SRI ALAGAPPA MUTHIAH(HUF),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(4), BANGALORE

In the result, both the appeals of the assessees are allowed\nand revenue appeals are dismissed

251\n1,05,150\n45,00,000\n5,61,800\n[C]\n1,12,92,691\n1,12,92,691\nTotal Long Term Capital Gains\n1/2 Share of assessee in Total Long\nTerm Capital Gains\n[D]\n29,21,90,606 [D]\n14,60,95,303\n54,28,86,124\n27,14,43,062\n3.8 In the assessment proceedings

IBM ISRAEL 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

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant

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

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant

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

1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued. Pursuant

M/S. ATRIA WIND (KADAMBUR) PRIVATE LIMITED,BENGALUAU vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Soundararajan K.Assessment Year: 2017-18

section 47(xiii) of the Act. The ld. CIT(A) had dismissed the appeal and confirmed the addition made under the head capital gains and in respect of the ground No.6, which relates to the levy of interest u/s 234B & 234C of the Act, the ld. CIT(A) had remitted the issue to the file of AO for recomputing

MR. RAMESH KUMAR,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), MANGALURU

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

capital gains tax under Section 45 of the Act could not be levied for this Assessment Year.", "result": "Allowed", "sections": [ "2(47)(v)", "53A", "45", "234A", "234B", "234C", "133A", "142(1)", "143(2)", "251

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BENGALURU, BENGALURU vs. INFOSYS LIMITED, BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

251 including Rs. 52,10,92,957 on account of foreign tax credit in respect of taxes presently under dispute with Australian tax authorities (ATO)) in respect of income on which deduction under section 10AA has been claimed. 4.2 The learned CIT(A) erred in not appreciating that foreign tax credit in respect of income on which deduction under section

INFOSYS LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is partly allowed and the\nappeal filed by the revenue is dismissed

Bench: Shri Waseem Ahmed\Nand\Nshri Keshav Dubey\N\N\Nita No. 881/Bang/2023\N Assessment Year: 2019-20\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nvs.\N\Ndy. Commissioner Of Income Tax\Ncircle - 3(1)(1)\Nbmtc Building, 80 Feet Road\Nkoramangala, Bangalore – 560095\Nkarnataka\N\Nrespondent\N\Nita No. 245/Bang/2024\N Assessment Year: 2019-20\N\Njt. Commissioner Of Income Tax (Osd)\Ncircle - 3(1)(1)\Nroom No. 241, 2Nd Floor\Nbmtc Building, 80 Feet Road\N6Th Block, Koramangala\Nbangalore - 560095\Nkarnataka\N\Nvs.\N\Ninfosys Limited\Nplot 44, Konappana Agrahara\Nhosur Road, Konappana\Nbangalore - 560100\Nkarnataka\N\Npan: Aaaci4798L\N\Nappellant\N\Nrespondent\N\Nassessee By\Ndepartment By\N\Nsri Padam Chand Khincha – Ca\Nsmt. Srinandini Das – Cit - Dr\N\Ndate Of Hearing\Ndate Of Pronouncement:\N\N09.05.2025\N06.08.2025\N\Norder\N\Nper Keshav Dubey:\N\Nthese Cross Appeals Are Filed Against The Order Of Ld. Commissioner Of\Nincome Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short \"Ld.\Ncit(A)/Nfac] Vide Din & Order No. Itba/Nfac/S/250/2023-24/1056786183(1) Dated 05.10.2023 Passed U/S.250 Of The Income Tax\Nact, 1961 (In Short “The Act\") For The A.Y.2019-20.\N\Npage 2 Of 34\N\N2. The Assessee Has Raised The Following Grounds Of Appeal: - \N\N\"1.\N\Ngeneral Ground\N\N1.

251 including Rs.\n52,10,92,957 on account of foreign tax credit in respect of taxes presently\nunder dispute with Australian tax authorities (ATO)) in respect of income on\nwhich deduction under section 10AA has been claimed.\n\n4.2 The learned CIT(A) erred in not appreciating that foreign tax credit\nin respect of income on which deduction under

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

GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE 26.10.2020 26.10.2020 26.10.2020 26.10.2020 A53A RETURN FILED 25.11.2020 25,11.2020 25.11.2020 25.11.2020 ADDITION MADE DISALLOWED

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

GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE 26.10.2020 26.10.2020 26.10.2020 26.10.2020 A53A RETURN FILED 25.11.2020 25,11.2020 25.11.2020 25.11.2020 ADDITION MADE DISALLOWED

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

GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE 26.10.2020 26.10.2020 26.10.2020 26.10.2020 A53A RETURN FILED 25.11.2020 25,11.2020 25.11.2020 25.11.2020 ADDITION MADE DISALLOWED

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

GAIN 12563022 IOS 101974790 51714335 152804718 57852150 TOTAL INCOME 367996150 1286588270 669502500 387279160 RETURN FILED ON139(1) 29.09.2013 28.0902014 30.09.2015 17.10.2016 143 (1) 31.10.2014 1,20,62,015 17.01.2017 80602017 143(3) ( RETURNED INCOME ACCEPTED 29.03.2016 29.12.2016 153C NOTICE 26.10.2020 26.10.2020 26.10.2020 26.10.2020 A53A RETURN FILED 25.11.2020 25,11.2020 25.11.2020 25.11.2020 ADDITION MADE DISALLOWED

NORTHERN OPERATING SERVICES PRIVATE LIMITED,ARGON SOUTH TOWER vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE 5 (1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2020-21 M/S. Northern Operating Services Pvt. Ltd., Vs. Dcit, 2Nd Floor Rmz Ecopace, Circle – 5(1)(1), Campus 1C, Bengaluru. Sarjapur Outer Ring Road, Bellandur, Bengaluru – 560 103. Pan : Aaccn 1652 J Appellant Respondent Assessee By : Ms. Divya Motwani, Ca. Revenue By : Shri. D. K. Mishra, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 26.09.2024 Date Of Pronouncement : 27.09.2024

251 (Bangalore – Trib.) had decided the issue in favour of the assessee. The learned AR further submitted that the matter need not be restored to the files of the AO without any allegations of the AO or DRP that assessee has not satisfied any conditions specified under section 80G of the Act. Lastly, it was contended that the donation receipts

NAGARAJU MUNIYAPPA ,KAGGALIPURA POST, KANAKAPU BADE KATTE vs. INCOME TAX OFFICER WARD 7(2)(5), BANGALORE, BANGALORE, KARNATAKA

In the result, the appeal is allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2016-17

Capital Gains”, thereby proposing a variation to that extent in the returned income. Finally, the total income was determined by the AO at ₹1,02,80,125 after making the addition of the amount discussed above. . Page 3 of 7 Aggrieved by the order of AO, the assessee preferred an appeal before

RANGARAJ ROHINI,INDIRANAGAR BANGALORE vs. DEPUTY COMMSSIONER OF INCOME TAX ASMNT CIRCLE 2(1) BANGALORE, KORMANGALA BANGALORE

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

Bench: Shri Waseem Ahmed & Shri Prakash Chand Yadav

capital gains to Rs. 1,11,26,626/- (from Rs. 64,86,375/- claimed by the assessee). As such, the excess indexed cost of acquisition of Rs. 46,40,251/- was disallowed by the AO and added back to the returned income of the assessee. 5. The assessee filed objections before the ld. DRP, which upheld the AO's decision

M/S. ANAND DIAGNOSTIC LABORATORY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

gains of such transfer of capital assets does not fall on the erstwhile firm. This decision is wholly against the revenue. The revenue placed on the decision of the CIT v. Mansukh Dyeing & Printing Mills [2022] 145 taxmann.com 151/[2023] 290 Taxman 354/[2022] 449 ITR 439 (SC)/2022 SCC Online SC 1618 The facts of the case have been

M/S. ANAND DIAGNOSTIC LABORATORY,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(4), BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Soundararajan K.

gains of such transfer of capital assets does not fall on the erstwhile firm. This decision is wholly against the revenue. The revenue placed on the decision of the CIT v. Mansukh Dyeing & Printing Mills [2022] 145 taxmann.com 151/[2023] 290 Taxman 354/[2022] 449 ITR 439 (SC)/2022 SCC Online SC 1618 The facts of the case have been