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

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

217 – 222 of PB) Operating System (supra) 3.13 Nevertheless, with respect to the section 201 proceedings initiated on IBM India on the same subject matter, while the appeals were pending before the ITAT and despite the fact that the Hon’ble ITAT constituted a Special Bench to hear the appeals, noting the judicial conflict in the views expressed by various

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

217 – 222 of PB) Operating System (supra) 3.13 Nevertheless, with respect to the section 201 proceedings initiated on IBM India on the same subject matter, while the appeals were pending before the ITAT and despite the fact that the Hon’ble ITAT constituted a Special Bench to hear the appeals, noting the judicial conflict in the views expressed by various

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Capital during the year: On Para 15.2, the learned Assessing Officer has detailed the disallowance of 1,24,17,338/- as under: Date Bank Account details Credit:- Remarks 06.04.2015 ICICI Bank SB 10,00,000.00 This amount is transferred No.055901501971 from NRE A/c to ICICI Bank A/c 26.06.2015 Bharat Co-Operate Bank 15,00,000.00 This amount is transferred A/c.003212100002005

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Capital during the year: On Para 15.2, the learned Assessing Officer has detailed the disallowance of 1,24,17,338/- as under: Date Bank Account details Credit:- Remarks 06.04.2015 ICICI Bank SB 10,00,000.00 This amount is transferred No.055901501971 from NRE A/c to ICICI Bank A/c 26.06.2015 Bharat Co-Operate Bank 15,00,000.00 This amount is transferred A/c.003212100002005

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

C’’ BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER IT(TP)A No.735/Bang/2018 Assessment Year: 2013-14 M/s. Infosys Ltd. Electronic City Hosur Road ACIT Circle-3(1)(1) Vs. Bangalore 560 100 Bangalore PAN NO : AAACI4798L APPELLANT RESPONDENT Assessment Year: 2013-14 Deputy Commissioner of M/s. Infosys Ltd. Income-tax Electronic City Circle

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

C’’ BENCH: BANGALORE BEFORE SHRI N.V. VASUDEVAN, VICE PRESIDENT AND SHRI CHANDRA POOJARI, ACCOUNTANT MEMBER IT(TP)A No.735/Bang/2018 Assessment Year: 2013-14 M/s. Infosys Ltd. Electronic City Hosur Road ACIT Circle-3(1)(1) Vs. Bangalore 560 100 Bangalore PAN NO : AAACI4798L APPELLANT RESPONDENT Assessment Year: 2013-14 Deputy Commissioner of M/s. Infosys Ltd. Income-tax Electronic City Circle

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nrequirements of sec.14A of the Act. Accordingly

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nrequirements of sec.14A of the Act. Accordingly

HEWLETT PACKARD INDIA SALES PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

gains of business or profession",— (a) in the case of any assessee— ******* (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVII-B and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1

JCIT, BANGALORE vs. M/S HEWLETT - PACKARD INDIA SALES PRIVATE LIMITED, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

gains of business or profession",— (a) in the case of any assessee— ******* (ia) thirty per cent of any sum payable to a resident, on which tax is deductible at source under Chapter XVII-B and such tax has not been deducted or, after deduction, has not been paid on or before the due date specified in sub-section (1

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BANGALORE

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that the disallowance voluntarily made by the assessee would meet the ITA Nos.780 to 785/Bang/2024 & CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY ENTERPRISES, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that the disallowance voluntarily made by the assessee would meet the ITA Nos.780 to 785/Bang/2024 & CO Nos.15

DEPUTY COMMISSIONER OF INCOME-TAX, , BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that the disallowance voluntarily made by the assessee would meet the ITA Nos.780 to 785/Bang/2024 & CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO

Bench: Shri Chandra Poojari & Smt. Beena Pillai

capital gain was also earned on sale of shares of M/s Mindtree limited. We notice that, as in the earlier year, the disallowance made by the assessee voluntarily is more than the amount of exempted income. Hence, we are of the view that the disallowance voluntarily made by the assessee would meet the ITA Nos.780 to 785/Bang/2024 & CO Nos.15

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nrequirements of sec.14A of the Act. Accordingly

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BANGALORE vs. COFFEE DAY GLOBAL LIMITED, BANGALORE

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nrequirements of sec.14A of the Act. Accordingly

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY GLOBAL LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nPage 7 of 26\nrequirements of sec.14A

DCIT, CENTRAL CIRCLE-1(3), BENGALURU, BENGALURU vs. COFFEE DAY ENTERPRISES LIMITED, BENGALURU

In the result, all the COs by assessee in CO\nNos

capital gain was also earned on\nsale of shares of M/s Mindtree limited. We notice that, as in the earlier\nyear, the disallowance made by the assessee voluntarily is more than\nthe amount of exempted income. Hence, we are of the view that the\ndisallowance voluntarily made by the assessee would meet the\nPage 7 of 26\nrequirements of sec.14A