MR. PRAKASH CHAND BETHALA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 7(1), BANGALORE

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2007-08

16A of that Act.” 6. Before the Assessing Officer, the assessee argued that the provisions of section 50C are applicable prospectively and not retrospectively. The assessee submitted that possession by transfer having been completed in 1989, the provisions of section 50C will not be applicable. According to the assessee, the provisions of section 50C of the Act comes with reference

SURESH SONNAHALLIPURA NARAYANASWAMY,BENGALURU vs. INCOME TAX OFFICER WARD - 5 (73) (7), BENGALURU

Bench: Shri. Jason P. Boaz & Shri. Laliet Kumar

gains and the other as 1(b), 3(a), 3(b) and 3(c) in respect of addition towards denial of deduction u/s.54F of the Act. 05. The first set of grounds viz., 1(a), 2(a), 2(b) and 2(c). In this regard, submission before us was as under : The assessee is the owner of land along with

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, HUBBALLI, HUBBALLI vs. SMT. SHEELA PRASANNAKUMAR , CHITRADURGA

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K

16A, clause (i) of sub-section (1) and sub-sections (6) and (7) of section 23A, sub-section (5) of section 24, section 34,4A,, section 35 and section 37 of the Wealth-tax Act. 1957 (27 of 1957). shall, with necessary modifications, apply in relation to such reference as they apply in relation to a reference made

BENEDICTA MARY MENDONCE,BANGALORE vs. INCOME TAX OFFICER, WARD- 3(3)(3), BANGALORE

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

Bench: Shri N.V.Vasudevan & Shri B.R.Baskaran

16A of that Act. Explanation 1.—For the purposes of this section, "Valuation Officer" shall have the same meaning as in clause (r) of section 2 of the Wealth-tax Act, 1957 (27 of 1957). Explanation 2.—For the purposes of this section, the expression "assessable" means the price which the stamp valuation authority would have, notwithstanding anything

AJIT VASANT PAI,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CPC, BANGALORE

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

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2017-18

6. In April 2019, the Assessee received an intimation under section 143(1)(a) approving all the reversals of adjustments proposed, except the Due date of filing as 07.11.2017 was not accepted by the Assessing Officer Page 3 of 9 and the Carry forward loss was disallowed. The Assessee filed for Rectification and reprocessing of return of income under section

DR. VIJAYALAKSHMI L ,BANGALORE vs. INCOME TAX OFFICER, WARD-2(2)(3), BANGALORE

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

Bench: Smt. Beena Pillaiassessment Year : 2020-21 Dr. Vijayalakshmi L, No. 730/D, “Sireesha”, The Income Tax 9Th Cross, 4Th Main, Officer, M C Layout, Ward – 2(2)(3), Vijayanagar, Bangalore. Bangalore – 560 040. Vs. Pan: Acjpv2022J Appellant Respondent

gains were 6,01,261). The learned CIT(A) failed to appreciate that the data entered in the form was accurate and the processing has been made erroneously and the adjustment ought to have been deleted in full, on the facts and circumstances of the case. 8. The Appellant denies the liability to pay interest under section 234B

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE vs. M/S THOUGHT WORKS TECHNOLOGIES INDIA PRIVATE LIMITED , BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

gains of business. To this extent, the Assessing Officer was clearly in error in treating the loss on foreign exchange as a notional loss not deductible in computation of business income. Learned CIT(A) rightly reversed the action of the Assessing Officer in this regard. 2.9 Since the transaction in EEFC account undertaken during the year are trading in nature

THOUGHTWORKS TECHNOLOGIES (INDIA) PRIVATE LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE -7(1)(1), BANGALORE

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

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

gains of business. To this extent, the Assessing Officer was clearly in error in treating the loss on foreign exchange as a notional loss not deductible in computation of business income. Learned CIT(A) rightly reversed the action of the Assessing Officer in this regard. 2.9 Since the transaction in EEFC account undertaken during the year are trading in nature

M/S CHITRAKALA INVESTMENT TRADE & BUSINESS FINANCE LTD.,,MANIPAL vs. DCIT, UDUPI

In the result, the appeals filed by all the assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava1. 2. 3. 1. M/S.Mangala Investments Ltd. Syndicate House, Manipal-576 104. Pan: Aaacm 8838 R 2. M/S.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. Pan:Aaccs 4700 N 3. M/S.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. Pan: Aaacc 7246 H ... Appellant Vs. Deputy Commissioner Of Income-Tax, Circle-1, Udupi. ... Respondent Assessees By : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, Cit(A) Date Of Hearing : 30/01/2017 Date Of Pronouncement : 01/05/2017 O R D E R Per Inturi Rama Rao, Am : These Are Appeals Filed By Three Assessees Against Identical Orders Of The Cit(A), Mysore, For The Assessment Year 1996-97. Ita Nos.1322 To 1324/Bang/2012 Page 2 Of 14 2. Since In All These Appeals Common Issues Are Involved, We Propose To Dispose Of The Same Vide This Consolidated Order For The Sake Of Convenience.

6 of 14 assessee-company as investment and therefore, any profit or loss arising out of transfer of such shares is clearly taxable under the head ‘capital gains’. 3.3 As regards the issue of determination of consideration, it is undisputed fact that in terms of award given by late C.Subramanian, consideration is determined at the rate of fRs.220 per share

M/S MANGALA INVESTMENTS LTD.,,MANIPAL vs. DCIT, UDUPI

In the result, the appeals filed by all the assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava1. 2. 3. 1. M/S.Mangala Investments Ltd. Syndicate House, Manipal-576 104. Pan: Aaacm 8838 R 2. M/S.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. Pan:Aaccs 4700 N 3. M/S.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. Pan: Aaacc 7246 H ... Appellant Vs. Deputy Commissioner Of Income-Tax, Circle-1, Udupi. ... Respondent Assessees By : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, Cit(A) Date Of Hearing : 30/01/2017 Date Of Pronouncement : 01/05/2017 O R D E R Per Inturi Rama Rao, Am : These Are Appeals Filed By Three Assessees Against Identical Orders Of The Cit(A), Mysore, For The Assessment Year 1996-97. Ita Nos.1322 To 1324/Bang/2012 Page 2 Of 14 2. Since In All These Appeals Common Issues Are Involved, We Propose To Dispose Of The Same Vide This Consolidated Order For The Sake Of Convenience.

6 of 14 assessee-company as investment and therefore, any profit or loss arising out of transfer of such shares is clearly taxable under the head ‘capital gains’. 3.3 As regards the issue of determination of consideration, it is undisputed fact that in terms of award given by late C.Subramanian, consideration is determined at the rate of fRs.220 per share

M/S SEA ROCK INVESTMENTS LTD.,,MANIPAL vs. DCIT, UDUPI

In the result, the appeals filed by all the assessees are dismissed

Bench: Shri Inturi Rama Rao & Shri Sudhanshu Srivastava1. 2. 3. 1. M/S.Mangala Investments Ltd. Syndicate House, Manipal-576 104. Pan: Aaacm 8838 R 2. M/S.Sea Rock Investments Ltd., Syndicate House, Manipal-576104. Pan:Aaccs 4700 N 3. M/S.Chitrakala Investments Trade & Business Finance Ltd. Syndicate House, Manipal-576104. Pan: Aaacc 7246 H ... Appellant Vs. Deputy Commissioner Of Income-Tax, Circle-1, Udupi. ... Respondent Assessees By : Ms. Prathibha, Advocate. Respondent : Dr.Shakir Hussain, Cit(A) Date Of Hearing : 30/01/2017 Date Of Pronouncement : 01/05/2017 O R D E R Per Inturi Rama Rao, Am : These Are Appeals Filed By Three Assessees Against Identical Orders Of The Cit(A), Mysore, For The Assessment Year 1996-97. Ita Nos.1322 To 1324/Bang/2012 Page 2 Of 14 2. Since In All These Appeals Common Issues Are Involved, We Propose To Dispose Of The Same Vide This Consolidated Order For The Sake Of Convenience.

6 of 14 assessee-company as investment and therefore, any profit or loss arising out of transfer of such shares is clearly taxable under the head ‘capital gains’. 3.3 As regards the issue of determination of consideration, it is undisputed fact that in terms of award given by late C.Subramanian, consideration is determined at the rate of fRs.220 per share

CONTINENTAL AUTOMOTIVE COMPONENTS INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX,CIRCE-2(1)(1), BANGALORE

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

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

6,62,43,531 12,23,86,607 8,80,23,884 2018-19 12,23,86,607 5,92,84,235 10,89,18,707 7,27,52,135 (4,96,34,472) 2019-20 7,27,52,135 1,38,44,824 2,93,18,763 5,72,78,196 (1,54,73,939) 24.1 For the year

JUBILANT BIOSYS LIMITED,NOIDA vs. ITO, BANGALORE

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

16A, (International Taxation), Noida-201301(UP) Ward 1(2), PAN: AAACJ 9445 P Bengaluru. 4 610/Bang/2010 -do- -do- (2007-08) 5 157/Bang/2010 -do- -do- (2008-09) 6 611/Bang/2010 -do- -do- (2008-09) Assessee by : Shri Kaushik Mukherjee, CA. Revenue by : Dr. P.V.Pradeep Kumar, Addl.CIT Date of hearing : 08/01/2018 Date of pronouncement : 23/03/2018 O R D E R Per BENCH : These

ANZ OPERATIONS AND TECHNOLOGY PRIVATE LIMITED,BANGALORE vs. DDIT, BANGALORE

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

16A, (International Taxation), Noida-201301(UP) Ward 1(2), PAN: AAACJ 9445 P Bengaluru. 4 610/Bang/2010 -do- -do- (2007-08) 5 157/Bang/2010 -do- -do- (2008-09) 6 611/Bang/2010 -do- -do- (2008-09) Assessee by : Shri Kaushik Mukherjee, CA. Revenue by : Dr. P.V.Pradeep Kumar, Addl.CIT Date of hearing : 08/01/2018 Date of pronouncement : 23/03/2018 O R D E R Per BENCH : These

JUBILANT BIOSYS LIMITED,NOIDA vs. ITO, BANGALORE

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

16A, (International Taxation), Noida-201301(UP) Ward 1(2), PAN: AAACJ 9445 P Bengaluru. 4 610/Bang/2010 -do- -do- (2007-08) 5 157/Bang/2010 -do- -do- (2008-09) 6 611/Bang/2010 -do- -do- (2008-09) Assessee by : Shri Kaushik Mukherjee, CA. Revenue by : Dr. P.V.Pradeep Kumar, Addl.CIT Date of hearing : 08/01/2018 Date of pronouncement : 23/03/2018 O R D E R Per BENCH : These

ANZ OPERATIONS AND TECHNOLOGY PRIVATE LIMITED,BANGALORE vs. DDIT, BANGALORE

Bench: Shri Sunil Kumar Yadav & Shri Inturi Rama Rao

16A, (International Taxation), Noida-201301(UP) Ward 1(2), PAN: AAACJ 9445 P Bengaluru. 4 610/Bang/2010 -do- -do- (2007-08) 5 157/Bang/2010 -do- -do- (2008-09) 6 611/Bang/2010 -do- -do- (2008-09) Assessee by : Shri Kaushik Mukherjee, CA. Revenue by : Dr. P.V.Pradeep Kumar, Addl.CIT Date of hearing : 08/01/2018 Date of pronouncement : 23/03/2018 O R D E R Per BENCH : These

DCIT, BANGALORE vs. M/S AKAMAI TECHNOLOGIES INDIA PVT. LTD.,, BANGALORE

In the result, appeal by the Revenue is dismissed, while the appeal by the assessee is treated as allowed for statistical purpose while the Cross

Bench: Shri N.V.Vasudevan & Shri B.R.Baskaran

16A and consequent erroneous levy of interest under Sections 234B and C of the Act; and (d) Non-grant of interest under Section 244A of the Act. 3. As far as the issue with regard to Transfer Pricing Adjustment and consequent addition to the total income in respect of an international transaction between the Assessee and its Associate Enterprise

AKAMAI TECHNOLOGIES INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, appeal by the Revenue is dismissed, while the appeal by the assessee is treated as allowed for statistical purpose while the Cross

Bench: Shri N.V.Vasudevan & Shri B.R.Baskaran

16A and consequent erroneous levy of interest under Sections 234B and C of the Act; and (d) Non-grant of interest under Section 244A of the Act. 3. As far as the issue with regard to Transfer Pricing Adjustment and consequent addition to the total income in respect of an international transaction between the Assessee and its Associate Enterprise