SHRI. G B SHIVARAJAPPA,BANGALORE vs. INCOME TAX OFFICER, WARD - 4(2)(4), BANGALORE

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

Bench: Shri George George K

capital gains for acquiring a house property, by making payments to the seller of the house property and has made a proper claim of deduction under section 54F of the Act, on the facts and circumstances of the case. 4. The learned CIT(A) was not justified in law and on facts in appreciating that the appellant has acquired possession

ASST.C.I.T., BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

capital expenditure incurred by the assessee. In reply, the learned counsel pointed out that the expenditure by way of technical know- how was capitalized and it was not claimed as revenue expenditure. Therefore, there was also no reason to disallow depreciation on such capitalized amount as the aforesaid provision does not deal with deduction of depreciation. Having considered arguments from

DCIT, BANGALORE vs. M/S WIPRO LTD.,, BANGALORE

Bench: Shri B.R. Baskaran, Accountantmember & Shri Pavan Kumar Gadaleit(Tp)A No.99/Bang/2014 Assessmentyear:2009-10

capital expenditure incurred by the assessee. In reply, the learned counsel pointed out that the expenditure by way of technical know- how was capitalized and it was not claimed as revenue expenditure. Therefore, there was also no reason to disallow depreciation on such capitalized amount as the aforesaid provision does not deal with deduction of depreciation. Having considered arguments from

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

244A of the Act on the amount of refund determined. Arithmetical error in computation of refund amount: 36. Notwithstanding and without prejudice to the above ground No. 34 and 35, the learned AO has erred in computing the total of tax refund (INR 16,01,166) and interest on refund IT(TP)A No.390/Bang/2021 Page

MAHESHWARAPPA MUNIRAMU,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, RANGE 2(2), BENGALURU, BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18 Maheshwarappa Muniramu #4261/17, 2Nd Cross, 20Th Main Subramanya Nagar Jcit Vs. Bengaluru 560 021 Range 2(2) Bangalore Pan No :Aempm8290C Appellant Respondent Appellant By : Sri Nagaraj K. H., Ca Respondent By : Sri Subramaniam, Jcit Dr Date Of Hearing : 30.06.2025 Date Of Pronouncement : 26.09.2025

244A thereon. During the financial year 2016-17 relevant for the Asst. year 2017- 18, the assessee along with his son Sri M. Sumanth had jointly sold an immovable property vide sale deed registered as document No.1401/2016-17 on 30.6.2016 for a total sale consideration of Rs.85,43,100/-, out of which Rs.20 lakhs was received in cash. The assessee owns

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

244A& 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assessing officer on which interest is levied are not discernible

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

244A& 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assessing officer on which interest is levied are not discernible

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

244A& 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assessing officer on which interest is levied are not discernible

RAMAMURTHY PRAVEEN CHANDRA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, we have allowed grounds raised by the assessee as per above terms for all the years

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

244A& 234 D of the Income Tax Act on the facts and circumstances of the case. The appellant contends that the levy of interest under section 234 B of the Act is also bad in law as the period, rate, quantum and method of calculation adopted by the learned assessing officer on which interest is levied are not discernible

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

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 is concerned, the facts and circumstances under which the said issue arises for consideration are that the Assessee is a company incorporated under

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

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 is concerned, the facts and circumstances under which the said issue arises for consideration are that the Assessee is a company incorporated under

KARNATAKA TELECOM DEPARTMENT EMPLOYEES CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 1(4), BLR, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

gains attributable to the activities of the assessee so as to be eligible under clause (a)(i) of section 80P(2) of the Act. Therefore, the interest income earned from bank deposits cannot be treated as business income attributable to the activities of the assessee society and is accordingly held to be ineligible for deduction under section

KARNATAKA TELECOM DEPARTMENT EMPLOYEES CO-OPERATIVE SOCIETY LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX,CENTRAL CIRCLE 1(4),BLR, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

gains attributable to the activities of the assessee so as to be eligible under clause (a)(i) of section 80P(2) of the Act. Therefore, the interest income earned from bank deposits cannot be treated as business income attributable to the activities of the assessee society and is accordingly held to be ineligible for deduction under section

KARNATAKA TELECOM DEPARTMENT EMPLOYEES CO-OPERATIVE SOCIETY LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME OF TAX, CENTRAL CIRCLE 1(4), BLR, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Soundararajan K.

gains attributable to the activities of the assessee so as to be eligible under clause (a)(i) of section 80P(2) of the Act. Therefore, the interest income earned from bank deposits cannot be treated as business income attributable to the activities of the assessee society and is accordingly held to be ineligible for deduction under section

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HUBBALLI vs. M/S. KARNATAKA VIKAS GRAMEEN BANK LIMITED, DHARWAD

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

244A of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts of the case 6. The Appellant craves leave of this Hon'ble Income Tax Appellate Tribunal to add, alter, delete or substitute

M/S KARNATAKA VIKAS GRAMEENA BANK,DHARWAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HUBBALLI

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

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

244A of the Act is also bad in law as the period, rate, quantum and method of calculation adopted on which interest is levied are all not discernible and are wrong on the facts of the case 6. The Appellant craves leave of this Hon'ble Income Tax Appellate Tribunal to add, alter, delete or substitute

VMWARE SOFTWARE INDIA PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(2), BANGALORE

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

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.2127/Bang/2017 : Asst.Year 2012-2013 M/S.Vmware Software India The Deputy Commissioner Of Private Limited, Kalyani Magnum Income-Tax, Circle 7(1)(2) V. Bangalore. Block-I, 3Rd Floor 165/2 Doraisanipalya, Iim Post Bannerghatta Road Bengaluru – 560 076. Pan : Aaccv4573E. (Appellant) (Respondent) Appellant By : Sri.T.Suryanaranayana, Advocate Respondent By : Dr.Manjunath Karkihalli, Cit -Dr Date Of Pronouncement : 17.06.2022 Date Of Hearing : 03.06.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 24.01.2017 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2012-2013. 2. The Issues Raised In The Appeal Are As Follows:- (I) Validity Of The Impugned Final Assessment Order; (Ii) Transfer Pricing (Tp) Adjustment Of Rs.26,85,43,457 Made By The Transfer Pricing Officer (Tpo) Towards The International Transactions Of Provision Of Contrct Software Development & Information Technology Enabled Services To The Assessee’S Associated Enterprises (Aes); (Iii) Addition Of Rs.7,62,39,388 Being The Alleged Suppressed Income Of The Assessee; & 2 It(Tp)A No.2127/Bang/2017. M/S.Vmware Software India Private Limited.

capital adjustment and treatment of foreign exchange gain / loss as operating in nature for the Appellant and the comparable companies; 18. On the facts and circumstances of the case, learned Assessing Officer erred in not giving effect to the directions issued by the learned Panel wherein post the DRP directions entire TP adjustment for software development services segment ought

WEP PERIPHERALS LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-7(1)(2), BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2012 – 13

gains arising before the 1st day of April, 1946, or after the 31st day of March, 1948 , and before the 1st day of April, 1956. Explanation 2.-- The expression" accumulated profits" in sub- clauses (a), (b), (d) and (e), shall include all profits of the company up to the date of distribution or payment referred to in those sub- clauses