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

254 to 274 of\nthe Paper book in ITA No.776/Bang/2024] wherein the taxation of\ncapital gains on receipt of possessions by the landowners has been\naccepted.\n5.1 The assessees had also furnished a copy of its katha after\ndevelopment, as undertaken before the Hon'ble Bench vide a\nseparate memo filed on 02/08/2024.\n6. On the other-hand both

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

254 the\nTribunal cannot go beyond the provisions of the said Section,\nthe fact remains that the petitioner has substantiated that\ninjustice is being done by not following the Division Bench\ndecision of this Court. Therefore, in order to do substantial\njustice, this Court exercising the power under Articles 226 and\n227 of the Constitution of India can condone

HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

254 ITR 22 has held that the section 54 speaks of purchase only and for availing benefit under this section it is not necessary that the assessee should become the owner of property by evidencing the registration thereof. The relevant findings are reproduced below for ease of reference & convenience- “3. The Assessing Officer, the appellate authority as well

NAVJYOTI SHARMA,BANGALORE vs. DCIT ASMNT, BANGALORE

In the result appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

254 ITR 22 has held that the section 54 speaks of purchase only and for availing benefit under this section it is not necessary that the assessee should become the owner of property by evidencing the registration thereof. The relevant findings are reproduced below for ease of reference & convenience- “3. The Assessing Officer, the appellate authority as well

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

In the result, appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

254 of the Income Tax Act, 1961 (in short “The Act”) for the AYs 2013-14 & 2014-15. Since the issues in both the appeals are common, these are clubbed together, heard together and disposed of by this common order for the sake of convenience. The grounds raised by the assessee for the Asst. year 2013-14 in ITA No.937/Bang/2024

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

In the result, appeals of the assessee are partly allowed

capital gain tax can be levied. \" 53. Concluded at page 12\npara 21 as under:\n\"27. In the result, we hold that sub-section 115JB as it stood prior to\nits amendment by virtue of Finance Act, 2012, would not be applicable\nto a banking company. We answer the question No. 2 in favour of the\nassessee and against

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

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

SMT SUSHAMA RAJESH RAO ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-5(2)(1) , BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan Kassessment Year: 2012-13 Sushama Rajesh Rao, Vs. The Deputy Commissioner No.159, Priyadarshani, R. T. Nagar, Of Income Tax, Mla Layout, Circle – 6(2)(1), Bangalore – 560 032. Bangalore. Pan : Acypr 5251 J Appellant Respondent Appellant By : Shri. V. Chandrashekar, Advocate Respondent By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 23.07.2025 Date Of Pronouncement : 18.08.2025

254 of the Income Tax Act, 1961 (hereinafter referred to as "Act") dated 07.12.2022 for Assessment Year 2012-13 in so far as it is against the Appellant is opposed to law, weight of evidence, natural justice, probabilities, facts and circumstances of the Appellant's case. 2. The Appellant denies herself liable to be assessed on a total income

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

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

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

section 80JJAA being disallowed. 17.1. The Ld.AR submitted that copy of the Audit report under section 80JJAA, being Form No. 10DA was submitted to the Ld.AO vide submission dated 28.5.2014. The Ld.AO thereafter called upon assessee to justify the allowability of deduction under section 80JJAA. The assessee explained in detail as to why deduction under section 80JJAA should be allowed

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

capital expenditure is governed by the Section 43A of the Act. Since in the above batch of the appeals, the assessment year involved was 1998-99, the SC decided the issue in view of Section 43A (pre-amended w.e.f. 01/04/2003) of the Act. After 1-4-2003, the issue is governed by the amended Section

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX RANGE-12 , BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

capital expenditure is governed by the Section 43A of the Act. Since in the above batch of the appeals, the assessment year involved was 1998-99, the SC decided the issue in view of Section 43A (pre-amended w.e.f. 01/04/2003) of the Act. After 1-4-2003, the issue is governed by the amended Section

M/S HARMAN CONNECTED SERVICES CORPORATION INDIA PRIVATE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-3(1)(2), BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariita Nos.1980 To 1982/Bang/2018 Assessment Years: 2009-10, 2010-11 & 2012-13

capital expenditure is governed by the Section 43A of the Act. Since in the above batch of the appeals, the assessment year involved was 1998-99, the SC decided the issue in view of Section 43A (pre-amended w.e.f. 01/04/2003) of the Act. After 1-4-2003, the issue is governed by the amended Section

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

2)(i), as "Income from other sources". Although the shares are held on the investment portfolio as an integral part of the business, the interest on such borrowings is allowable under section 36(1)(iii). Thus, the qualifying factor to ascertain whether the borrowings for purchasing shares is an integral part of the business of the assessee. The interest

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 16 of 116 Tribunal. The Tribunal should not be prevented from

MRS. MALAVIKA HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 16 of 116 Tribunal. The Tribunal should not be prevented from

MR. AMARTHYA SIDDHARTHA L/R OF LATE SRI. V G . SIDDHARTHA ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 16 of 116 Tribunal. The Tribunal should not be prevented from

MR. ISHAAN HEGDE L/R OF LATE SRI. V G SIDDHARTHA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOMER TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result the appeal filed by the revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

254 only to decide the grounds which arise from the order of the Commissioner of Income-tax (Appeals). Both the assessee as well as the Department have a right to file an appeal/cross-objections before the . ITA No.1442 to 1447, 2129 to 2132, 1448 to 1453 & 1454 to 1459/Bang/2024 Page 16 of 116 Tribunal. The Tribunal should not be prevented from