ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU vs. HIREHAL JAIRAJ BALRAM, BENGALURU

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

gain\nwhich arises from the transfer of a capital asset, which\ncould be brought to tax under Section 45 read with Section\n48 of the Income Tax Act.\n13. The assessee in the affidavit explaining the delay in filing the\nappeal late before the Tribunal has also mentioned the\nfactual aspects and the legal dispute and has stated on oath

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

172 DTR 261 (Delhi), (2018) 68 ITR 58 (Delhi) with ITA Nos 2558/2012 and 2044 and 2045/2014 dated 20.11.2018, the ITAT dismissed the appeals of Spaze Towers Pvt Ltd, thereby upholding the penalties imposed under Section 271(1)(c) of the Income Tax Act, 1961, for non- disclosure of income. These penalties were based on the company's failure

MUSTAFA ASIF MASOOD ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(3)(2), BANGALORE

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

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2018-19 Shri. Mustafa Asif Masood, Vs. Ito, 145, 5Th Main, 7Th Sector, Hsr Layout, Ward – 4(3)(2), Bangalore – 560 034, Karnataka. Bangalore. Pan : Aorpm 0736 L Appellant Respondent Assessee By : Shri. Satish C, Ca Revenue By : Shri. Ashwin D Gowda, Addl. Cit(Dr)(Itat), Bangalore. Date Of Hearing : 29.07.2025 Date Of Pronouncement : 31.07.2025

172/-, assessee did not offer capital gain. Therefore, the difference amount of Rs.11,99,887/- was also added as short term capital gain and assessment was completed under section

JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 6, BANGALORE vs. M/S. SAMSUNG R & D INSTITUTE INDIA -BANGALORE PRIVATE LIMITED, BANGALORE

In the result, the appeals filed by the assessee as per revised\ngrounds stands allowed and the appeals filed by the revenue\nstands dismissed for the years under consideration

capital\nexpenditure, but only condition is that if certain amount is\nclaimed as deduction either by way of debiting to the P&L\naccount or by way of depreciation u/s 32 without effecting\nTDS on such payments, the same can be disallowed.\n5.6 In view of the aforementioned statutory position, it is\namply clear that by virtue of section

M/S SAMSUNG R & D INSTITUTE INDIA BANGALORE PRIVATE LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX CIRCLE-6(1)(1), BANGALORE

In the result, the appeals filed by the assessee as per revised\ngrounds stands allowed and the appeals filed by the revenue\nstands dismissed for the years under consideration

capital\nexpenditure, but only condition is that if certain amount is\nclaimed as deduction either by way of debiting to the P&L\naccount or by way of depreciation u/s 32 without effecting\nTDS on such payments, the same can be disallowed.\n5.6 In view of the aforementioned statutory position, it is\namply clear that by virtue of section

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

172,31,17,307/- made under section 32AC of the Act. 7. The aggrieved assessee preferred an appeal before the learned CIT(A) who after following the order of the Tribunal in the own case of the assessee for A.Y. 2014-15 & 2015-16 bearing ITA Nos. 125 & 126/Bang/2019, confirmed the disallowance made by the AO. 8. Being aggrieved

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

capital gain earned. He submits that the sum of Rs. 1,81,03,143/– is the undisputed sale consideration received by the assessee which was deposited in the non-resident external account with the federal bank received from the buyer Dr Gopalan. Out of that sum the sum of Rs 1,60,00,000/- was deposited for opening non-resident

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. LATE SHRI V G SIDDHARTHA, REPRESENTED BY LEGAL HEIR MS. MALVIKA HEGDE, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

gains. The AO also pointed out that as per the original debenture purchase agreement, the holder of debentures was entitled to a coupon payment at 13.75%. However, no such coupon or interest income was realized or considered at the time of redemption. The assessee’s claim that waiver of interest was based on an informal agreement was found

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

gains. The AO also pointed out that as per the\noriginal debenture purchase agreement, the holder of debentures was\nentitled to a coupon payment at 13.75%. However, no such coupon or\ninterest income was realized or considered at the time of redemption.\nThe assessee’s claim that waiver of interest was based on an informal\nagreement was found

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

gains. The AO also pointed out that as per the\noriginal debenture purchase agreement, the holder of debentures was\nentitled to a coupon payment at 13.75%. However, no such coupon or\ninterest income was realized or considered at the time of redemption.\nThe assessee’s claim that waiver of interest was based on an informal\nagreement was found