M/S UB SPORTS MANAGEMENT OVERSEAS LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX(INTERNATIONAL TAXATION) CIRCLE-1(2), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

M/S PALMER INVESTMENT GROUP LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-2(1), BANGALORE

In the result, the appeals filed by the assessees are partly allowed

Bench: Shri George George K. & Ms. Padmavathy S.

capital gains (based on the assessed income) of Rs. 96,52,74,468/-. We shall adjudicate the above two issues as under: - Re-computation of arm's length price of shares sold by the assessee amounting to Rs. 262,27,80,021/- (Ground Nos. 1 to 14): 6. The brief facts in relation to the above issue are that

VINAY KONCHADY SHENOY ,BANGALORE vs. INCOME TAX OFFICER, WARD-5(3)(1), , BANGALORE

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2019-20

3 of 6 property and other sources and also claimed loss from Long Term Capital Gain on sale of property to the extent of Rs.1,44,253/- 2.3 During the year, the assessee had sold residential property to the extent of Rs.77,50,000/- on 20.04.2019. Accordingly, the purchaser deducted TDS of Rs. 77,500/- (percentage on consideration paid

SHRI. BEHRA GOPAL KRISHNA RAO ,VISAKHAPATNAM vs. INCOME TAX OFFICER, WARD-1(1), MANGALURU

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

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2016-17 Shri. Behra Gopal Krishna Rao, The Income Tax Officer, Manidweep, Villa Or – 76, Ward – 1(1), Shriram Panorama Hills, Vs. Mangaluru. Law College Road, Yendada, Visakhapatnam – 530 045. Pan : Afkpk 2436 B Appellant Respondent Assessee By : Ms. Sunaina Bhatia, Ca Revenue By : Smt. Supriya Rao O. N, Addl. Cit(Dr), Itat, Bengaluru. Date Of Hearing : 26.07.2023 Date Of Pronouncement : 26.07.2023

section 143(3) of the Act was completed vide order dated 24.12.2018. In the said Assessment Order, AO had computed income from long term capital gains of Rs.44,97,253

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

capital fund. Thus, it is evident that interest on NCDs, interest on loan to Subsidiaries, interest on debentures, interest on Govt securities, interest on tax refunds, insurance claim, incentive from airlines and rental income from BSNL are offered to tax under the head Profits and gains of business and not under the head Income from other sources

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.

capital fund. Thus, it is evident\nthat interest on NCDs, interest on loan to Subsidiaries, interest on\ndebentures, interest on Govt securities, interest on tax refunds, insurance\nclaim, incentive from airlines and rental income from BSNL are offered to tax\nunder the head Profits and gains of business and not under the head\nIncome from other sources

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

In the result both the appeals of the Revenue as well as\nCos of the Assessee for the Asst

gains that are derived from the\nexport. There cannot be any doubt that interest income earned by\nmembers credit co-operative society can said to be \"attributable to\"\nthe business of providing credit facilities to its members. Kindly\nnote that the deduction u/s.80P is not with respect to an activity but\nwith reference to business as a whole

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Chandra Poojari & Smt. Beena Pillai

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: ITA Nos. 391, 392 & 663/Bang/2023 Page 13 of 31 "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE

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

Bench: Chandra Poojari & Smt. Beena Pillai

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: ITA Nos. 391, 392 & 663/Bang/2023 Page 13 of 31 "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question

DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 2(1)(1), BANGALORE vs. CANARA BANK, BANGALORE

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

Bench: Chandra Poojari & Smt. Beena Pillai

capital gain tax can be levied. " 53. Concluded at page 12 para 21 as under: ITA Nos. 391, 392 & 663/Bang/2023 Page 13 of 31 "27. In the result, we hold that sub-section 115JB as it stood prior to its amendment by virtue of Finance Act, 2012, would not be applicable to a banking company. We answer the question

HEWLETT PAKCARD INDIA SALES PRIVATE LIMITED,BANGALORE vs. JCIT, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

section 199 read with rule ITA No.1245 & 1252/Bang/2015 Page 17 of 70 37BA(3)(i) of the Income Tax Rules. Accordingly, we do not find any merit in ground No. 2 of the appeal, hence dismissed. 17. Ground Nos. 3 – 5 of the appeal is against the deletion of the addition of ₹ 1038, 88, 98,234/– made

JCIT, BANGALORE vs. M/S HEWLETT PACKARD INDIA SALES P. LTD.,, BANGALORE

In the result appeal of the ld AO is dismissed and Assessee is partly allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2010-11

section 199 read with rule ITA No.1245 & 1252/Bang/2015 Page 17 of 70 37BA(3)(i) of the Income Tax Rules. Accordingly, we do not find any merit in ground No. 2 of the appeal, hence dismissed. 17. Ground Nos. 3 – 5 of the appeal is against the deletion of the addition of ₹ 1038, 88, 98,234/– made

METAL CLOSURES PVT LTD,BANGALORE vs. ACIT, CIRCLE 4(1)(2), BANGALORE, BANGALORE

In the result, the appeal of the Revenue is treated as allowed for statistical purpose

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadavassessment Year: 2014-15

253 ITR 430 (Ker.). Now the plea of the assessee is that it has to be allowed u/s 28 of the Act. The section 28 of the Act reads as follows: “28. Profits and gains of business or profession. - The following income shall be chargeable to income-tax under the head "Profits and gains of business of profession

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

253)] 7. That even otherwise the initiation of proceedings u/s 153C of the Act is without jurisdiction and bad in law due to absence of the mandatory satisfaction as required u/s 153C(1) of the Act. a. That it is a borrowed satisfaction and has been recorded mechanically without application of mind. b. That the satisfaction recorded

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

253)] 7. That even otherwise the initiation of proceedings u/s 153C of the Act is without jurisdiction and bad in law due to absence of the mandatory satisfaction as required u/s 153C(1) of the Act. a. That it is a borrowed satisfaction and has been recorded mechanically without application of mind. b. That the satisfaction recorded

M/S. TECHNICOLOR INDIA PVT. LTD.,,GURGAON vs. DCIT, NEW DELHI

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2010-11

253(1) of the Income Tax Act, 1961 (the Act") against the order dated January 02, 2015 (received on February 17, 2015) passed under section 143(3) read with section 144C(13) of the Act passed by the Deputy Commissioner of Income Tax, Circle 25(1) and Page 2 of 27 25(2), New Delhi (AD") for the assessment year

CENTRE FOR E-GOVERNANCE ,BANGALORE vs. DCIT, EXEMPTION, CIRCLE-1 , BANGALORE

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

Capital Expenditure incurred, Income accumulated or set apart for e-Governance project under section 11(1)(2) and deduction under section 11(1)(a) for accumulation of 15 percentage of Gross Revenue as per provisions of the Act. Ground No-3 and Ground No-4 are complementary to the Ground No-2 wherein, Vide Ground No-3 the appellant

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

253 of the Act. There appears to be no justification for cutting Date of Order 07-11-2017 W.P.Nos.24646-24651/2015 Prathiba Jewellery House Vs. The Commissioner of Income-Tax (Appeals) & Ors., short that regular remedy at this stage and to entertain these writ petitions on merits.” 15.1 Being so, this ground in ITA Nos.982 to 987/Bang/2023 in assessment

JOHN DEVELOPERS,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

253 of the Act. There appears to be no justification for cutting Date of Order 07-11-2017 W.P.Nos.24646-24651/2015 Prathiba Jewellery House Vs. The Commissioner of Income-Tax (Appeals) & Ors., short that regular remedy at this stage and to entertain these writ petitions on merits.” 15.1 Being so, this ground in ITA Nos.982 to 987/Bang/2023 in assessment