS on the amount retained by the Airlines while making the payment to the assessee. Our attention was also invited to the proviso to section 40(a)(ia) of the Act, according to which if the respondent has paid the tax on the receipt and filed the return before the due date of filing the return, the assessee cannot

M/S. DELHI INTERNATIONAL AIRPORT PRIVATE LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

In the result, appealsof the assessee are partly allowed

Bench: Shri Sunil Kumar Yadavand Shri. Jason P Boaz

TDS on the amount retained by the Airlines while making the payment to the assessee. Our attention was also invited to the proviso to section 40(a)(ia) of the Act, according to which if the respondent has paid the tax on the receipt and filed the return before the due date of filing the return, the assessee cannot

RANGSONS SCHUSTER TECHNOLOGIES PRIVATE LIMITED ,MANDYA vs. DCIT,CIRCLE-1(1)& TPS , MYSORE

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

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year : 2018-19 M/S. Rangsons Schuster Technologies Pvt. Ltd., Vs. Dcit, Plot No.9, Hebbal Ii Nd Phase Viadb Circle – 1(1) & Tps, Industrial Area, Survey No.36, Belagolahobli, Mysore. Srirangapatna, H.O. Shrirangapattana, Mandya– 571 438,Karnataka. Pan : Aafcr 4493 J Appellant Respondent Assessee By : Shri. V. Srinivasan, Advocate Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 23.09.2025 Date Of Pronouncement : 29.09.2025

438,Karnataka. PAN : AAFCR 4493 J APPELLANT RESPONDENT Assessee by : Shri. V. Srinivasan, Advocate Revenue by : Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore. Date of hearing : 23.09.2025 Date of Pronouncement : 29.09.2025 O R D E R Per Laxmi Prasad Sahu, Accountant Member : This appeal is filed by the assessee against the Order passed by the CIT(A) dated

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

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

TDS was not applicable amounting to Rs. 202,90,08,182/-, as a capital expenditure eligible for 25 percent depreciation amounting to Rs. 146,31,38,211/- and erred in making a net disallowance of Rs. 438,94,14,633/-. The assessee contended that the software expense should be held as revenue expenditure and without prejudice, depreciation should be allowed

M/S INFOSYS LTD ,BANGALOR E vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-3(1)(1), BANGALORE

In the result, the appeal filed by the assessee as well as by revenue are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.735/Bang/2018 Assessment Year: 2013-14

TDS was not applicable amounting to Rs. 202,90,08,182/-, as a capital expenditure eligible for 25 percent depreciation amounting to Rs. 146,31,38,211/- and erred in making a net disallowance of Rs. 438,94,14,633/-. The assessee contended that the software expense should be held as revenue expenditure and without prejudice, depreciation should be allowed

M/S. TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

438 assembly,electro limit gauge Purchase of bearing cup 8,018 Purchase of bearing assembly 85,928 Purchase of tapered roller bearing, bearing assembly, 2,03,132 electrol imit gauge blocks and transducer conditioner sangamo In view of the facts brought to our notice, the expenditure of Rs.50,000/- paid towardsarchitect's fees is being directed to be allowed

M/S TIMKEN ENGINEERING & RESEARCH INDIA P. LTD. vs. DCIT,

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

438 assembly,electro limit gauge Purchase of bearing cup 8,018 Purchase of bearing assembly 85,928 Purchase of tapered roller bearing, bearing assembly, 2,03,132 electrol imit gauge blocks and transducer conditioner sangamo In view of the facts brought to our notice, the expenditure of Rs.50,000/- paid towardsarchitect's fees is being directed to be allowed

TIMKEN ENGINEERING & RESEARCH INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

438 assembly,electro limit gauge Purchase of bearing cup 8,018 Purchase of bearing assembly 85,928 Purchase of tapered roller bearing, bearing assembly, 2,03,132 electrol imit gauge blocks and transducer conditioner sangamo In view of the facts brought to our notice, the expenditure of Rs.50,000/- paid towardsarchitect's fees is being directed to be allowed

DCIT vs. M/S TIMKEN ENGINEERING AND RESEARCH PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

438 assembly,electro limit gauge Purchase of bearing cup 8,018 Purchase of bearing assembly 85,928 Purchase of tapered roller bearing, bearing assembly, 2,03,132 electrol imit gauge blocks and transducer conditioner sangamo In view of the facts brought to our notice, the expenditure of Rs.50,000/- paid towardsarchitect's fees is being directed to be allowed

DCIT, BANGALORE vs. M/S TIMKEN ENGINEERING & RESEARCH INDIA PVT. LTD.,, BANGALORE

In the result, the appeal of the revenue is partly allowed in the terms indicated above

Bench: Shri Arun Kumar Garodia & Shri Laliet Kumar

438 assembly,electro limit gauge Purchase of bearing cup 8,018 Purchase of bearing assembly 85,928 Purchase of tapered roller bearing, bearing assembly, 2,03,132 electrol imit gauge blocks and transducer conditioner sangamo In view of the facts brought to our notice, the expenditure of Rs.50,000/- paid towardsarchitect's fees is being directed to be allowed

M/S. GMR HYDERABAD INTERNATIONAL AIRPORT LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

438 of the Income tax. act in 198]-84. Clause (a) of section 43B provides that "any sum payable by the assessee by way of tax, duty, cess or fee, by whatever name called under any law for the time being in force" shall be allowed as a deduction in a financial year only if It has been actually paid

M/S. GMS HYDERABAD INTERNATIONAL AIRPORT LIMITED,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

438 of the Income tax. act in 198]-84. Clause (a) of section 43B provides that "any sum payable by the assessee by way of tax, duty, cess or fee, by whatever name called under any law for the time being in force" shall be allowed as a deduction in a financial year only if It has been actually paid

M/S.GMR HYDERABAD INTERNATIONAL AIRPORT LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, BANGALORE

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

438 of the Income tax. act in 198]-84. Clause (a) of section 43B provides that "any sum payable by the assessee by way of tax, duty, cess or fee, by whatever name called under any law for the time being in force" shall be allowed as a deduction in a financial year only if It has been actually paid