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

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

253 ITR 749 (Guj)\n\n13.14 The assessee relied on the decision Hon'ble Supreme\nCourt in State of Bihar v. Kalika Kuer @ Kalika Singh & Others 5\nSCC 448 for the proposition that even if the earlier decision of the\nCo-ordinate Bench seems to be incorrect to a Bench of the same\njurisdiction on the ground that a possible

AKSHAY KUMAR RUNGTA,BANGALORE vs. INCOME TAX OFFICER, WARD 2(1), INTERNATIONAL TAXATION

In the result, appeal filed by the assessee is allowed as per above terms

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubeyit(It)A No.66/Bang/2024 Assessment Year :2015-16

capital gain has been earned by sale of share as penny stock. After recording of reasons and taking necessary approval from the competent authorities as per extended date by the CBDT, the approval was granted and notice under section 148 of the Act was issued to the assessee. The assessee furnished reply on 30.10.2023 and the assessee also furnished reply

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

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

5. The Appellant craves leave to add, to alter, to amend or to delete any of the grounds that may be urged at the time of hearing of the Appeal Wherefore on the above grounds and on such other grounds the Appellant prays the Appellate Authority to set aside the Assessment order and may pass such other as the Appellate

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

gainfully refer to the “MEMORANDUM EXPLAINING FINANCE BILL 2013”, which brings out the intention of the Parliament in inserting Explanation-2 in sec. 36(1)(vii) of the Act. It is extracted below:- “Clarification for amount to be eligible for deduction as bad debts in case of banks:- Under the existing provisions of section 36(1)(viia) of the Income

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

gainfully refer to the “MEMORANDUM EXPLAINING FINANCE BILL 2013”, which brings out the intention of the Parliament in inserting Explanation-2 in sec. 36(1)(vii) of the Act. It is extracted below:- “Clarification for amount to be eligible for deduction as bad debts in case of banks:- Under the existing provisions of section 36(1)(viia) of the Income

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

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

capital gains of Rs.44,97,253/- by denying the claim of exemption under section 54 of the Act. 3. Aggrieved, assessee filed appeal before the First Appellate Authority (FAA). The CIT(A) dismissed the appeal in limine without adjudicating the issues on merits since there was no response to the notices issued from the Office of the FAA to file

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

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

JNANAVAAHINI SHIKSHANA SAMSTHE MYSORE ,MYSURU vs. INCOME TAX OFFICER, EXEMPTION,WARD, MYSURU

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

Bench: Shri Keshav Dubeyjnanavaahini Shikshana Samsthe Income Tax Officer (Exemption), Ward-Mysuru Near Big Banyan Tree Nh-212, T Narsipura Road, Alnahalli, Mysuru, Vs. Karnataka Pan – Aabtj5183A (Appellant) (Respondent)

gaining the attention of the institution. No personal hearing was granted by the CIT(Appeals), and hence, the principles of natural justice was not followed. 2 Jnanavaahini Shikshana Samsthe Mysore 2. Incorrect Disclosure in ITR 2.1 The learned AO erred in making the assessment in the manner done by the learned AO. The learned AO erred in making the additions

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

NITESH KEKRE,BANGALORE vs. DCIT, CIRCLE-3(3)(1), BANGALORE

In the result appeal of the assessee is hereby allowed for statistical purposes

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

capital gain and interest etc. The assessee for the A.Y. 2017-18 filed return of income as on 27th July 2017 declaring income at Rs. 2,06,36,780/- which included income earned outside India. The assessee against the tax liability claimed credit of foreign tax of Rs. 81,178/- only. The claim of foreign tax credit (FTC) was disallowed

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

5 nominees from Central Government as well as State Government. In our view, the control or directions issued by the State Government would not change the character of “business activity”. We are of the view that activity carried out by the assessee should be examined independently and the fact that assessee is being regulated by the State Government would

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

5 nominees from Central Government as well as State Government. In our view, the control or directions issued by the State Government would not change the character of “business activity”. We are of the view that activity carried out by the assessee should be examined independently and the fact that assessee is being regulated by the State Government would

M/S. BANGALORE METRO RAIL CORPORATION LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1(1)(2), BANGALORE

In the result, all the appeals of the assessee as well as revenue’s appeal are partly allowed for statistical purposes

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2011-12

5 nominees from Central Government as well as State Government. In our view, the control or directions issued by the State Government would not change the character of “business activity”. We are of the view that activity carried out by the assessee should be examined independently and the fact that assessee is being regulated by the State Government would