DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

In the result, appeal filed by the assessee is partly allowed and the appeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

capital fund. Thus, it is evident that interest on NCDs, interest on loan to Subsidiaries, interest on debentures, interest on Govt securities, interest on tax refunds, insurance claim, incentive from airlines and rental income from BSNL are offered to tax under the head Profits and gains of business and not under the head Income from other sources

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

In the result, appeal filed by the assessee is partly allowed and the\nappeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\N\N\Nita No. 881/Bang/2023\N Assessment Year: 2019-20\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nvs.\N\Ndy. Commissioner Of Income Tax\Ncircle - 3(1)(1)\Nbmtc Building, 80 Feet Road\Nkoramangala, Bangalore – 560095\Nkarnataka\N\Nrespondent\N\Nita No. 245/Bang/2024\N Assessment Year: 2019-20\N\Njt. Commissioner Of Income Tax (Osd)\Ncircle - 3(1)(1)\Nroom No. 241, 2Nd Floor\Nbmtc Building, 80 Feet Road\N6Th Block, Koramangala\Nbangalore - 560095\Nkarnataka\N\Nvs.\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nrespondent\N\Nassessee By\Ndepartment By\N\Nsri Padam Chand Khincha – Ca\Nsmt. Srinandini Das – Cit - Dr\N\Ndate Of Hearing\Ndate Of Pronouncement:\N\N09.05.2025\N06.08.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Cross Appeals Are Filed Against The Order Of Ld. Commissioner Of\Nincome Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short \"Ld.\Ncit(A)/Nfac] Vide Din & Order No. Itba/Nfac/S/250/2023-24/1056786183(1) Dated 05.10.2023 Passed U/S.250 Of The Income Tax\Nact, 1961 (In Short “The Act\") For The A.Y.2019-20.\N\Npage 2 Of 34\N\N2. The Assessee Has Raised The Following Grounds Of Appeal: - \N\N\"1.\N\Ngeneral Ground\N\N1.

capital fund. Thus, it is evident\nthat interest on NCDs, interest on loan to Subsidiaries, interest on\ndebentures, interest on Govt securities, interest on tax refunds, insurance\nclaim, incentive from airlines and rental income from BSNL are offered to tax\nunder the head Profits and gains of business and not under the head\nIncome from other sources

TATA ELXSI LIMITED ,BANGALORE vs. DEPUTY COMMISIONER INCOMER TAX, CIRCLE-7(1)(1), BANGALORE

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

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahuassessment Year : 2018-19 M/S. Tata Elxsi Ltd., The Deputy 126, Itpb Road, Commissioner Hoody, Of Income Tax, Whitefield, Circle – 7(1)(1), Bangalore – 560 048. Bangalore. Vs. Pan: Aaact7872Q Appellant Respondent

capital gains and income from other sources. Insofar as income under the head 'profits and gains of business or professions' is concerned, provisions thereto are contained in Sections 28 to 44DB of the Act. Section 28 specifies various incomes which shall be chargeable to income tax under this head. Thereafter, Section 29 provides that income referred to in Section

M/S. TATA ELXSI LIMITED., ,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

In the result, all the appeals of the assessee are partly allowed for statistical purposes

Bench: Shri George George K. & Shri Chandra Poojari

capital gains and income from other sources. Insofar as income under the head 'profits and gains of business or professions' is concerned, provisions thereto are contained in Sections 28 to 44DB of the Act. Section 28 specifies various incomes which shall be chargeable to income tax under this head. Thereafter, Section 29 provides that income referred to in Section

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

gains of the business for the assessment year 1981-82. 2. The assessee had, in the course of the assessment proceedings for the assessment year 1981-82, claimed the deduction of Rs. 10,542 which amount had heed paid by it to the Income-tax Department as interest under section 201(1A). The claim so made was rejected

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

gains of the business for the assessment year 1981-82. 2. The assessee had, in the course of the assessment proceedings for the assessment year 1981-82, claimed the deduction of Rs. 10,542 which amount had heed paid by it to the Income-tax Department as interest under section 201(1A). The claim so made was rejected

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

gains of the business for the assessment year 1981-82. 2. The assessee had, in the course of the assessment proceedings for the assessment year 1981-82, claimed the deduction of Rs. 10,542 which amount had heed paid by it to the Income-tax Department as interest under section 201(1A). The claim so made was rejected

M/S. TATA ELXSI LIMITED,BANGALORE vs. DEPUTY COMMISSIONER INCOME TAX, CIRCLE-7(1)(1), BANGALORE

10A which also\ncontains similar provision) that the deduction is to be allowed from the total\nincome of the undertaking and not from the total income of the assessee.\nIn view of the above, it is proposed to clarify that the amount of deduction referred\nto in section 10AA shall be allowed from the total income of the assessee computed

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

capital expenditure and it is only a revenue expenditure. Further, in the following decision it was held that study undertaken in IT(TP)A No.370/Bang/2021 Page 26 of 110 relation to an existing business is revenue in nature. [CIT v. Manganese Ore India Ltd [2016] 67 Taxmann.com 268 (Bombay), ITO v. Dodsal Mfg P Ltd [1984] 19 Taxman 27 (Ahmedabad

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

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA 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

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

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

Accordingly, the appeal filed by the assessee is also allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

capital fund and other miscellaneous income of Rs. 10,500. Thus, it is evident that interest on NCDs, interest on loan to Subsidiaries, interest on Govt securities, interest on tax refund, interest on govt. bonds & CST refund, incentives received and other miscellaneous incomes are offered to tax under the head Profits and gains of business and not under the head

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

Accordingly, the appeal filed by the assessee is also allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

capital fund and other miscellaneous income of Rs. 10,500. Thus, it is evident that interest on NCDs, interest on loan to Subsidiaries, interest on Govt securities, interest on tax refund, interest on govt. bonds & CST refund, incentives received and other miscellaneous incomes are offered to tax under the head Profits and gains of business and not under the head

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

capital, raw materials, and technology. It encompasses a wide range of activities. The Oxford English Dictionary defines "production" as “that which is produced; a thing that results from any action, process, or effort; a product of human activity or effort.” 14.3 The Hon’ble Supreme Court, in the case of CIT vs. N.C. Budharaja & Co. (204 ITR 412), observed that

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

capital, raw materials, and technology. It encompasses a wide range of activities. The Oxford English Dictionary defines "production" as “that which is produced; a thing that results from any action, process, or effort; a product of human activity or effort.” 14.3 The Hon’ble Supreme Court, in the case of CIT vs. N.C. Budharaja & Co. (204 ITR 412), observed that

M/S DELL INTERNATIONAL SERVICES INDIA PVT LTD ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTPU , BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital adjustment shall be carried out in the light of above order of the Tribunal. Ordered accordingly. IT(TP)A No.2846/Bang/2017 M/s. Dell International Services India Pvt. Ltd., Bangalore Page 20 of 47 16. With regard to Ground Nos.5 & 6, no argument has been put before us by the ld. A.R., hence not considered for adjudication. 17. Ground No.7

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

In the result, the appeal of the assessee is hereby partly allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

gains in labor productivity in services. (refer p 472-473 of DRPB) 10. Hence, it was felt that the unusual path may lead to vulnerability of Indian Economy to ups and downs of global economy. The reason being service industries are foot loose industries where as manufacturing industries are not. In addition, employment growth is inadequate and is not matching

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

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

Capital Gains |\n| 0 |\n| 0 |\n| 0 |\n| 0 |\n| Other Sources |\n| 0 |\n| 0 |\n| 0 |\n| 0 |\n| Total |\n| 7600800 |\n| 1520710 |\n| 2475880 |\n| 1520710 |\n\nIndonesia and claimed a foreign tax credit (FTC) of Rs.15,20,710/- which was deducted as tax at source by the employer in Indonesia and disclosed the same

SANGHAMITRA RURAL FINANCIAL SERVICES,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, EXEMPTIONS CIRCLE-1, BANGALORE

In the result, appeals of the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Madhumita Roy

capital so as to advance the loan. Borrowed funds of the assessee have been utilised to lend loans to the public and the rate of interest charged is with a view to generate profit. xv. The ld. A.R. submitted that the learned assessing officer has held that the assessee is engaged in business activity and denied the exemption under section