ANANTULA VIJAY MOHAN ,HYDERABAD vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, appeals filed by the assessee are allowed

Bench: Shri Laxmi Prasad Sahu\Nand\Nshri Keshav Dubey\Nita Nos.2059 & 2060/Bang/2024\N Assessment Years : 2016-17 & 2017-18\Nanantula Vijay Mohan\N9, Banjara Avenue Road\Nno.1, Banjara Hills\Nhyderabad 500 034\Npan No:Aelpm6515K\Nappellant\Nvs.\Ndcit\Ncircle-6(1)(1)\Nbangalore\Nrespondent\Nsp No.67/Bang/2024\N(Arising Out Of Ita No.2060/Bang/2024)\N Assessment Year: 2017-18\Nanantula Vijay Mohan\N9, Banjara Avenue Road\Nno.1, Banjara Hills\Nhyderabad 500 034\Npan No: Aelpm6515K\Nappellant\Nvs.\Ndcit\Ncircle-6(1)(1)\Nbangalore\Nrespondent\Nappellant By\Nrespondent By\N: Sri Padma Khincha, A.R.\N: Sri Sridhar E., D.R.\Ndate Of Hearing\Ndate Of Pronouncement:\N: 18.02.2025\N: 07.05.2025\Norder\Nper Laxmi Prasad Sahu:\Nthese Appeals At The Instance Of The Assessee Are Directed\Nagainst The Orders Of Ld. Cit(A)/Nfac, Delhi Both Dated 23.09.2024\Nvide Din & Order No. Itba/Nfac/S/250/2024-25/1068988279(1)\Nfor The Assessment Year 2016-17 & Vide Din & Order\Nno.Itba/Nfac/S/250/2024-25/1068999127(1) For The Assessment\Nyear 2017-18 Passed U/S 250 Of The Income Tax Act, 1961 (In Short\N\"The Act\"). Since Both These Appeals & The Stay Petition Are Of The\Nsame Assessee For The Different Assessment Years, These Are Clubbed\Ntogether, Heard Together & Disposed Of By This Common Order For\Nthe Sake Of Convenience & Brevity.\Nita No.2059/Bang/2024 (Ay 2016-17):\N2. First, We Take Up Ita No.2059/Bang/2024 For The Ay 2016-\N17 Wherein The Assessee Has Raised The Following Grounds Of Appeal:\N1. General\N1.

capital gain ('LTCG') of Rs.\n22,55,37,300/- arising from sale of bonus shares. The Assessee\nwas issued a notice under section 148 of the Act by the learned\nDeputy Commissioner of Income Tax, Circle 6(1)(1) (“AO”) on\n31.03.2021 to reassess the income for AY 2017-18. The notice\nrequired the Assessee to file a return

HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

144C(13) of the Act dated 15.01.2025, the assessee has filed the present appeal before this Tribunal. The assessee has also filed a paper book as well as case law compilation in support of his case. 5. Before us, the ld. A.R. of the assessee CA Siddesh N Gaddi vehemently submitted that only dispute in the present case is with

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

144C(13) of the Act dated 12.12.2024, the assessee has filed the present appeal before this Tribunal. The assessee has also filed a paper book in support of his case. 5. Before us, the ld. A.R. of the assessee vehemently submitted that the assessee had sold his house property at Delhi on 07/09/2015 and also made a booking for construction

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

capital gain of Rs.28,65,882/-in the financial year 2014-15 in the scrip of M/s GCM Securities Limited, M/s Unno Industries, M/s Pearl Electric Limited, M/s Mahaveer Advanced Rem and claimed the same as exempt u/s 10(38) of the act. During the course of search and seizure proceedings u/s 132 of the Act, it was found that

RAHUL AGARWAL ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION, CIRCLE-1(1) , BENGALURU

In the result, the appeal of the assessee is allowed as above

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahu

144C(15)(b). 3. The DRP/ AO, having accepted the fact that the Appellant 52,19,475 was resident in India during the relevant previous year, ought to have held that the AO had no jurisdiction to assess the Appellant. 4. The impugned order deserves to be quashed as the initiation 52,19,475 of proceedings under section 148 read

PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE 1(3), BENGALURU, BANGALORE

In the result the appeal of the assessee is allowed

Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)

capital gain income of Rs. 37,28,537/- on sale of sale of equity share / unit of equity oriented Mutual Fund under section 111A. 3.2 Subsequent to a survey conducted under section 133A, proceedings under section 147 of the Act were initiated accordingly notice under section 148 of the Act dated 25.03.2021 was issued, requiring the Assessee to file

M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

144C of the Income Tax Act, 1961 (the Act). The relevant M/s. Palmer Investment Group Ltd. assessment year is 2014-15. Common issues are raised in these appeals, hence they were heard together and are being disposed off by this consolidated order. 2. Facts pertaining to both the assessees are identical except for variation in figures. Therefore we are setting

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

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

144C of the Income Tax Act, 1961 (the Act). The relevant M/s. Palmer Investment Group Ltd. assessment year is 2014-15. Common issues are raised in these appeals, hence they were heard together and are being disposed off by this consolidated order. 2. Facts pertaining to both the assessees are identical except for variation in figures. Therefore we are setting

M/S. PRACTO TECHNOLOGIES PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal by the assessee is allowed

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

gain as operating in nature for the purpose of computing OP/TC of the Appellant and the OP/TC of the comparable companies remaining in the final set; 6.9. Erred in not providing appropriate adjustments to account for differences in working capital employed by the Appellant vis-a-vis the comparable companies. IT(TP)A No.154/Bang/2022 Page 5 of 28 6.10 Erred

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, BANGALORE

In the result, all the appeals filed by the assessee stands\npartly allowed and all the stay petitions filed by the assessee\nstands dismissed as infructuous

Capital gains\") for—\n(i) the transfer of all or any rights (including the granting of a\nlicence) in respect of a patent, invention, model, design,\nsecret formula or process or trade mark or similar property;\n(ii) the imparting of any information concerning the working\nof, or the use of, a patent, invention, model, design, secret\nformula or process

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU vs. ENZEN GLOBAL SOLUTIONS PVT LTD, BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K

144C of the IT Act, on 23.09.2021 at a total assessed income of Rs.56,09,42,530/- after making an addition of Rs.21,45,00,000/- on account of premium accrued on RPS under Income from other sources. 9. The ld. AR relied on the order of the Tribunal. 10. We have heard both the parties and perused the material

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. ENZEN GLOBAL SOLUTIONS PVT LTD , BENGALURU

In the result, the appeal of the Revenue is dismissed

Bench: Shri Chandra Poojari & Shri Soundararajan K

144C of the IT Act, on 23.09.2021 at a total assessed income of Rs.56,09,42,530/- after making an addition of Rs.21,45,00,000/- on account of premium accrued on RPS under Income from other sources. 9. The ld. AR relied on the order of the Tribunal. 10. We have heard both the parties and perused the material

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

144C(13) r.w.s. 144B of the Income-tax Act,1961 ['the Act' for short] for assessment year 2016-17 in pursuance of directions given by Ld Dispute Resolution Panel (DRP) dated 29.03.2021. IT(TP)A No.370/Bang/2021 Page 2 of 110 2. The brief facts of the case are that the assessee filed his return of income on 30.11.2016 declaring

MS. PUSPHA RAO PAMIDI,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), BANGALORE

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahums. Pushpa Rao Pamidi Vs Dcit, Circle - 2(1) No. 156/1, C/O T. Viswanath & Co Bengaluru Sharada Mansion, 2Nd Floor R V Road, V V Puram Bengaluru 560004 Pan – Bhhpp1695K (Appellant) (Respondent) Assessee By: Shri Sathish S., Advocate Revenue By: Ms. Neera Malhotra, Cit-Dr Date Of Hearing: 07.02.2023 Date Of Pronouncement: 08.02.2023 O R D E R Per: George George K., J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Final Assessment Order Dated 28.07.2022 Passed Under Section 143(3) R.W.S. 144C Of The Income Tax Act, 1961 (The Act). The Relevant Assessment Year Is 2018-19. 2. There Is A Delay Of Four Days In Filing This Appeal Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay & Also An Affidavit Stating Therein The Reasons For Belated Filing Of This Appeal. On Perusal Of The Reasons Stated In The Affidavit We Find That The Delay In Filing The Appeal Cannot Be Attributed To Any Latches On The Part Of The Assessee & There Is Sufficient Cause For Belated Filing Of This Appeal. Hence, We Condone The Delay Of Four Days & Proceed To Dispose Of The Case On Merits.

144C of the Income Tax Act, 1961 (the Act). The relevant assessment year is 2018-19. 2. There is a delay of four days in filing this appeal before the Tribunal. The assessee has filed a petition for condonation of delay and also an affidavit stating therein the reasons for belated filing of this appeal. On perusal of the reasons

CONCUR TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 2(2)(1), BANGALORE

Appeal of the assessee is partly allowed as indicated above

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2021-22

15. Accordingly, the assessment order under section 144 read with section 144C (13) read with section 144B of the act was passed on 25 October 2024 determining total income of the assessee at ₹ 460,090,995/–. Assessee is aggrieved with the same and is in appeal before us. 16. The assessee has submitted a detailed chart and the submissions

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, JAPAN

In the result, all the three appeals filed by assessee stands\npartly allowed

15-04-2024\nORDER\nPER BEENA PILLAI, JUDICIAL MEMBER\nPresent appeals are filed by assessee against the separate orders\npassed by the Ld.CIT(International Taxation), Circle 2(1),\nBangalore for A.Ys. 2013-14 to 2015-16.\nPage 2 of 32\nS.P. Nos. 7 to 9/Bang/2024 &\nIT(IT)A Nos. 100 to 102/Bang/2024\n2. Brief facts of the case

KDDI CORPORATION,JAPAN vs. DEPUTY COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION), CIRCLE 2(1), BANGALORE, KARNATAKA, BANGALORE

In the result, all the three appeals filed by assessee stands\npartly allowed

15-04-2024\nORDER\nPER BEENA PILLAI, JUDICIAL MEMBER\nPresent appeals are filed by assessee against the separate orders\npassed by the Ld.CIT(International Taxation), Circle 2(1),\nBangalore for A.Ys. 2013-14 to 2015-16.\nPage 2 of 32\nS.P. Nos. 7 to 9/Bang/2024 &\nIT(IT)A Nos. 100 to 102/Bang/2024\n2. Brief facts of the case

VAZHOOR SUDARSANAN THAMPI,THRISSUR vs. INCOME TAX OFFICER, (INTERNATIONAL TAXATION), WARD-2(1), BENGALURU

Appeal is partly allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan Ka. Y. 2015-16 Appellant Respondent Vazhoor Sudarshanan The Income Tax Officer Thampi International Taxation Vazhoor House, Ward 2 (1) T C 5/1892Valappad Bangalore Vallapad Beach Thrissur Kerala 680567 Pan Afxpt6193D For Appellant Shri Sidhesh N Gadi, Ca For Respondent Dr. Divya K J Cit Dr Date Of Hearing 19-08-2025 Date Of Pronouncement 28-08-2025

144C (7) of the act. The learned assessing officer submitting the remand report on 25/10/2024. In the remand proceedings, assessee submitted the computation of income for the assessment year 2015 – 16, passport, financial statements such as balance sheet, profit, and loss account. The assessee claimed that he is holding since long shares in three private limited companies and has provided

MARVELL INDIA PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

144C(1) of the Act on 29/09/2003 proposing the following additions/disallowance adjustments: a) Transfer Pricing (TP) adjustment amounting to Rs.16,00,55,328/- b) Disallowance of Depreciation claimed on Goodwill amounting to INR.3,08,21,235/- c) Addition on account of Free of Cost Assets amounting to INR.1,93,90,395/-, d) Addition