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2,314 results for “TDS”+ Section 5(2)(b)clear

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Key Topics

Section 143(3)54Addition to Income54Section 4052TDS52Section 20137Section 153A37Deduction36Section 201(1)34Section 10A34Section 154

M/S PRESTIGE ESTATES PROJECTS LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-18(1), BANGALORE

In the result, the appeal of the assessee is allowed

ITA 813/BANG/2019[2014-15]Status: DisposedITAT Bangalore02 Mar 2021AY 2014-15

Bench: Shri N.V.Vasudevan, Vp & Shri Chandra Poojari, Am

For Appellant: Sri.Padamchand Khincha, CAFor Respondent: Smt.R.Premi, JCIT-DR
Section 191Section 194Section 201Section 201(1)Section 206ASection 4

section 53A of the Transfer of Property Act. This agreement cannot, therefore, be said to be in the nature of a contract referred to in section 53A of the Transfer of Property Act. It cannot, therefore, be said that the provisions of section 2(47)(v) will apply in the situation before us. Considering the facts and circumstances

Showing 1–20 of 2,314 · Page 1 of 116

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33
Disallowance33
Section 6830

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

ITA 297/BANG/2024[2018-19]Status: DisposedITAT Bangalore17 Jan 2025AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

For Appellant: Sri Abharana &Anantham, A.RsFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 143(3)Section 14ASection 234BSection 250

5(d) of the BR Act as under: ITA No.424/Mum/2020 & 3740/Mum/2018 The Union Bank of India & Central Bank of India 39 "(d) "company" means any company as defined in section 3 of the Companies Act, 1956 (1 of ITA Nos.1154/Bang/2023 & ITA 210, 222 & 297/Bang/2024 M/s. Canara Bank., Bangalore Page 22 of 40 1956); and includes a foreign company within

M/S. UDUPI NIRMITHI KENDRA,UDUPI vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS) CIRCLE-1, MANGALORE

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 1962/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1,, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2089/BANG/2018[2013-14]Status: DisposedITAT Bangalore16 Jun 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2087/BANG/2018[2011-12]Status: DisposedITAT Bangalore16 Jun 2022AY 2011-12

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. UDUPI NIRMITHI KEDRA,UDUPI vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE - 1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 947/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

M/S. DAKSHINA KANNADA NIRMITHI KENDRA,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX (EXEMPTIONS), CIRCLE -1, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 948/BANG/2019[2016-17]Status: DisposedITAT Bangalore16 Jun 2022AY 2016-17

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2088/BANG/2018[2012-13]Status: DisposedITAT Bangalore16 Jun 2022AY 2012-13

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALURU vs. INCOME TAX OFFICER, WARD 1(1),, MANGALURU

In the result, all appeals filed by the assessees in all the assessees’ appeals are dismissed except for assessment year

ITA 2086/BANG/2018[2010-11]Status: DisposedITAT Bangalore16 Jun 2022AY 2010-11

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2013-14

For Appellant: Shri Tata Krishna, A.RFor Respondent: Smt. Priyadarshini Basaganni, D.R
Section 11Section 143(2)Section 2Section 2(15)

section 11 of the IT Act cannot be denied by invoking 1st proviso to section 2 (15) if the primary/ dominant objects are not (a) in the nature of trade, commerce or business; or (b) rendering any service in relation to any trade, commerce or business. 4.29 It is reiterated that the Assessee’s main objects do not involve carrying

CANARA BANK (ERSTWHILE SYNDICATE BANK),BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, appeal of the assessee is partly allowed

ITA 937/BANG/2024[2013-14]Status: DisposedITAT Bangalore16 Oct 2024AY 2013-14

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Ms. Brinda Rameswaran, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 143(3)Section 14ASection 250

5(d) of the BR Act as under: ITA No.424/Mum/2020 & 3740/Mum/2018 The Union Bank of India & Central Bank of India 39 "(d) "company" means any company as defined in section 3 of the Companies Act, 1956 (1 of 1956); and includes a foreign company within the meaning of section 591 of that Act;" 47. Therefore

SRI SRINIVASA TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

ITA 1076/BANG/2024[2021-2022]Status: DisposedITAT Bangalore18 Feb 2025AY 2021-2022

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Siva Prasad Reddy & Shri BalachandranFor Respondent: Ms. Nandini Das, CIT (DR)
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 2(45)Section 80G

B APPELLANT RESPONDENT Assessee by : Shri Siva Prasad Reddy & Shri Balachandran, Advocate, Revenue by : Ms. Nandini Das, CIT (DR) Date of hearing : 19.12.2025 Date of Pronouncement : 18.02.2025 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the order passed by the CIT(A)-15, BLR both dated 29/03/2024 for the assessment

SRI SRINIVASA TRUST,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BANGALORE

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

ITA 1075/BANG/2024[2020-21]Status: DisposedITAT Bangalore18 Feb 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Siva Prasad Reddy & Shri BalachandranFor Respondent: Ms. Nandini Das, CIT (DR)
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 2(45)Section 80G

B APPELLANT RESPONDENT Assessee by : Shri Siva Prasad Reddy & Shri Balachandran, Advocate, Revenue by : Ms. Nandini Das, CIT (DR) Date of hearing : 19.12.2025 Date of Pronouncement : 18.02.2025 O R D E R PER WASEEM AHMED, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the order passed by the CIT(A)-15, BLR both dated 29/03/2024 for the assessment

ARUN DURAISWAMY,MYSORE, KARNATAKA vs. ITO, INTL. TAXATION WARD 1(1), BANGALORE

In the result the appeal filed by the assessee is allowed

ITA 193/BANG/2025[2015-16]Status: DisposedITAT Bangalore16 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Deepak Gunashekar, A.RFor Respondent: Dr. Divya K.J, CIT D.R
Section 139Section 147Section 148Section 148ASection 149Section 69Section 69C

TDS by Mrs. Kalavathi K from her Central Bank of India IT(IT)A No.193/Bang/2025 Arun Duraiswamy, Mysore Page 6 of 23 account on 30/03/2015. The confirmation from Central Bank of India was also produced. The source for the funds in Central Bank of India was from gold loan taken- account A/c. No. 344549861. 3.2 During the assessment proceedings

M/S. ORIGAMI CELLULO PRIVATE LIMITED,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 5, BENGALURU

In the result, the appeal of the assessee is allowed

ITA 394/BANG/2020[2015-16]Status: DisposedITAT Bangalore15 Sept 2021AY 2015-16

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2015-16

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Pradeep Kumar, CIT(DR-III)(ITAT), Bengaluru
Section 142(1)Section 143(2)Section 143(3)Section 263Section 40A(2)(b)Section 92A(2)Section 92C

5 of 31 8. The ld. AR accordingly prayed that the impugned order of the PCIT should be quashed. 9. On the other hand, the ld. DR submitted that apart from the reasons mentioned in para 2 hereinabove for scrutiny, there were payments to related persons specified in section 40A(2)(b) duly reported in audit report and ITR filed

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

In the result, the appeal filed by the Revenue is dismissed

ITA 1498/BANG/2025[2016-17]Status: DisposedITAT Bangalore06 Nov 2025AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Vishal Bhat - CAFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)
Section 115JSection 211(2)

5(d) of the BR Act as under: ITA No.424/Mum/2020 & 3740/Mum/2018 The Union Bank of India & Central Bank of India 39 "(d) "company" means any company as defined in section 3 of the Companies Act, 1956 (1 of 1956); and includes a foreign company within the meaning of section 591 of that Act;" 47. Therefore

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK (ERSTWHILE SYNDICATE BANK), BANGALORE

In the result, the appeal filed by the Revenue is dismissed

ITA 1499/BANG/2025[2017-18]Status: DisposedITAT Bangalore06 Nov 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Vishal Bhat - CAFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)
Section 115JSection 211(2)

5(d) of the BR Act as under: ITA No.424/Mum/2020 & 3740/Mum/2018 The Union Bank of India & Central Bank of India 39 "(d) "company" means any company as defined in section 3 of the Companies Act, 1956 (1 of 1956); and includes a foreign company within the meaning of section 591 of that Act;" 47. Therefore

RAGHAVAN NAMBATH MENON,BENGALURU vs. ITO, WARD INTL. TAXATION 1(2), BMTC BUILDING, KORAMANGALA, BENGALURU

In the result, I pass the following:-

ITA 278/BANG/2025[2015-16]Status: DisposedITAT Bangalore06 Feb 2026AY 2015-16

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: CA Suresh Muthukrishnan, A.RFor Respondent: Dr. Divya K.J., CIT D.R
Section 143(2)Section 147Section 148Section 148ASection 149Section 149(1)(b)Section 68

2) and 142(1) of the Act were issued along with the Show Cause notice dated 05/12/2023 to the assessee. As observed by the AO, the assessee made only part compliances. 3.1 In the instant case, specific information was disseminated through the insight portal in accordance with the risk management strategy (RMS) formulated by the CBDT. As per the information

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

ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

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

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

ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18

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

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

ITA 499/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17

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