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

264 crores, and is not at all comparable to the operations of the Assessee. Detailed submissions in this regard are placed at pages 303-308 of the paperbook. 15.4 In respect of the above 4 companies, reliance is placed on the decision of this Tribunal in the case of Sonus Networks India Pvt. Ltd. v. DCIT (order dated 14.10.2020 passed

ACIT, CIRCLE-2(2)(1), BANGALORE vs. CANARA BANK, BENGALURU

In the result, appeal filed by the Revenue is dismissed

264/-.\nAfter denying the submissions of the assessee, the CPC added the total income\nof the assessee at Rs.26,43,80,59,650/- under regular provisions after making\naddition of Rs.26,43,80,59,650/- pertaining to recovery from bad debts written\nof accounts. The AO, CPC, also computed the income of the assessee under\nsection 115JB

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2, LTU, BENGALURU vs. M/S. ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

gains derived from any industrial undertaking engaged in the manufacture or production . IT(TP)A No.446 & 593/Bang/2020 Page 13 of 41 of article or thing. Admittedly this condition is satisfied in the case of the Assessee. 2. There are certain prohibition laid down in Sec. 80JJAA(2) of the Act and it is not the case of the Ld.AO that

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIVATE LIMITED,BENGALURU vs. THE JOINT COMMISSIONER OF INCOME TAX, LARGE TAX PAYERS UNIT, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Soundararajan K

gains derived from any industrial undertaking engaged in the manufacture or production . IT(TP)A No.446 & 593/Bang/2020 Page 13 of 41 of article or thing. Admittedly this condition is satisfied in the case of the Assessee. 2. There are certain prohibition laid down in Sec. 80JJAA(2) of the Act and it is not the case of the Ld.AO that

CHITRADURGA ZILLA REDDY JANA SANGH(R),CHITRADURGA vs. INCOME TAX OFFICER, WARD-1 EXEMPTION, HUBLI

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18

capital account. Therefore, the disallowance of exemption u/s 11 of the Act should be restricted to the shortfall of 85% of total income from actual amount applied. Hence, the shortfall of Rs. 50,23,822/- (1,47,63,150 – 97,39,328) should be brought to tax instead of Rs.76,29,084/- as done in intimation and accordingly granted relief

HEWLETT PACKARD INDIA SALES PVT. LTD.,,BANGALORE vs. JCIT, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

264,92,26,481 advance: 2 Addition of deferred revenue 346,02,21,726 Undisclosed income detected from TDS 3 279,40,71,311 certificates Addition of undisclosed sales on 4 916,08,87,209 account of goods: 5 Disallowances of other audit entries: 36,89,24,197 Page 8 ITA Nos. 579 & 593/Bang/2015 Disallowance of claim of deduction

JCIT, BANGALORE vs. M/S HEWLETT - PACKARD INDIA SALES PRIVATE LIMITED, BANGALORE

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Hp India Sales Pvt. Ltd. (Formerly Known As The Joint Hewlett-Packard India Commissioner Sales Pvt. Ltd.), Of Income Tax, 24, Salarpuria Arena, Ltu, Hosur Main Road, Bangalore. Vs. Adugodi, Bangalore – 560 030. Pan: Aaacc9862F Appellant Respondent & Assessment Year : 2009-10 (By Revenue) : Shri Percy Pardiwala, Sr. Assessee By Advocate Revenue By : Shri Saravanan B, Cit-Dr

264,92,26,481 advance: 2 Addition of deferred revenue 346,02,21,726 Undisclosed income detected from TDS 3 279,40,71,311 certificates Addition of undisclosed sales on 4 916,08,87,209 account of goods: 5 Disallowances of other audit entries: 36,89,24,197 Page 8 ITA Nos. 579 & 593/Bang/2015 Disallowance of claim of deduction

TOYOTA KIRLOSKAR MOTOR PRIVATE LIMITED,BANGALORE vs. DCIT, CIRCLE-7(1)(1), BANGALORE

In the result, appeal of the assessee is partly allowed

Bench: Shri George George K. & Shri Chandra Poojari

Gains of Business or Profession” do not refer to or include the amounts computed under Chapter X and therefore addition made under Chapter X is bad in law; b. Not appreciating that the provisions of section 40A(2) override the provisions of Chapter X and there being no action under section 40A(2) for royalty expenses, no adjustment under Chapter

M/S. AMALA JYOTHI VIDYA KENDRA TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME-TAX (CENTRAL),, BANGALORE

In the result, appeals of the assessee are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2021-22

capital expenditure which otherwise is not an allowable expenditure would be considered as application in the event of an assessee trust enjoying the benefits of the registration. Under the circumstances, the law that should apply is with reference to the year of default. He submitted that the Pr. Commissioner of Income Tax (Central) should have acted

M/S. ADARSH VIDYA KENDRA TRUST,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), , BANGALORE

In the result, appeals of the assessee are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2021-22

capital expenditure which otherwise is not an allowable expenditure would be considered as application in the event of an assessee trust enjoying the benefits of the registration. Under the circumstances, the law that should apply is with reference to the year of default. He submitted that the Pr. Commissioner of Income Tax (Central) should have acted

M/S. AMALA JYOTHI VIDYA KENDRA TRUST ,BENGALURU vs. THE PR. COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

In the result, appeals of the assessee are allowed

capital\nexpenditure which otherwise is not an allowable expenditure would\nbe considered as application in the event of an assessee trust\nenjoying the benefits of the registration. Under the circumstances,\nthe law that should apply is with reference to the year of default. He\nsubmitted that the Pr. Commissioner of Income Tax (Central) should\nhave acted

M/S. ADARSH VIDYA KENDRA TRUST,BENGALURU vs. THE PR. COMMISSIONER OF INCOME TAX, CENTRAL , BANGALORE

In the result, appeals of the assessee are allowed

capital\nexpenditure which otherwise is not an allowable expenditure would\nbe considered as application in the event of an assessee trust\nenjoying the benefits of the registration. Under the circumstances,\nthe law that should apply is with reference to the year of default. He\nsubmitted that the Pr. Commissioner of Income Tax (Central) should\nhave acted

M/S. SRI. SRINIVASA EDUCATIONAL & CHARITABLE TRUST,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(3), BANGALORE

In the result, the appeal of the assessee is allowed

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

capitation fee received in cash but not recorded in the books of accounts. 11. In response to the show cause notice, the assessee submitted its reply. However, the learned PCIT found that the assessee failed to substantiate its claims with documentary evidence. After considering the assessee’s reply, the materials seized during the search, and the statements of various individuals

M/S. NTT DATA GLOBAL SERVICES PRIVATE LIMITED,BANGALORE vs. THE JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE- 5, BANGALORE

264\nTotal Assessed Income\n309,31,53,514\n3.12.\nBeing aggrieved the Assessee has preferred the appeal before the\nTribunal on the ground reproduced at Paragraph 2 above which are\ntaken up hereinafter in seriatim.\nGround No. 1 to 13.3\n4.\nGround 1 to 13.3 raised by the Assessee pertain to the TP addition.\nWhen the appeal was taken

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

capital, payouts etc. The entire handling of cash is done\nby me and my assistant Shri. Mathew Joseph.\nPage 47 of 147\n20.8 However, it is noted by the ld. AO that the Chairman of the\ncompany Shri Paul P. John has not accepted income earned out of\ntrips of trucks was not accounted, which is in variance

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall