M/S WIPRO LTD. vs. ITO,

In the result, the appeals of the assessee are allowed and S

Bench: Shri Abraham P George & Shri Vijaypal Rao

TDS returns in Form No.27Q in respect of the payment to non-residents. The Assessing Officer issued an intimation giving the summary of short deduction and interest payable for delayed deposit of tax. The Assessing Officer along with an intimation under Section 200A has also issued a Demand Notice under Section 156 of the Act. Therefore, the assessee challenged

MR. VIKRAM DHONDU RAO, ,BANGALORE vs. DCIT, CIRCLE-4(1)(1), BANGALORE

In the result, appeal filed by the assessee in ITA No

Section 143(1) of the Act.\n5. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in confirming the denial of the relief u/s 90 of the Act amounting to Rs.15,20,710/-.\n6. That the learned Commissioner of Income Tax (Appeals) erred in law and on facts in concurring with the finding

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T, BANGALORE

In the result, Revenue’s appeal for A

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

90 amounting to Rs. 3,69,70,354/- which was claimed in the return of income. 10.2 The learned Commissioner of Income tax (Appeals)-I, Bangalore has erred in not allowing double taxation relief on account of variation of deduction under section 10A and consequent increase in income, as confirmed / sustained by the appellate order. 11.1 The learned Commissioner

INFOSYS LTD.,,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, Revenue’s appeal for Assessment Year 2006-07 is partly allowed for statistical purposes

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

90,949 are also liable for disallowance under Section 40(a)(ia) of the Act for non-deduction of TDS

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

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

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

TDS), Mysore – 570 018. Circle - 1(1), PAN : BLRBO 2644 F Bangalore. APPELLANT RESPONDENT Revenue by : Shri. R. N. Siddappaji, Addl. CIT Assessee by : Shri. R. E. Balasubramanyam, CA Date of hearing : 16.04.2019 Date of Pronouncement : 30.04.2019 O R D E R Per Jason P. Boaz, Accountant Member This appeal by Revenue is directed against the order

DY DIT vs. M/S INFOSYS BPO LTD.,,

In the result, all the appeals of the revenue and the cross

Bench: Shri Vijay Pal Rao & Shri Jason P Boaz

90(2) of the Act and that in the impugned cases of payments made to non-residents, assessee correctly applied the rate of tax prescribed under the DTAAs and not as per section 206AA of the Act because the 11 ITA No.1143/(B)2013 & IT(IT)A Nos.8 & 9-14 & CO Nos.83 & 84-14 provisions of the DTAAs was more

SHRI. VIKRAM DHONDU RAO ,BANGALORE vs. DCIT, CIRCLE-4(1)(1), BANGALORE

In the result, the appeal of the assessee in ITA

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

90 of the Act on the ground that the Form 67 was not filed. However, on becoming aware of the fact that the Form 67 has to be filed, the assessee filed the form-67 on 01/08/2020 vide e-filing acknowledgement number 437052681010820. 3.4 The assessee also filed an application u/s 154 of the Act before the AO praying

KAZYA WATANABE,BANGALORE vs. ASSISTANT DIRECTOR OF INCOME TAX, (CPC), , BANGALORE

In the result, the appeal is allowed

Bench: Shri Chandra Poojari & Shri George George Kassessment Year : 2021-22 Mr. Kazuya Watanabe, The Assistant Director Of Income Tax, Plot No.21, Toyota Kirloskar Auto Parts Centralized Processing Centre, Private Limited, Vs. Bengaluru. Bidadi Industrial Area, Ramanagara, Bengaluru – 562 109. Pan : Adfpw 5263 M Appellant Respondent Assessee By : Shri. Sarwan Kumar, Ca Revenue By : Shri. Sankar Ganesh, Addl. Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 06.06.2023 Date Of Pronouncement : 06.06.2023

section 90 of the Act to the extent of Rs.9,47,077/- and TDS of Rs.22,65,473/-. 3. The return

M/S MANTRI TECHNOLOGY CONSTELLATIONS PVT LTD ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the revenue’s appeal is dismissed and the assessee appeal is

Bench: Shri A.K. Garodia & Shri Pavan Kumar Gadaleit(It)A No.130/Bang/2018 (Assessment Year: 2014-15) M/S. Mantri Technology Constellations Pvt. Ltd., Mantri House, 41, Vittal Mallya Road, Bangalore-560001 ….Appellant Pan Aafcm 1653D Vs. Dy. Commissioner Of Income Tax, (International Transaction), Circle 1(2), Bangalore. ……Respondent. It(It)A No.384/Bang/2018 (Assessment Year: 2014-15) (By Revenue) Assessee By: Shri V. Srinivasan, Advocate. Revenue By: Shri H. Anand, Addl. Cit (D.R)

Section 90(2) of the Act and calculated the short deduction of TDS and interest and has determined the total

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

90,215/- under Section 201(1A) of the Act. 2.1. During the assessment year 2012-13 in ITA no.1151, the assessee created aggregate provision of Rs. 49,16,35,934/- towards various expenses. While computing the total income assessable for the assessment year 2012-13, the assessee suo moto disallowed the entire provision so created under Sections

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

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

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

90,215/- under Section 201(1A) of the Act. 2.1. During the assessment year 2012-13 in ITA no.1151, the assessee created aggregate provision of Rs. 49,16,35,934/- towards various expenses. While computing the total income assessable for the assessment year 2012-13, the assessee suo moto disallowed the entire provision so created under Sections

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

90,215/- under Section 201(1A) of the Act. 2.1. During the assessment year 2012-13 in ITA no.1151, the assessee created aggregate provision of Rs. 49,16,35,934/- towards various expenses. While computing the total income assessable for the assessment year 2012-13, the assessee suo moto disallowed the entire provision so created under Sections

SHASHIDHAR SEETHARAM SHARMA,BANGALORE vs. ASSISTANT DIRECTOR OF INCOME TAX OFFICER, CPC, BANGALORE

In the result, the appeal is allowed

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariassessment Year : 2017-18 Shri. Shashidhar Seetharam Sharma, Vs. Ito, Flat B002, Renaissance Brindavan, Cpc, Uttarahalli Main Road, Bengaluru. Bengaluru South, Bengaluru – 560 061. Pan : Ahwps 5221 Q Appellant Respondent Assessee By : Shri. Y. Sridhar, Ca Revenue By : Shri. K. Sankar Ganesh, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 19.09.2022 Date Of Pronouncement : 19.09.2022 O R D E R Per N. V. Vasudevan

TDS of Rs.1,28,925 in the return filed u/s 90/91. The return was processed u/s 143(1) and an intimation order dated 30-03-2019 was passed. The appellant subsequently filed Form No. 67 (statement of income from a country or specified territory outside India and Foreign Tax Credit) on 08-02-2020 and made a rectification application

DEPUTY COMMISSIONER OF INCOME TAX, (INTERNATIONAL TAXATION), CIRCLE- 1(2), BANGALORE vs. M/S. MANTHAN SOFTWARE SERVICES PRIVATE LIMITED, BANGALORE

In the result, all the five appeals filed by the assessee are allowed for statistical purposes and all the five appeals filed by the revenue are dismissed

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

section 90 (2) of I T Act and therefore, the rate prescribed under DTAA or Act whichever is lower is applicable. We would like to observe that we have restored back the matter to the file of ld. CIT(A) for fresh decision regarding the requirement of TDS

M/S MANTHAN SOFTWARE SERVICES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, all the five appeals filed by the assessee are allowed for statistical purposes and all the five appeals filed by the revenue are dismissed

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

section 90 (2) of I T Act and therefore, the rate prescribed under DTAA or Act whichever is lower is applicable. We would like to observe that we have restored back the matter to the file of ld. CIT(A) for fresh decision regarding the requirement of TDS

M/S MANTHAN SOFTWARE SERVICES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, all the five appeals filed by the assessee are allowed for statistical purposes and all the five appeals filed by the revenue are dismissed

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

section 90 (2) of I T Act and therefore, the rate prescribed under DTAA or Act whichever is lower is applicable. We would like to observe that we have restored back the matter to the file of ld. CIT(A) for fresh decision regarding the requirement of TDS

M/S MANTHAN SOFTWARE SERVICES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, all the five appeals filed by the assessee are allowed for statistical purposes and all the five appeals filed by the revenue are dismissed

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

section 90 (2) of I T Act and therefore, the rate prescribed under DTAA or Act whichever is lower is applicable. We would like to observe that we have restored back the matter to the file of ld. CIT(A) for fresh decision regarding the requirement of TDS

M/S MANTHAN SOFTWARE SERVICES PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, all the five appeals filed by the assessee are allowed for statistical purposes and all the five appeals filed by the revenue are dismissed

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

section 90 (2) of I T Act and therefore, the rate prescribed under DTAA or Act whichever is lower is applicable. We would like to observe that we have restored back the matter to the file of ld. CIT(A) for fresh decision regarding the requirement of TDS