AJITH M KUMAR,BANGALORE vs. DCIT, CIRCLE-3(3)(1), BANGALORE

In the result, Appeal filed by the Assessee is allowed for statistical purposes

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2018-19

TDS was granted. 3. The Assessee preferred an Appeal before the Ld. CIT(A) wherein he filed a detailed written statement stating that due to the death of his father and ill health of his mother, assessee could not file return of income. The Assessee submitted that his salary income is Rs. 32,45,753/- after considering the HRA exemption

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

The appeal of the assessee is partly allowed, whereas the revenue’s appeal is dismissed

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2013-14

80-IA of the Act. 3. The CIT(A) have erred in law and on facts in holding that the appellant has formed joint venture partnerships (JV) with the third parties and have earned revenue share from the entire JV activity, instead of letting out the space at reasonable rate and therefore considered the same as ineligible income under section

M/S. BANGALORE INTERNATIONAL AIRPORT LIMITED,BANGALORE vs. COMMISSIONER OF INCOME TAX (APPEALS)- 1, BANGALORE

The appeal of the assessee is partly allowed, whereas the revenue’s appeal is dismissed

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2013-14

80-IA of the Act. 3. The CIT(A) have erred in law and on facts in holding that the appellant has formed joint venture partnerships (JV) with the third parties and have earned revenue share from the entire JV activity, instead of letting out the space at reasonable rate and therefore considered the same as ineligible income under section

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

TDS credit AO to verify and allow Foreign tax credit of Rs. 96,55,80,804 includes an amount of Rs. 68,14,32,706 which is under dispute before the Australian Tax Authorities. As per section

SHRI MAHAVEER CO-OPERATIVE CREDIT SOCIETY LTD,ALAGUR vs. INCOME TAX OFFICER, ALAGUR

In the result, the appeal by the assessee is allowed for statistical purposes\nPronounced in the open court on this 25th day of July, 2025

TDS, therefore\n30% of 75,000 i.e., Rs.22,500 was further disallowed. Accordingly assessment\norder was passed u/s.143(3) of the Act on 29.11.2018. Accordingly, total income\nof was computed at Rs.19,33,151/-.\n4.\nThe assessee aggrieved with the same, preferred appeal before the ld. CIT(A). It\nwas submitted that the amount of investment made by the assessee

SRI KRISHNARAJENDRA CHARITABLE TRUST,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), BENGALURU

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

Bench: Shri B.R.Baskaran & Smt.Beena Pillai, Judical Member Sri.Krishnarajendra Charitable The Commissioner Of Income Tax (Exemptions) Trust, Bangalore Bangalore Palace Compound, Vs. Jayamahal Road, Jc Nagar, Bangalure, Karnataka, 560006 Pan : Aabtc808K Appellant Respondent

section 80 G (5) (vi) of the Act to Ld.CIT (E) for fresh consideration the light of decisions referred to herein above. Needless to say that Ld.CIT(E) will afford proper opportunity of being heard to assessee in accordance with law. Accordingly grounds raised by assessee stands allowed for statistical purposes. In the result, appeal filed by assessee stands allowed

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-

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS. 6. The next argument put-forth by the learned representative was that specific provisions prevail over general provisions. As per the learned representative, Section 194BB of the Act is a specific provision applicable in case of winnings from horse races. It is contended that a specific provision overrules a general provision, provided both the provisions operate in the same

M/S. CHIRANTHANA,BENGALURU vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), BENGALURU

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

Bench: Shri B.R.Baskaran & Smt.Beena Pillai, Judical Member M/S. Chiranthana The Commissioner Of F-25, 1St Floor, Income Tax (Exemptions) Shriram Sardhana Apartments, Bangalore Behind M.S Ramaiya Residency, Vs. Bangalure, Karnataka, 560006 Pan : Aabtc808K Appellant Respondent

section 80 G (5) (vi) of the Act to Ld.CIT (E) 6 for fresh consideration the light of decisions referred to herein above. Needless to say that Ld.CIT(E) will afford proper opportunity of being heard to assessee in accordance with law. Accordingly grounds raised by assessee stands allowed for statistical purposes. In the result, appeal filed by assessee stands

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 40(a)(ia) of the Act, observed that assessee debited TDS of ₹ 36,80,465/- in respect of part

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 40(a)(ia) of the Act, observed that assessee debited TDS of ₹ 36,80,465/- in respect of part

SAP INDIA PRIVATE LIMITED ,BANGALORE vs. COMMISSIONER INCOME TAX (A) BANGALORE-6, BANGALORE

In the result, both the appeals of the assessee are partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

80-IC unit has been recomputed at Rs.42,77,77,145/- and deduction claimed on the said sum u/s.80-IC of the Act. On examination of the claim, the AO found that the assessee has disallowed a sum of Rs.11,65,08,868/- on account of non-deduction of TDS by invoking the provisions of section

SAP INDIA PRIVATE LIMITED,BANGALORE vs. COMMISSIONER INCOME TAX (A) BANGALORE-6, BANGALORE

In the result, both the appeals of the assessee are partly allowed

Bench: Shri N.V. Vasudevanand Shri B. R. Baskaran

80-IC unit has been recomputed at Rs.42,77,77,145/- and deduction claimed on the said sum u/s.80-IC of the Act. On examination of the claim, the AO found that the assessee has disallowed a sum of Rs.11,65,08,868/- on account of non-deduction of TDS by invoking the provisions of section

M/S. WIPRO LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

section 10A." Thus it is clear that the Tribunal has followed the earlier order for the Assessment Year 2004-05 which has been upheld by the Hon'ble jurisdictional High Court. Following the earlier order of this Tribunal as well as Hon'ble jurisdictional High Court, we decide this issue in favour of the assessee and against the revenue

WIPRO LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

section 14A as computed under Rule 8D(2)(iii) cannot be more than the actual expenditure which can be relatable for earning the exempt income and debited to the Profit and Loss account. In the case on hand the disallowance made by the assessee on its own is not the total expenditure debited to the profit and loss account

M/S.METROPOLITAN MEDIA COMPANY LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, HUBLI

In the result, appeal filed by the revenue is dismissed

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadale

TDS under Section 194C of the Act, and applied the provisions of Section 40(a)(ia) of the Act and disallowed an amount of Rs.6,80

M/S. IBM INDIA PVT. LTD.,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-4(1)(2), BENGALURU

In the result appeal filed by assessee stands partly allowed

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

80 IC(4), which is pari materia to section 10AA(4). We have perused decision of Hon’ble Supreme Court in case of DCIT, Bangalore vs.ACE Multi Axes Sysrems Ltd., reported in (2018) 400 ITR 141, relied by Ld.Standing Cousel for revenue. Hon’ble Supreme Court in this case was considering claim u/s.80IB(2). Hon’ble Court observed as under

M/S. JITO BELGAUM CHAPTER,BELAGAVI vs. THE COMMISSIONER OF INCOME TAX (EXEMPTIONS), BENGALURU

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

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiassessment Year : 2019 – 20

section 80 G (5) (vi) of the Act to Ld. CIT (E) for fresh consideration the light of decisions referred to herein above. Needless to say, that Ld. CIT(E) will afford proper opportunity of being heard to assessee in accordance with law. Accordingly grounds raised by assessee stands allowed for statistical purposes. In the result, appeal filed by assessee

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

80 taxmann.com 123;  Decision of Coordinate Bench of this Tribunal in case of ACIT v. Acer India (P.) Ltd. by Order dated 05.10.2018 passed by this Hon’ble Tribunal in ITA No. 1940/Bang/2018). Page 13 ITA Nos. 1644/Bang/2014, 1151/Bang/2015 & 2035/Bang/2016 On the contrary, the Ld.DR submitted that even though the amount of expenses have not been crystallised, TDS was liable